FOI 2026/1653

I have reviewed the public papers for the NHS Greater Manchester Integrated Care Board meeting held on 11 February 2026. These papers raise important questions about the transparency, completeness, and evidential basis of the governance processes that informed the meeting. In the public interest, and to support informed scrutiny of how decisions affecting patients and communities are made, I am requesting the following information under the Freedom of Information Act 2000.

This request covers the period 1 November 2025 to 11 February 2026, which includes the preparation for and conduct of the February public Board meeting.

1. Draft Versions of the Minutes – 11 February 2026 Board Meeting

Please provide the draft versions of the minutes for the public Board meeting held on 11 February 2026, including any versions containing tracked changes, comments, or edits made prior to final approval.

Rationale:  The published minutes represent a final, curated version of events. Draft versions will clarify how the public record was constructed, including any material that was removed, softened, or reframed during the editorial process.

2. Minute‑Taking Guidance Used by the ICB

Please provide the current guidance, protocol, or standard operating procedure used by NHS Greater Manchester ICB staff for taking, drafting, and finalising minutes of public Board meetings.

Rationale:  This document will clarify whether the minute‑taking process itself contains structural instructions that limit the recording of challenge, dissent, or detailed deliberation, and therefore shape the completeness of the public record.

3. Transition Committee – January 2026 Minutes (Risk Discussions)

Please provide the full, unredacted minutes of the Transition Committee meeting(s) held in January 2026 where discussions took place regarding clarity between ICB and system risks, the lines of defence in risk management, and the need for more dynamic or evidence‑based risk reporting. These discussions are referenced in the Transition Committee report presented to the Board on 11 February 2026.

Rationale:  The public summary notes these concerns but provides no detail. The full minutes will show the depth of discussion, the specific risks identified, and whether the Board received a complete and accurate escalation.

4. EPRR Assurance – Improvement Action Plan

Please provide the improvement action plan referenced in the Board papers of 11 February 2026, developed in response to the ICB’s 68% compliance rating in the 2025/26 EPRR core standards assurance process. The plan should include the actions identified, responsible officers, and intended timelines.

Rationale:  The public record acknowledges non‑compliance but does not set out the underlying gaps or the scale of risk. The improvement plan will clarify the seriousness of the issues identified and the adequacy of the proposed response.

5. Workforce Consultation – Feedback on the Draft Operating Model

Please provide an anonymised summary of written feedback received during the November 2025 engagement period on the draft operating model, specifically feedback that raised concerns about the ability of the reduced workforce to safely deliver statutory functions, or that identified risks to patient safety, staff wellbeing, or service continuity. If providing the full summary exceeds the cost limit, please provide the number of responses raising such concerns and a thematic summary of the issues identified.

Rationale:  The public papers state that feedback was received and considered but provide no detail on its content. This feedback is likely to contain risks and concerns that were not reflected in the final Board papers or decisions.

If any of the requested information is exempt from disclosure, please specify the exemption relied upon and provide an explanation. If any part of this request risks exceeding the appropriate cost limit, please advise me so that I may refine it.

I would prefer to receive the information electronically. I look forward to your response within 20 working days.

1. Draft versions of minutes, including tracked changes and internal comments, are not disclosed. These documents are withheld under Section 36(2)(b) of the Freedom of Information Act 2000, as disclosure would be likely to inhibit the free and frank exchange of views for the purposes of deliberation and the effective conduct of public affairs.

The approved minutes represent the formal and accurate record of the meeting and are publicly available via NHS Greater Manchester’s (NHS GM) website Meetings/Events | Greater Manchester Integrated Care Partnership. Board meetings are held in public and livestreamed for anyone who is unable to attend in person.

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 Person’ 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 GM is Professor Colin Scales, Acting Chief Executive.

Professor 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.
• would otherwise prejudice, or would be likely otherwise to prejudice, the effective conduct of public affairs.

The meeting in question forms part of the ICB’s internal governance and operational decision-making processes. They involve discussion of the following, but not limited to, financial detail, commissioning pressures, provider performance, and clinical considerations. This needs to be recorded correctly, and in keeping with internal governance processes to provide a true and accurate record of discussions.

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.

There is an inherent public interest in ensuring that there is openness and transparency regarding NHS GM’s decision making.  Disclosure of this information would also be consistent with our commitment to proactively publish data that is in the wider public interest.

Factors favouring non-disclosure.

Early release of the requested information, prior to the completion of review and approval via internal governance processes, could be misrepresentative, and incorrect. NHS GM must maintain the ability to review the information that has been recorded, to check for ambiguous or missing information, regulatory compliance, accountability, and ensure a clear and transparent record of the discussions and decisions that have taken place at the meeting. The risk of sharing information that is not accurate and correct would likely undermine stakeholder trust, governance transparency would likely suffer, and auditing and performance evaluations compromised.

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 draft information which may include incorrect detail, outweighs the public interest in disclosure. Furthermore, the final draft minutes are currently publicly available on the NHS GM website.

2. Draft minutes are reviewed by the Executive Team and signed off by the Chair prior to approval by the Board.

3. Approved minutes from the January Transition Committee are published on the website here: Meetings/Events | Greater Manchester Integrated Care Partnership

4. The EPRR Core Standards Action Plan 2025 – 2026 is embedded as follows:

**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 NHS Greater Manchester Operating Model Response to feedback January 2026 is embedded as follows:

**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 **