White Paper Team

Room 601

Department of Health

79 Whitehall

London

SW1A 2NS

16th September 2010

Dear Sir/Madam,

Re: NHS Sustainable Development Unit response to the Department of Health consultation on the NHS White Paper: Liberating the NHS: Regulating healthcare providers

The NHS Sustainable Development Unit (SDU) welcomes the opportunity to respond to the NHS White Paper “Liberating the NHS: Regulating healthcare providers.” This response is in letter form to better convey overarching principles that the Sustainable Development Unit (SDU) would like to make.

The NHS SDU provides leadership, expert support, and technical guidance across the NHS and health system in relation to sustainability. The unit is keen to ensure that a joined up approach to economic, social and environmental sustainability are core to the health reforms and the QIPP agenda. Sustainability is an integral concept of excellence in regulating providers.

The Climate Change Act sets a legal requirement to achieve carbon reductions of 34% by 2020 and 80% by 2050. Work carried out by the NHS Sustainable Development Unit (SDU) for England indicates that the NHS needs to achieve a 10% reduction on 2007 levels by 2015 to meet the legal imperative. The act also highlights the requirement for climate change adaptation plans to be in place based on projected climate impacts relating to weather, specific illness, commodity price rises, increased migration and social impacts e.g. increased inequalities.

The case for sustainability in healthcare is clear. There is sound evidence that many components of sustainability achieve cost reductions and immediate health gains. It ensures the development of a sustainable system which reduces inappropriate demand, reduces waste and incentivises a more effective use of services and products[1]. It should therefore form an integral part of healthcare regulation.

We would therefore welcome a strengthening of the reporting requirements for healthcare providers around sustainability through both economic and quality components. At present Monitor require all Foundation Trusts to include a section on sustainability in their annual reports. The SDU would welcome the opportunity to support regulators in further developing the metrics and reporting mechanisms to ensure SD is fully embedded as a corporate priority.

Indeed every provider will need to ensure that it is fulfilling its legislative requirements in relation to climate change mitigation and adaptation. They will need to ensure that the organisation is striving to be truly viable and is adding economic, environmental and social value to its activities. Many leading NHS organisations have already recognised that sustainability at an organisational level goes beyond energy efficiency and aims to ensure a reduction in waste of time and resources, improved efficiencies and streamlined processes. Every organisation also has a responsibility to support its contribution to the local economy in terms of procurement, workforce, and community development, in recognition of the health benefits that can be achieved.

In summary the NHS SDU strongly recommends that the DH considers and truly embeds an integrated approach to social, economical and environmental sustainability into future NHS structures and functions including the regulation sysetm. It is our duty of care for the health of current and future generations.

Please do not hesitate to contact the unit for any further clarifications or questions in relation to this response. Thanking you for the opportunity to respond to the White Paper

Yours Faithfully,

Sonia Roschnik Hannah Greensmith

Operational Director Project Manager

NHS SDU NHS SDU

[1] Decision making in the NHS using Marginal Abatement Cost Curves: Save Money by Saving Carbon, 2010. Cambridge: NHS Sustainable Development Unit.