| Reference | FOI 2025/1424 |
|---|---|
| Description | Copies of documents:- risk assessments in relation to pause in Right to Choose funding for ADHD and Autism, Equality Impact Assessments (EqIAs) or similar equality analyses in connection with changes |
| Date Requested | 20/10/2025 |
| Date Replied | 04/11/2025 |
| Category | LDA Transformation |
Under the Freedom of Information Act 2000, I would like to request copies of the following documents held by Greater Manchester ICB:
1. Any risk assessments undertaken in relation to the pause in Right to Choose funding for ADHD and Autism.
2. Any Equality Impact Assessments (EqIAs) or similar equality analyses carried out in connection with these changes.
3. Please also confirm the dates on which these assessments were carried out, and whether they were presented to the ICB Board, sub-committees, or shared with the relevant Health Scrutiny Committee.
If any of the requested information is withheld, please specify the FOIA exemption being relied upon.
NHS Greater Manchester (NHS GM) is implementing a transformation programme to create a new, needs-led model, focusing on early support prioritising those with the highest clinical need, and ensuring equitable access across all pathways, including Right to Choose.
NHS GM will be implementing redesigned pathways for the assessment and support of children, young people, and adults with ADHD and autism.
The implementation will follow a clinically prioritised approach, ensuring that resources are focused on individuals with the greatest level of need and that assessments and interventions are delivered in person.
This approach supports timely, high-quality care, reduces variation in service delivery, and ensures equitable access for those with the most complex or urgent needs.
Referrals for Autism and ADHD assessments have surged nationally, with over 25,000+ adults and 18,000+ children and young people now on NHS GM diagnostic assessment waiting lists.
This rise is reflected locally and nationally, whereby Adult ADHD referrals have increased by more than 400% – including in Greater Manchester from approximately 2,700 in 2022 to over 11,000 in 2024.
Similar growth has been seen in Autism referrals for adults, as well as ADHD and Autism assessments for children and young people.
Given limitations in the available clinical workforce (both in the NHS and private providers) average waiting times have now also now grown exponentially – ranging from 18 months to more than 7 years, with demand continuing to outpace the capacity of local NHS commissioned services.
NHS GM began work in response to this challenge on changing Autism and ADHD care pathways more than 2 years ago. This followed several serious individual case/provider care failures (including subsequent coronial hearings and multiple patient/GP complaints) as well as an unsustainable rise in demand for NHS-funded diagnostic assessments.
This work has been shared through public Greater Manchester Joint Health and Scrutiny Committees (GMCA Part A Report Template, GMCA Part A Report Template) other ICB Governance forums (including the Tackling Inequalities Board and Involvement Assurance Group) and NHS England (NHSE) Regional Service Change/ Reconfiguration Gateway Panels working in line with national requirements (planning-assuring-delivering-service-change-v6-1.pdf) from 2024 onwards.
This work has continued to be supported by Equality and Quality Impact Assessments shared through Public Boards originally in 2024 and accompanying Risk Assessments (see attached examples) addressing the 4 key Government tests of service change:
Public information relating to this work can be found through the following links:
We have worked with multiple Lived Experience and wider stakeholder groups throughout this continuing change programme and held targeted sessions at particular vulnerable groups in and across localities in Greater Manchester.
This also built on previous work establishing core standards for Autism assessment and post-diagnostic support GM Autism Post Diagnosis Standards – GMAC
Importantly all our work complies fully with recent information shared by the NHSE Advice to service systems (NHS England » ADHD service delivery and prioritisation – advice to systems) that includes direction on the use of the new NHS Standard Contract Activity Management provisions to ensure that each provider delivers the right level of activity by agreeing or setting an Indicative Activity Plan with each provider (whether contracted or non-contract activity) and to manage this activity target by reference to that plan using the contractual Activity Management process.
NHS GM has recently temporarily paused new non-urgent Right to Choose autism and ADHD assessments while we work with providers to ensure services remain safe, sustainable and clinically prioritised. Activity continues as normal with our local commissioned services.
This is not a removal of the Right to Choose offer, but a temporary prioritisation process in response to significant increases in demand across both adult and children’s autism and ADHD services in Greater Manchester. We continue to prioritise those with the most urgent clinical needs and those already in the system, including people who have an assessment booked, are part-way through, or are already receiving medication or post-diagnostic support.
Across the country, and here in Greater Manchester, demand for autism and ADHD assessments has risen sharply over recent years. The number of children and adults waiting has increased year on year and the rate of referrals continues to exceed available capacity. This creates very long waits, which we know are difficult for individuals and families.
NHS GM is working with localities, providers, and partners to develop a fair and sustainable long-term approach to meet this rising demand, supported by the development of new models of needs-led support.
We are also increasing investment in community-based services, self-help resources, digital solutions, coaching and peer support groups, so that people can access practical help and advice while waiting for assessment or support.
Patients on existing waiting lists will retain their place and their original referral date. We expect non-urgent appointments to resume when the new financial year begins, subject to budget confirmation.
We recognise how challenging this situation is for families and are committed to improving the timeliness, quality and accessibility of neurodevelopmental services across Greater Manchester.
**Documents were sent to the requester with this response. If you require a copy of the full response, together with the documents, please contact NHS GM’s FOI team – nhsgm.foi@nhs.net**
Accompanying this work, we have now updated the accompanying Equality and Risk Assessment information related to this work. However, we would note:
1. The review process is currently ongoing. All updated documents are currently going through our internal governance program and are, therefore, classified as temporary working materials. As such they have not been validated and approved and are not able to be shared at this stage.
2. The review process is currently ongoing. All updated documents are currently going through our internal governance program and are, therefore, classified as temporary working materials. As such they have not been validated and approved and are not able to be shared at this stage.
The release of this information is exempt from disclosure by virtue of section 22 of the Freedom of Information Act 2000 as it is intended for future publication.
Section 22(1) of the Freedom of Information Act 2000 states:
(a) the information is held by the public authority with a view to its publication, by the authority or any other person, at some future date (whether determined or not),
(b) the information was already held with a view to such publication at the time when the request for information was made, and
(c) it is reasonable in all the circumstances that the information should be withheld from disclosure until the date referred to in paragraph (a).
This exemption is subject to the public interest test and for the reasons outlined below, we are satisfied that the exemption applies.
Public interest test
There is an inherent public interest in ensuring that there is openness and transparency to increase confidence in procurement processes and the purchasing decisions made by NHS GM. Furthermore, disclosure of this information would also be consistent with NHS GM’s commitment to proactively publish data that is in the wider public interest.
However, this information is subject to is subject to review, validation and approval, prior to publication. Early release of the requested information could be misrepresentative, and it is in the public interest that this information is true and accurate.
After considering the arguments outlined above, we have decided that, on balance, the public interest is better served at this time in withholding the latest versions of our Equality Impact and Risk Assessments under section 22 of the Freedom of Information Act 2000, on the basis that it will be published in the future once finalised, as outlined above.
3. As the current updated assessments are ongoing and formal sign-off is still being sought through our internal governance processes, the dates requested are not yet available, although as can be seen in this response links have been provided to a large amount of information already in the public domain on our work in this area.
