Dr Richard Dune

26-06-2025

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From policy to practice: Understanding ICS structures, governance, compliance, and what they mean for health and social care providers in 2025

Integrated Care Systems (ICSs) represent one of the most significant NHS reforms in a generation. These place-based partnerships aim to transform how health and social care services are planned, commissioned, and delivered across England. The goal is clear: join up services, improve population health, reduce health inequalities, and enable more person-centred, sustainable, and efficient care.

In this blog, Dr Richard Dune explores how ICSs are structured, how Integrated Care Boards (ICBs) and Integrated Care Partnerships (ICPs) operate, and what this means for NHS providers, local authorities, social care organisations, the voluntary sector, and service users in 2025 and beyond.

What are ICSs

ICSs are partnerships of organisations, including the NHS, local authorities, voluntary and community groups, and others, that take collective responsibility for improving the health and care of the population within a defined geography. There are 42 ICSs across England, covering populations from 500,000 to over 3 million.

ICSs were legally established on 1 July 2022 under the Health and Care Act 2022, building on years of collaboration through Sustainability and Transformation Partnerships (STPs). These systems are not just about NHS structures; they embody a shift towards collaborative planning and service delivery across the public and voluntary sectors.

The four statutory aims of ICSs

ICSs are founded on four key statutory purposes:

• Improve outcomes in population health and healthcare
• Tackle inequalities in outcomes, access, and patient experience
• Enhance productivity and value for money through collaborative service design
• Support broader social and economic development, including employment and community wellbeing.

These objectives are reinforced by the NHS’s Triple Aim Duty, which legally requires all NHS bodies to consider the collective impact of decisions on:

• The health and well-being of the population
• The quality of services provided
• The sustainable and efficient use of resources.

ICSs are now the national mechanism to align strategy, funding, and accountability across entire health and care systems.

How are ICSs structured?

ICSs have two core components, these are:

• Integrated Care Boards (ICBs)
• Integrated Care Partnerships (ICPs).

Let’s discuss these in more details, below.

Integrated Care Boards (ICBs)

ICBs are statutory NHS bodies responsible for:

• Planning and funding NHS services (e.g. hospitals, GP practices, mental health, community care)
• Allocating NHS budgets in line with local priorities
• Managing system-wide performance
• Leading collaboration among providers
• Developing joint five-year forward plans.

ICBs have replaced Clinical Commissioning Groups (CCGs), absorbing their commissioning functions and expanding them to include a wider system perspective. Each ICB must work in alignment with the integrated care strategy developed by its ICP.

Integrated Care Partnerships (ICPs)

ICPs are statutory joint committees that bring together:

• NHS organisations
• Local authorities
• VCSE partners
• Public health bodies
• Education, housing, justice, and employment representatives.

They are tasked with developing a long-term strategy that addresses the wider determinants of health and guides the ICB’s plans.

ICSs, ICBs and ICPs: Working in tandem

Integrated Care Boards (ICBs) act as the operational and commissioning arms of each ICS, overseeing NHS budgets, service delivery, contracts, and performance. Integrated Care Partnerships (ICPs), formed in collaboration with local authorities, serve as the strategic arms, setting priorities through inclusive, population-focused strategies. Working together, they must:

• Align NHS and local authority strategies
• Respond to Joint Strategic Needs Assessments (JSNAs) and Joint Health and Wellbeing Strategies
• Develop long-term Integrated Care Strategies
• Ensure meaningful engagement with the public, VCSE partners, and Healthwatch to co-produce care that reflects local needs.

Neighbourhoods, places and systems: The ICS operating model

ICSs operate across three tiers:

Neighbourhoods (30,000–50,000 people)

• Anchored around Primary Care Networks (PCNs).
• Enable integrated working at the community level.
• Teams often include GPs, district nurses, social care workers, pharmacists, and representatives from the voluntary, community, and social enterprise (VCSE) sector.

Places (250,000–500,000 people)

• Usually align with local authority boundaries.
• Responsible for most service integration and redesign.
• Bring together NHS, councils, VCSEs, housing, and education leaders.

Systems (500,000–3 million people)

• Strategic system leadership and accountability.
• Plan workforce strategies, capital investment, digital infrastructure, and specialist services.

This subsidiarity model ensures decisions are made at the most appropriate local level.

Why do we need ICSs?

ICSs were created in response to:

• Rising complexity of long-term conditions.
• Fragmented services and siloed working.
• Widening health inequalities and social deprivation.
• The need to focus on prevention, early intervention, and joined-up support.

The old model of episodic care, focused on treatment, was failing to deliver coordinated, efficient, or person-centred care.

ICSs encourage:

• Collaborative service planning.
• Place-based, population-driven commissioning.
• Shared accountability for outcomes.

The role of Integrated Care Boards (ICBs)

Each ICB is responsible for:

• Commissioning all NHS services except those retained by NHS England
• Managing performance and transformation across the system
• Supporting digital innovation and workforce integration
• Engaging stakeholders, including providers, clinicians, patients, and citizens.

Key priorities in 2025 include:

• Reducing waiting times.
• Expanding access to community services.
• Delivering personalised care and shared decision-making.
• Meeting the expectations of the Provider Selection Regime (PSR).

What replaced CCGs?

ICBs replaced CCGs but go beyond commissioning to lead integrated, strategic delivery. While CCGs managed contracts, ICBs are now:

• Responsible for system-wide collaboration.
• Driving population health management.
• Coordinating multiple providers through Provider Collaboratives.

This shift is from transactional contracting to relational, outcomes-based commissioning.

Compliance and system oversight

In addition to CQC regulation, ICBs conduct:

• Quarterly reviews
• Integrated Quality and Performance Reporting
• Joint assurance frameworks.

Key compliance areas for providers:

• Data quality and digital maturity
• Patient safety and clinical governance
• Financial sustainability
• Health equity and community engagement
• Workforce capacity, diversity, and CPD.

Digital transformation and data sharing

ICBs are leading the digital transformation agenda, including:

• Shared Care Records across the NHS and social care
• Real-time dashboards for population health analytics
• Digitally-enabled care pathways and telehealth.

Providers must demonstrate:

• Compliance with UK GDPR and the DSP Toolkit
• Readiness for digital-first services
• Cybersecurity and IT infrastructure resilience
• Digital inclusion strategies for underserved groups.

Place-based partnerships and provider collaboratives

Each ICS includes place-based partnerships and provider collaboratives. Let’s discuss these two below.

Place-based partnerships

• Lead local service design and delivery
• Interface with neighbourhood teams and VCSE groups
• Translate the ICP strategy into community action.

Provider collaboratives

• At least two NHS trusts are working across systems.
• Focus on:

• Reducing unwarranted variation
• Improving resilience through mutual aid
• Delivering specialist services collaboratively.

Some collaboratives include independent and third-sector providers, particularly in the areas of mental health and community care.

What ICSs mean for providers

Whether you're an NHS trust, GP practice, private provider, or VCSE organisation, ICSs require new ways of working:

Providers must:

• Engage in system-wide planning
• Participate in collaborative governance
• Share data and insights for population health
• Design services that reflect community voices
• Evidence alignment with ICS objectives.

Opportunities include:

• Pilot funding for innovative models
• Access to place-based transformation programmes
• Co-leadership of strategic care pathways
• Improved CQC outcomes through proactive system alignment.

ICS priorities for 2025 and beyond

Key focus areas include:

• Roll-out of Integrated Neighbourhood Teams
• Personalised budgets for people with complex needs
• VCSE integration into commissioning structures
• Enhanced workforce development strategies
• Delivery of Green Plans for environmental sustainability.

ICBs will also report on:

• Capital investment plans
• System maturity assessments
• Digital infrastructure upgrades.

Challenges and risks

While ICSs bring enormous potential, risks remain:

• Fragmented engagement across different levels of the system
• Underdeveloped or inconsistent Place-based arrangements
• Tension between NHS priorities and local authority flexibility
• Risk of re-centralising control through ICBs
• Need for sustained investment in VCSE participation.

Oversight and national accountability

ICSs are held accountable to NHS England through ICBs. Additional oversight mechanisms include:

• CQC reviews of ICS performance under the 2022 Health and Care Act
• Public reporting on outcomes, access, and inequalities
• National benchmarking and inspection
• A developing Integration Index to measure progress from the service user’s perspective.

Final thoughts

ICSs are not just structural reforms; they represent a philosophical and operational shift in how health and social care are delivered. They emphasise collaboration over competition, population health over institutional boundaries, and prevention over reaction.

For providers, the message is clear: to remain relevant and resilient, you must be:

• Digitally mature
• System engaged
• Outcome driven
• Community responsive
• Governance aligned.

ICSs are where the future of health and care in England is being built. Whether you’re a frontline clinician, senior leader, or governance lead, now is the time to embed your service into the system’s core.

Align with ICS priorities using ComplyPlus™

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