FOI 2025/1344

I am writing to you under the provisions of the Freedom of Information Act 2000 to request detailed disclosure regarding the appointment of CPUK Ltd to support the ongoing “independent review” of Manchester’s Community Mental Health Teams (CMHTs). This review is of significant public interest due to longstanding concerns about patient safety, preventable deaths, and the safe delivery of community services at Greater Manchester Mental Health NHS Foundation Trust (GMMH). Given the seriousness of these matters, it is essential that the commissioning of this investigation is transparent and that the independence and suitability of the provider are beyond question.

1. Procurement policy and processes at GM ICB: Firstly, I would like to understand the procurement process carried out by Greater Manchester ICB when appointing CPUK Ltd. Please confirm whether this commission was subject to a formal procurement route, such as open tendering, use of a framework agreement, or whether it was a direct award. Please provide all relevant documentation that records this procurement exercise, including any advertisements, invitations to tender, submissions from bidders, evaluation criteria, scoring processes, and decision-making matrices.

2. ICB providers’ credential checklist: Secondly, I request full disclosure of all supplier due diligence and credential checks undertaken prior to commissioning CPUK Ltd. Specifically, this should include evidence confirming the company’s registration and financial standing, particularly in light of Companies House records, which show dormant accounts filed up to 31 October 2024. I ask for copies of any insurance documentation held, such as professional indemnity and public liability cover, alongside safeguarding, GDPR, equality, whistleblowing, and complaints policies provided by the company. In addition, please provide any staff or investigator CVs, qualifications, accreditations, and other relevant background information reviewed by the ICB before confirming the appointment.

3. Independence criteria: Thirdly, I seek clarification on the independence and conflict of interest position relating to CPUK Ltd. Please provide copies of conflict-of-interest declarations submitted by CPUK Ltd or its directors, and any internal ICB assessments confirming that the company had no personal or professional connections to GMMH or ICB leadership that would compromise the integrity of the review.

4. Terms of reference and methodology: In addition, please release the Terms of Reference for this review in full, along with any documentation relating to the governance and oversight of the process. This should include details of any steering groups, advisory panels, or ICB representation involved in supporting or monitoring the review. I would also like to receive confirmation of the methodology being followed, particularly whether it is based on PSIRF principles, trauma-informed approaches, or other recognised frameworks, and details of the planned engagement with staff, patients, carers, and families.

5. Reporting transparency: I also request information on the transparency and reporting arrangements, including confirmation of whether the final report will be published in full and the timescales expected for publication. Please provide any internal ICB discussions or decisions which reflect whether this review’s findings will be made openly available to staff, stakeholders, and the public.

6. comparison matrix: Further, I would like disclosure of any documents that show how CPUK Ltd was evaluated against alternative providers. This includes comparison matrices, scorecards, or narrative assessments used to weigh CPUK Ltd against other consultancy firms and investigation providers with established reputations in NHS inquiries, such as Niche Health & Social Care Consulting or Verita. Alongside this, I ask for the rationale documented by the ICB in selecting CPUK Ltd, including consideration of financial health, relevant, staff qualifications, complaints history, independence, and transparency.

7. Finally, given the gravity of this review, I ask for any internal documents, minutes or correspondence within the ICB that acknowledge the whistleblowing concerns already raised about unsafe practice and preventable patient deaths, across CMHTS including those linked to the “Community Waiting Well” service at GMMH since its inception in 2022, and how these issues are intended to be addressed within the scope of the review.

This request is made in the public interest to ensure transparency, accountability, and confidence in an investigation of critical importance to patients, carers, staff and the Greater Manchester community. I request that all information is provided electronically. Where documentation is already openly published, please provide the relevant links.

I look forward to receiving your response within the statutory 20 working days, in accordance with the Freedom of Information Act 2000.

Background
In January 2024 the “Independent Review of Greater Manchester Mental Health NHS Foundation Trust Final Report, January 2024 authored by Professor Oliver Shanley OBE” was published. This report will be referred to as the “Shanley review” throughout this document.
Within the recommendations of the Shanley review there was a specific requirement which related to Community Mental health.
“Recommendation 9: We identified some common concerns across services we visited at the Trust, which were also prevalent within Edenfield. The Trust and the wider system must consider how they understand issues identified in these services (and others) in more detail, including through the actions described below
Bullet 4 under this recommendation is:
• As a second stage review, the Trust and its partners should identify together where and in which services further independent assurance is needed. We recommend that Community Mental Health Services are independently reviewed.”

Objectives
In line with the recommendations from the Shanely review NHS Greater Manchester (NHS GM) has commissioned an independent review to assess the provision of Community Mental Health Teams (CMHTs) the review of these services will be in line with themes identified in the Shanley Review and measure the safety and effectiveness of the services against what is commissioned.

• The objective of the review is to evaluate the extent to which CMHTs are delivering effective care and supporting meaningful recovery and in line with what is commissioned, the review will adopt a desk top review approach, alongside feedback from patients’ carers and staff to identify areas of good practice and gaps, provide recommendations for improvement, Support a commissioner-led review of CMHT services across GM to inform a revised service specification with clear, measurable outcomes.

Terms of Reference

• A Terms of Reference was developed and focus on core themes from the Shanley review which are the voice of patients, families and carers, Leadership, Culture , Workforce , Governance and Organisational learning and responsiveness, Oversight.

• Key Lines of inquiries have been developed as per the themes noted in the Shanley review and are described in the table below;

• The KLOEs will be addressed by applying a mixed methods approach which includes
• A review of performance data and relevant policies
• An audit of patient records
• Feedback from patients and carers
• Feedback from staff
• Feedback from stakeholders

Governance

• CPGB Ltd have been commissioned to carry out the review in Manchester (GMMH) and Heywood, Middleton and Rochdale (HMR) (PCFT) which is expected to conclude in Oct 2025.

• The final report will include findings, thematic analysis, and evidence-based recommendations aligned with the KLOEs and Shanley review themes.
• Recommendations should be made at all three spatial levels of the system, Provider, Place and System and displayed as such in the final report.
• The final report will be presented at the following NHS GM meetings.
• Mental Health Clinical Effectiveness Group (with an update to GM Clinical Effectiveness Group as required)
• Adult Community Group
• Mental Health Partnership board
• Quality & Performance Committee

• The review will be tracked and managed through its stages using a comprehensive project plan, held by a dedicated task and finish group to include representation from.
• Clinical Director, Mental Health (SRO, Chair)
• Programme Director
• Head on Mental Health Clinical Effectiveness
• Assistant Director, Adult Community
• Programme Manager, Adult Community
• Clinical Care Professional lead (CCPL) Adult Community

• The review is part of the Mental Health Programme team workplan within the remit of Clinical Effectiveness and Governance and in collaboration with the Community Mental Health transformation plan.
o Interim findings and progress throughout the review is shared at agreed touch points to ensure findings inform transformation priorities such as community mental health teams specification review, inpatient quality transformation work, intensive and assertive outreach quality improvement and other relevant programmes.

1. CPBG Ltd were appointed through an Invitation to Quote (ITQ) process, as the contract value was below the threshold set out in UK public procurement regulations.

The ITQ was issued to eight providers, all accredited on the NHS Independent Investigations Framework for Local Care System Investigations (Lot 3), including CPBG Ltd. In line with NHS Greater Manchester (NHS GM) procurement rules, a minimum of three quotes was required.

Several providers responded to the ITQ. Of these, CPBG Ltd were the only provider to submit a full bid. The remaining providers confirmed they could not deliver within the required timescale.

Bids were assessed against two criteria:
• Ability to deliver the review in accordance with the terms of reference provide.
• Ability to complete the review within the requested timescales.

CPBG ltd.’s submission met the criteria in full and they were therefore awarded the contract.

**PDF documents were sent to the requester with this response.  If you require a copy of the full response, together with the attachments, please contact NHS GM’s FOI team – nhsgm.foi@nhs.net.**

NHS GM considers the submissions from bidders, as exempt by virtue of Section 43(2). Section 43(2) exempts information whose disclosure would, or would be likely to, prejudice the commercial interests of any legal person (an individual, a company, the public authority itself or any other legal entity).

Public interest test

There is an inherent public interest in ensuring that there is openness and transparency in the spending of public money. Transparency is likely to increase confidence in procurement processes and the purchasing decisions made by NHS GM. It also enables the public to understand whether NHS GM is getting value for money from its purchasing decisions.

However, the release of this information would likely prejudice the commercial interests of the CPGB Ltd. The information could provide competitors with insights into pricing models and methodologies which would undermine the integrity of the procurement process and fair competition.

After considering the arguments outlined above, we have decided to withhold this information.

2. CPGB Ltd are accredited on the NHS Independent Investigations Framework. This framework enables NHS organisations to procure independent providers under a range of lots, which correspond to the type of investigation required. As part of the accreditation process, providers are required to evidence their credentials to NHS England.

The framework itself is not a publicly available document, as it is owned and managed by NHS England. For further information, including reference details and contact information for enquiries, can be found via the East of England Collaborative Procurement Hub Independent Investigations – East of England Collaborative Procurement Hub
3. In the bidders’ terms, attached to the ITQ conflicts of interest are required to be declared. Paragraph 1.11 which details this is referenced below
1.11 CONFLICTS OF INTEREST
The Contracting Authority requires all actual or potential conflicts of interest to be resolved to their satisfaction prior to the submission of Bids in response to this ITQ.
In the event that any actual or potential conflict of interest comes to a Bidder’s attention following the submission of its Bid, that Bidder should immediately notify the Contracting Authority.
Failure to declare such conflicts and/or failure to address such conflicts to the reasonable satisfaction of the Contracting Authority could result in a Bidder being disqualified.
CPGB ltd did not declare any conflicts of interest.
4. The TORs, which also include a suggested work plan, were presented to the Quality and Performance Committee, the Mental Health Partnership Group, and the System Improvement Board before the procurement process. Feedback from these groups has been incorporated into the final version. As a result:
• Elements have been strengthened to ensure health inequalities are addressed.
• An explicit description has been added on how the outputs and recommendations of the independent review will inform and align with the transformation work linked to the CMHT review specification and the wider review of community care.
• Clarity has been provided on which CMHT teams are within scope.
• A framework has been added to ensure cost–benefit analysis is applied to recommendations, supporting quality improvements in line with current priorities and ensuring best value.

The TORs require the use of mixed methodology, including analysis of data, policy and care audit, and feedback from patients, staff, and stakeholders. More detail is set out in the TORs attached.

As an NHS England–approved independent provider, CPGB Ltd apply appropriate methodologies for each aspect of the review, including the use of trauma-informed approaches when gathering the views of staff, patients, and carers.

**A PDF document was sent to the requester with this response.  If you require a copy of the full response, together with the attachments, please contact NHS GM’s FOI team – nhsgm.foi@nhs.net.**

5. The final report is expected to be completed before the end of the calendar year. This review has been commissioned to address the requirements set out by Shanley, with its recommendations intended to inform the ongoing transformation work to develop a single specification for CMHTs and to review the wider community services offer, in line with the requirements of the NHS Ten-Year Plan.
Once available, the report will be considered through the system governance processes, including the Quality and Performance Committee, and shared with stakeholders. Options for onward publication will also be reviewed.
6. CPGB Ltd were appointed using the NHS Independent Investigations Framework. The Invitation to Quote (ITQ) was issued to all providers accredited to deliver Local System Investigations (Lot 3) under the framework, excluding any with an active conflict of interest.
7. This review is focused on the themes identified in the Shanley review and has therefore been structured around them. It includes a number of KLOEs relating to both culture and workload, with a specific requirement to examine the effectiveness of Freedom to Speak Up processes. Further detail is provided in the attached Terms of Reference.

**PDF documents were sent to the requester with this response.  If you require a copy of the full response, together with the attachments, please contact NHS GM’s FOI team – nhsgm.foi@nhs.net.**