FOI 2026/1530

Please treat this email as a request for information under the Freedom of Information Act 2000.

I am requesting copies of any documents, whether draft or final, relating to the assessment of risk, safety, safeguarding and equality impacts associated with the proposed triage model for adult ADHD and/or autism assessment pathways in Greater Manchester.

This request includes, but is not limited to:

1. Any risk assessments, safety assessments, hazard logs or clinical safety documentation relating to the proposed triage model.
2. Any assessment of suicide risk, self-harm risk, safeguarding risk, or deterioration while waiting linked to triage decisions.
3. Any Equality Impact Assessments (EqIAs), equality analyses, or reasonable-adjustment assessments relating to triage.
4. Any documents considering indirect discrimination or disproportionate impact on disabled people or other protected groups arising from triage.
5. Any internal papers, briefings, slide decks, or working documents discussing risk, safety or equality implications of triage criteria or outcomes.

Please include documents held in draft form, working versions, or documents described as “in development”, “for discussion”, or “pre-approval”.

For the avoidance of doubt, this request covers information held in any format, including emails, attachments, presentations, and working documents.

In accordance with section 3(2)(b) of the Freedom of Information Act 2000, this request includes any information held on behalf of the ICB by another organisation, including (but not limited to) any Commissioning Support Unit (CSU) or external contractor acting for the ICB.

1. NHS Greater Manchester (NHS GM) does not hold the specific documents requested.
2. NHS Greater Manchester (NHS GM) does not hold the specific documents requested.

3 & 4. NHS GM holds the information requested, however, this has not yet been approved and validated via internal governance.

Therefore, the release of this information is exempt from disclosure by virtue of section 36(2)(b)(i) and (ii) of the Freedom of Information Act, as disclosure would be likely to inhibit the free and frank provision of advice and the free and frank exchange of views for the purposes of deliberation.

The Minister responsible for the Freedom of Information in the Department of Health has authorised the senior person in charge of the National Health Service bodies to act as ‘Qualified Persons’ and under Section 5 of the National Health Service Act 1977 this is the Chief Executive. Under the Section 36 exemption, the ‘qualified person’ for NHS Greater Manchester (NHS GM) is Mr Colin Scales, Acting Chief Executive.

Mr Scales is of the opinion that the information should be withheld as he considers that it would, or would be likely to prejudice, the effective conduct of public affairs.

Disclosure of the minutes would, or would be likely to:

• inhibit the free and frank provision of advice, and
• inhibit the free and frank exchange of views for the purposes of deliberation.

Releasing preliminary information that has not yet been approved and validated would risk undermining future decision-making by discouraging open and candid consideration of alternative approaches. Release would also be likely to prejudice the effective conduct of public affairs.

Public Interest Test

Factors favouring disclosure.

Openness and transparency: It is important that NHS GM acknowledges their responsibility to be open, transparent and accountable.

Factors favouring non-disclosure.

NHS GM consider sharing the information requested would inhibit advice, views and openness between decision makers, necessary to agree appropriate service provision for the patients it serves. It is critical that NHS GM maintain the greatest possible confidence without any concern that confidential or sensitive information provided, consulted, or relied on may be compromised. Furthermore, to divert resources to manage the impact of disclosure, would cause disruption to important services that NHS GM provides, and the organisations ability to efficiently conduct public affairs.

Balancing Test.

NHS GM has carefully considered whether the requested information could be disclosed in a redacted or partial form. However, meaningful disclosure would not be possible without undermining the protected interests. Redaction would leave the remaining material fragmentary and misleading.

As such, it is the decision of NHS GM that the public interest at this time lies in non-disclosure of the information for the reasons outlined above. NHS GM consider that the public interest in withholding the internal draft working information outweighs the public interest in disclosure.

5. NHS GM has completed the NHS Gateway Process for Service Change (planning-assuring-delivering-service-change) with respect to the Triage model changes. This process for service change involves a structured approach to that of changes to health and care services are well-planned, implemented, and assessed.

The key steps of this process include demonstration of:

• Planning and Design: Commissioners and partners must consider how to take forward proposals, including effective public involvement and enabling them to reach robust decisions
• Public Involvement: Engaging local diverse communities, local authorities, key stakeholders and expert review is essential
• Consultation: Following the process set out above – appropriately involving local communities, local authorities, key stakeholders and expert review is crucial

• Implementation: Ensuring that the service change aligns with system and organisational priorities and complies with statutory duties.
• Quality Assurance: Conduction Equality Impact Assessments (EIAs) and Quality Impact Assessments (QIAs) to ensure the impact of changes is assessed and mitigating actions are taken.

To ensure proper and professional consideration, this process was overseen by regional lead officers, clinicians and other stakeholders, in recognition that the NHS Gateway process is designed to support commissioners and their partners in designing service change through robust decisions that reduce health inequalities.

To support this work, NHS GM prepared a detailed Pre-Consultation Business Case (PCBC) with accompanying documents to be reviewed and assured for completeness. This information was then shared by NHS GM to NHS England (NHSE) demonstrating:

• evidence of meeting the ‘four tests’, i.e.
  • Strong public and patient engagement
  • Consistency with current and prospective need for patient choice
  • A clear, clinical evidence base, and
  • Support for proposals from clinical commissioners
• providing confidence that a credible wider support offer will be in place, and
• having an operational and communications plan for the rollout.

This work on the open Consultation and Gatekeeping compliance process has been accompanied with discussions with the Greater Manchester Joint Health Scrutiny Committee and other groups, where again matters related to mitigating any impact or concerns related to risk, safety and inequalities.

Throughout all this required dialogue, it has been confirmed that NHS GM has completed work appropriately addressing all the questions noted in this FOI request.

This work was subsequently supported through comprehensive Public Consultation and Engagement exercises with both Adults and Children and Young People with their families, – with the outcomes published on GM websites: (eg ADHD and Autism Assessments | Greater Manchester Integrated Care Partnership)

NHS GM has also published other papers on the FOI request that can be accessed via the following link: Meetings/Events | Greater Manchester Integrated Care Partnership.

These include public discussions with system leaders with respect to risk, safety and equality implications of triage criteria or outcomes. Triage mechanisms are routine elements of NHS commissioned pathways.

To date, there have been no particular evidence-based clinical concerns noted with respect to introduction of triage in respect to adherence to the National Institute for Health and Care Excellence (NICE) or other Best Practice guidance.

Other information held, that falls within the scope of the questions, consists of internal briefing papers, draft decision documents and records created to support internal discussions and decision-making. The release of this information is exempt from disclosure by virtue of section 36(2)(b)(i) and (ii) of the Freedom of Information Act, as disclosure would be likely to inhibit the free and frank provision of advice and the free and frank exchange of views for the purposes of deliberation.

The Minister responsible for the Freedom of Information in the Department of Health has authorised the senior person in charge of the National Health Service bodies to act as ‘Qualified Persons’ and under Section 5 of the National Health Service Act 1977 this is the Chief Executive. Under the Section 36 exemption, the ‘qualified person’ for NHS Greater Manchester (NHS GM) is Mr Colin Scales, Acting Chief Executive.

Mr Scales is of the opinion that the information should be withheld as he considers that it would, or would be likely to prejudice, the effective conduct of public affairs.

Disclosure of the minutes would, or would be likely to:

• inhibit the free and frank provision of advice, and
• inhibit the free and frank exchange of views for the purposes of deliberation.

Releasing preliminary options and reasons for rejection would risk undermining future decision-making by discouraging open and candid consideration of alternative approaches. Release would also be likely to prejudice the effective conduct of public affairs.

Public Interest Test

Factors favouring disclosure.

Openness and transparency: It is important that NHS GM acknowledges their responsibility to be open, transparent and accountable.

Factors favouring non-disclosure.

NHS GM consider sharing the information requested would inhibit advice, views and openness between decision makers, necessary to agree appropriate service provision for the patients it serves. It is critical that NHS GM maintain the greatest possible confidence without any concern that confidential or sensitive information provided, consulted, or relied on may be compromised. Furthermore, to divert resources to manage the impact of disclosure, would cause disruption to important services that NHS GM provides, and the organisations ability to efficiently conduct public affairs.

Balancing Test.

NHS GM has carefully considered whether the requested information could be disclosed in a redacted or partial form. However, meaningful disclosure would not be possible without undermining the protected interests. Redaction would leave the remaining material fragmentary and misleading.

As such, it is the decision of NHS GM that the public interest at this time lies in non-disclosure of the information for the reasons outlined above. NHS GM consider that the public interest in withholding the internal draft working information outweighs the public interest in disclosure.