| Reference | FOI 2026/1606 |
|---|---|
| Description | Commissioning of CPUK Ltd by GM ICB for Manchester CMHTS independent Review |
| Date Requested | 09/02/2026 |
| Date Replied | 02/03/2026 |
| Category | Mental Health |
On 26 August 2025, I submitted a Freedom of Information request (FOI 1344/2025) concerning the commissioning, governance, methodology, and independence of the external provider appointed to conduct the independent review of Community Mental Health Teams (CMHTs) across Greater Manchester. In your response, you confirmed that CPGB Ltd had been commissioned through an Invitation to Quote process, that Terms of Reference had been finalised following system‑level governance scrutiny, and that the review was expected to conclude before the end of the 2025 calendar year.
You further stated that the final report would include findings, thematic analysis, and evidence‑based recommendations aligned with the Shanley Review themes, and that the report would be considered through NHS GM governance structures, including the Quality and Performance Committee, the Mental Health Partnership Board, and the Adult Community Group. You also confirmed that options for onward publication would be reviewed.
Given that the review was commissioned in response to Recommendation 9 of the Shanley Review—specifically to address longstanding concerns regarding patient safety, leadership, culture, governance, and organisational learning within community mental health services—there is a compelling public interest in ensuring transparency regarding its findings, recommendations, and subsequent actions taken by NHS GM and its provider partners.
Under the Freedom of Information Act 2000, I now request disclosure of the completed independent review and all associated documentation. Each request is numbered for clarity.
2.1 The Final Independent Review Report
Please provide a full copy of the completed independent review of Community Mental Health Teams (CMHTs) commissioned from CPGB Ltd, including all chapters, appendices, thematic analyses, evidence tables, and recommendations.
2.2 Executive Summaries and Presentations
Please provide any executive summaries, slide decks, briefing papers, or condensed versions of the report that were prepared for internal governance groups, including but not limited to the Quality and Performance Committee, the Mental Health Partnership Board, the Adult Community Group, and the Clinical Effectiveness Group.
2.3 Action Plans Developed in Response to the Review
Please provide all action plans, improvement plans, or implementation frameworks produced by NHS GM, GMMH, PCFT, or any other provider in response to the findings and recommendations of the review. This should include:
(a) actions agreed at provider level; (b) actions agreed at place level; (c) actions agreed at system level; (d) any monitoring or assurance mechanisms established to track progress.
2.4 Communications Between NHS GM and Providers Regarding the Review
Please provide copies of correspondence, letters, emails, meeting notes, or briefing documents exchanged between NHS GM and the relevant providers (including GMMH and PCFT) relating to:
(a) the findings of the review; (b) required actions or expectations communicated to providers; (c) provider responses, commitments, or challenges raised; (d) any discussions regarding publication, transparency, or stakeholder engagement.
2.5 Governance Papers and Minutes
Please signpost to publicly available documents or provide all papers, minutes, or reports submitted to NHS GM governance bodies concerning the review, including but not limited to:
(a) Quality and Performance Committee; (b) Mental Health Partnership Board; (c) Adult Community Group; (d) System Improvement Board; (e) Clinical Effectiveness Group.
This should include any decisions made regarding acceptance of findings, approval of action plans, or decisions relating to publication.
2.6 Methodological Documentation
If not already included within the final report, please provide any methodological documents, audit tools, data analysis frameworks, or engagement protocols used by CPGB Ltd in conducting the review.
2.7 Publication Decision
Please provide any internal discussions, decision logs, or correspondence relating to whether the final report will be published in full, published in part, or withheld from publication, including the rationale for any decision taken.
I request that all information be provided electronically in PDF or Word format
2.1 Final Independent Review Report
The independent review of CMHTs commissioned from CPGB Ltd has been completed by the external provider. However, the report is currently undergoing final quality assurance and governance consideration and has not yet been formally adopted or accepted through NHS Greater Manchester’s (GM) governance processes.
The report is therefore considered information intended for future publication. Disclosure at this stage is exempt under Section 22 of the Freedom of Information Act (information intended for future publication).
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
Factors favouring disclosure.
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.
Factors favouring non-disclosure.
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.
Balancing Test.
After considering the arguments outlined above, we have decided that, on balance, the public interest is better served at this time in withholding the information 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.
In addition, early disclosure would prejudice the effective conduct of public affairs by inhibiting full and frank consideration of findings, system learning, and improvement actions, and is therefore also exempt under Section 36(2)(b)(ii).
Section 36(2)(b)(i)(ii) and (c) – Prejudice to the Effective Conduct of Public Affairs.
Section 36 of the Act sets out a qualified exemption from the right where in the reasonable opinion of a qualified person such disclosure would prejudice the effective conduct of public affairs.
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:
The decision to apply this exemption has been made with the reasonable opinion of the qualified person, as required by the Act.
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.
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 information outweighs the public interest in disclosure.
2.2 Executive Summaries and Presentations
At the time of your request, no finalised executive summaries, slide decks, or condensed versions of the report have been produced for internal governance groups. Any interim briefing materials that exist form part of the deliberative process and are exempt from disclosure under Section 36 of the Act. Therefore, release of information at this stage would be likely to inhibit the free and frank exchange of views causing a chilling effect on the “safe space” required s during the assessment, challenge and assurance process as outlined above.
Action planning in response to the independent review is currently in development, whilst early work has commenced across provider, place, and system levels, no finalised or formally approved action plans or implementation frameworks are held at this time.
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.
There are a number of teams within NHS GM that would hold correspondence, letters, emails, meeting papers, and documents in scope of the request, This includes Mental Health Commissioning, Quality and Safeguarding, Corporate Governance, Programme teams and Senior Leadership colleagues.
It would be reasonable to estimate that at least 20 colleagues will potentially hold relevant emails, and each would be required to undertake searches across email accounts, including inbox, sent and deleted folders. In addition to this there are multiple shared drives across the organisation holding documentation and Teams activity used for programme and governance activity.
It is estimated that approximately 45 minutes, per person, would be required to run searches across email accounts and extract the information, 45 minutes per person to search Teams activity, shared drives, meeting folders and extract the information. Using the estimated calculation below it would require a disproportionate amount of time and therefore, on this occasion it is with regret NHS GM are not able to process this section of your request further.
45 minutes to search and extract emails + 45 mins to search and extract Teams activity, shared drives, meeting folders = 90 mins (1 hour 30 mins) per person.
90 minutes (1 hour 30 mins) x 20 people = 1,800 minutes (30 hours)
Although we cannot answer your request, we might be able to answer a refined request within the cost limit. Therefore, you may wish to consider limiting to formal correspondence between NHS GM and provider executive teams, limiting to a defined date range
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
2.5 Governance Papers and Minutes
Publicly available documents, meeting papers, reports are published on the NHS GM website. In line with section 16 of the Freedom of Information Act 2000, please find a link below to assist you.
Meetings/Events | Greater Manchester Integrated Care Partnership
The review was commissioned via an Invitation to Quote process, with CPGB Ltd appointed to undertake an independent assessment. The methodology included document and data review, stakeholder engagement, and thematic analysis aligned to the Shanley Review themes, including leadership, culture, governance, patient safety, and organisational learning. Further methodological detail will be contained within the final report.
No final decision has yet been taken regarding whether the report will be published in full or in part. Any decision on publication will follow completion of governance assurance processes and consideration of patient safety, staff wellbeing, and system learning. The rationale for any publication decision will be documented as part of this process.
In summary, NHS GM acknowledges the public interest in this work and is committed to transparency, learning, and improvement. At this stage, however, disclosure of the requested information would be premature and could undermine the responsible handling of sensitive system-wide learning. Once governance processes are complete, we will consider appropriate publication and stakeholder engagement.
