FOI 2025/1514

Thank you for your response to FOI 1463. After reviewing the answers, I need some clarification before I proceed with an Internal Review, as several responses appear incomplete or do not address the questions asked.
1. CHC costings and care plans
My questions 3.1–3.4 requested any recorded information about including costings in CHC care plans, disclosing costed plans to families, preparing costed plans before reviews, and any policy allowing or prohibiting the omission of costings. The response did not provide any recorded information and instead referred back to earlier answers that do not cover these points.
Please confirm:
a) whether the ICB holds any recorded policy or guidance requiring CHC costings to be included in care plans;
b) whether the ICB holds any recorded policy requiring costings to be shared with families;
c) whether the ICB holds any document authorising staff to omit costings;
d) whether the ICB holds any governance or audit documents relating to cost transparency.
If the answer to any of the above is “no information held”, please confirm this explicitly.
2. Interpretation of CHC Framework paragraphs 333–339
Your response stated that these paragraphs relate to Section 117. That is incorrect. In the National Framework (2022), paragraphs 333–339 cover governance, record-keeping, transparency and maintaining accurate cost information.
Please confirm:
a) whether NHS GM ICB holds any governance or audit documentation relating to these paragraphs;
b) if not, please confirm that no information is held;
c) whether the FOI response will be corrected to reflect the correct interpretation of the Framework.
3. Natural support
In response to questions 4.1–4.6, you stated that no policies exist. My request covered wider material, including guidance, instructions, governance documents, finance or commissioning documents, or any recorded information relating to the use of unpaid family support.
Please confirm:
a) whether the ICB truly holds no recorded information at all on natural support in any form;
b) if any information exists but was not disclosed, please identify it;
c) whether “no information held” applies across all ten GM localities.
4. Driver, travel and escorting support
Questions 5.2–5.4 asked for any criteria, guidance or costing assumptions relating to driver support, travel or escorting. The reply only stated that “there are no criteria, nor guidance”.
Please confirm:
a) whether the ICB holds any commissioning, costing or operational documents that refer to travel, driver support, mileage or escorting;
b) whether any internal cost templates include mileage or travel assumptions;
c) if not, please confirm explicitly that no information is held.
5. Budget shortfalls
Questions 8.1–8.5 asked for any recorded information relating to identifying or managing shortfalls between assessed need and funded provision, including policies, guidance, instructions, reporting templates or escalation procedures. The response did not address these items or state whether such information is held.
Please confirm whether the ICB holds any documents relating to: shortfalls, underfunded packages, unfunded elements, reliance on families, providers covering unfunded hours, uplift delays or monitoring of insufficient budgets. If no information is held, please confirm this clearly.
6. Imosphere and CareCubed
You confirmed that these systems are used but did not disclose any guidance, configuration information, operational instructions or training materials.
Please confirm whether the ICB holds any recorded information relating to the use or configuration of these tools. If none exists, please confirm that as well.
7. Locally agreed policies
In section 1.3, you referred to “locally agreed policies”, but none were provided. Please confirm the titles of these policies and whether they are held and available for release under FOIA.
8. FOIA compliance
For each clarification above, please confirm whether information is held, withheld under a specific exemption, or not held at all, as required under sections 1 and 16 of FOIA.

1. NHS Greater Manchester ICB (NHS GM) refers you the following documents, for your due consideration:

NHS GM’s Choice and Equity Policy

NHS GM’s CHC Operational Policy

The National Framework, as published on the Department of Health and Social Care (DHSC) website:

National Framework for NHS Continuing Healthcare and NHS-funded Nursing Care – July 2022 (Revised) – corrected May 2023

1. No policy or guidance that requires teams to include costings in a clinical care plan.
2. No policy that requires the automatic sharing of costings with families.
3. No document exists in relation to this, therefore, no information is held.
4. NHS GM ICB are not aware of any particular audits. We would however, refer you to the NHS GM ICB website for Board and Committee Meeting papers, in particular the Audit Committee, as well as the Quality and Performance Committee (QPC), which both routinely discuss the overarching financial management and governance surrounding individualised packages of care (IPOC).

Meetings/Events | Greater Manchester Integrated Care Partnership

2. The National Framework July 2022, paragraphs 333-339 are in relation to Section 117.
3. This information is not recorded on the NHS Greater Manchester systems/data bases. Therefore, this section of your request is exempt by virtue of the following exemption, Section 12(1).

Section 12(1) does not oblige a public authority to comply with a request for information if the authority estimates that the cost of complying with the request would exceed the appropriate limit.

The Freedom of Information Act allows Public Authorities to decline to answer FOI requests when we estimate it would cost us more than £450 (equivalent to 18 hours, calculated at £25 per hour) to identify, locate, extract, and then provide the information that has been asked for.

NHS Greater Manchester (NHS GM) consists of the 10 Greater Manchester localities, Bolton, Bury, Heywood, Middleton and Rochdale, Manchester, Oldham, Salford, Stockport, Tameside, Trafford and Wigan (former Clinical Commissioning Groups), and therefore documents are held on various data bases. As such a manual search of records would be required. Due to the volume and complexity of the data involved, it would require a disproportionate amount of time and resources to locate, extract and collate the data. Therefore, on this occasion it is with regret NHS GM are not able to process this section of your request further.

Although we cannot answer your request, we might be able to answer a refined request within the cost limit. Therefore, you may wish to restrict your request to consider specifying a specific area, one form of information. However, please be aware that we cannot guarantee at this stage that a refined request will fall within the cost limit, but NHS GM would do our upmost to assist you.

4. Please refer to the response provided to questions 1 and 3.
5. Please refer to the response provided to question 1. In addition, NHS GM ICB wishes to draw your attention to section 4.4 of the NHS GM Governance Handbook. Section 4.4 details of the scheme of reservation and delegation (SoRD) in respect of financial management across the organisation.

NHS Greater Manchester Integrated Care Governance Handbook

6. Within the FOI Act, Section 43 refers to exemptions to protect commercially sensitive information, covering trade secrets or data whose release would likely harm any person’s (including the public body’s) commercial interests, such as pricing, supplier strategies, or confidential negotiations, but it is a qualified exemption requiring a public interest test to balance secrecy against transparency before withholding.

Section 43(2) of the Freedom of Information Act 2000 states:

“Information is exempt information if its disclosure under this Act would, or would be likely to, prejudice the commercial interests of any person (including the public authority holding it)”.

In this instance disclosure of information would be extremely prejudicial to their position in the marketplace if a competitor was to be handed this information without having invested the time, money and effort they have done.

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 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.

NHS GM utilises both pieces of software for financial market management and are of the view that the information provided by both organisations, including the utilisation of the software and literature is commercially sensitive to each respective provider. Disclosure of information considered to be a Trade Secret would be prejudicial to both providers position whilst also adding little to the transparency of the ICB’s decision-making processes.

Training materials do not belong to NHS GM ICB for either of the software mentioned. Therefore, After considering the arguments outlined above, we have decided to withhold this information.

Therefore, it will be necessary for you to contact the respective training providers for the information you seek.

In keeping with the four values of NHS GM ICB, which are collaboration, compassion, inclusion and integrity, it is recommended that should you wish to obtain material about either product, you contact them directly:

Our Solutions | Imosphere

CareCubed – The National Care Costing Tool

7. NHS GM ICB refers you to the answer provided to question 1.
8. Responses have been provided, with the necessary narrative for questions 1-7.