FOI 2026/1681

I am writing to submit a formal request for information under the Freedom of Information Act 2000.

This request pertains to your organisation’s commissioning, strategy, and oversight of language access, interpreting, translation, and other communication accessibility services.

I would be grateful if you could provide the following information:

1. Current Provision & Scope

a. The name(s) of your current supplier(s) for:

1. • Spoken language interpreting (including telephone and video remote interpreting)
   • Written translation
   • British Sign Language (BSL) interpreting
   • Other accessible communication formats (e.g., Easy Read, large print, braille)

b. For each contract, the start date and end date (including any extension options)

c. The total contract value (annual and full-term, if available).

d. Please clarify if these contracts are for the ICB’s own corporate use, or if they are system-wide agreements available to your commissioned provider organisations (e.g., NHS Trusts, Primary Care Networks, General Practice).

2. System-Wide Spend and Usage

a. The total annual spend on language services across your Integrated Care System (ICS) for the last three financial years.

b. A breakdown of this spend by service type (e.g., face-to-face interpreting, telephone interpreting, video remote interpreting, translation, BSL).

c. If available, please provide a further breakdown of spend and usage data by provider type (e.g., Primary Care, Acute Trusts, Mental Health Trusts, Community Services).

d. The top 10 most requested languages (excluding BSL) by volume across the system over the last 12 months.

e. The total volume of bookings/assignments in the last 12 months, broken down by service type if possible.

3. Procurement and Future Strategy

a. The procurement route used for the current contracts (e.g., open tender, framework, direct award)

b. If procured via a framework, please provide the name of the framework and the framework provider.

c. The anticipated timeline for re-procurement or renewal.

d. The name and contact details of the person or team responsible for managing these contracts and/or commissioning strategy.

e. Are there plans to consolidate language service procurement across your ICS under a single framework or contract in the next procurement cycle?

4. Performance and Governance

a. The key performance indicators (KPIs) used to measure supplier performance.

b. Details of any service credits, penalties, or formal performance concerns raised against your supplier(s) in the last 12 months.

c. A copy of the service specification for the current contract(s), if publicly shareable.

5. Strategy, Health Inequalities, and Accessibility

a. Does the ICB have a formal Language Access or Communication Accessibility Policy that applies across the ICS?

b. How does the ICB’s commissioning strategy for language services specifically support its statutory duty to reduce health inequalities?

c. Has the ICB identified any specific patient pathways or geographical areas where language access is a key challenge to be addressed?

d. Does the ICB have a specific policy or strategy regarding the promotion and use of digital/remote interpreting (video and telephone) versus face-to-face interpreting across its provider network?

e. Please provide any published equality impact assessments relating to language or communication access.

f. Please provide any data you hold on patient feedback, complaints, or Patient Advice and Liaison Service (PALS) contacts related to language access services in the last 12 months.

1a. The requested information relates to a live and ongoing procurement exercise. We are, therefore, applying Section 43(2) (Commercial Interests) of the Freedom of Information Act 2000.

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)”.

Factors favouring disclosure.

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.

Factors favouring non-disclosure.

However, we consider that disclosure at this stage would be likely to prejudice the commercial interests of the supplier and NHS GM, as it could compromise the integrity of the procurement process and ongoing negotiations. If disclosed, it is likely to negatively affect their ability to negotiate or to compete in a commercial environment, particularly in relation to future commissioning, negotiation and value-for-money considerations.

Balancing Test.

After considering the arguments outlined above, we have decided to withhold this information.  While we recognise the public interest in transparency relation to NHS commissioning arrangements, we consider that maintaining a fair and competitive procurement process currently outweighs the public interest in disclosure. The position may be reviewed once the procurement has concluded

1b. Current contracts are on a rolling basis due to them currently being under review and a mini-competitive process underway.

1c. c£1.8 per annum.

1d. Current contracts in place are commissioned by the ICB for use by the ICB and Primary Care services (General Practice, NHS Dentistry, NHS Pharmacy, and NHS Optometry). However, existing arrangements are based upon previously CCG commissioning arrangements, and therefore there is variation in terms of primary care access to this provision. NHS Trusts pay for and commission their own Interpreting services – they are not commissioned by the ICB.

2a. As the ICB does not commission Interpreting Services for the whole ICS, we will be unable to provide this information.

2b. NHS Greater Manchester (Integrated Care Board) was formed on 1^st July 2022, and therefore not all data pre-1^st July 2022 is available (or may not be fully accurate) as they were managed under what were previously ten Clinical Commissioning Group’s for each locality within Greater Manchester. Therefore, we are unable to provide a history sufficient to demonstrate a true split of spenditure. The following table illustrates combined total budgetary values between 20/21 – 24/25.

The above figures mainly relate to funding / expenditure for interpretation and translation support to service users accessing primary care services.

2c. The ICB does not commission Interpreting services for Mental Health Trusts, NHS Acute Trusts or Community Services which typically sit within an Acute Trust.

2d. The data varies between locality to locality, and therefore what maybe the highest spoken language which requires interpretation and translation support in one locality may not be the same for another.

Overall, as a general response, the top five spoken languages within Greater Manchester, and are therefore amongst the highest requested for interpretation and translation, are:

• Urdu
• Panjabi
• Bengali
• Polish
• Arabic

The following table shows the most commonly spoken community languages in Greater Manchester (but are not limited to):

Currently we don’t hold a full breakdown of data across the ten localities to be able to provide exact costings spent against every language, but this is an area we are working on for the future of the service, to better understand usage.

2e. NHS Greater Manchester (Integrated Care Board) was formed on 1^st July 2022, and therefore not all data pre-1^st July 2022 is available (or may not be fully accurate) as existing contracts were managed under what were previously ten Clinical Commissioning Group’s for each locality within Greater Manchester. The following table was collated for the purpose of the review project and mini-competition process:

3a. The current contracts were inherited from each of the CCGs which were combined to form the NHS Greater Manchester ICB. Therefore, we are unable to confirm how these historical arrangements were previously commissioned or what process was followed to satisfy EU procurement regulations or the public contracts (2015) at the time.

3b. We can only confirm that previous CCGs likely used the NHS Shared Business Services Interpretation and Translation Framework as this is a commonly used framework in the NHS. However other frameworks are available such as Crown Commercial Services who also have a framework for Interpretation and Translation services.

3c. There have been several delays, however the current timeline is to commence with a new service contract from 1^st June 2026.

3d. All queries can be directed to gmss.gmicb.contracting-primarycare@nhs.net and will be responded to in a timely manner.

3e. Due to how funding is currently allocated for this service, we are not in a position to consolidate funding across all of the NHS Acute Trusts, Local Authorities, and other organisations such as VCFSE to be able to provide a single commissioned interpreting service to support the whole of the ICS. All organisations within the ICS have their own national and localised funding and therefore there would need to be a joint agreement to share funding and a facilitated way to jointly manage a single budget. The national funding which the ICB receives, includes an allocation to provide Interpreting Services to Primary Care in alignment with NHS policy.

4a. There are a broad and varying range of KPI’s across the 10 localities in Greater Manchester based upon previous CCG arrangements which the ICB inherited, some of which we have not been able to fully establish. A new set of KPI’s have been created and have been shared with the market as part of the mini-tender process.

4b. None

4c. As noted above, all current arrangements are based upon 10 CCG historical arrangements and therefore there isn’t a single specification.

5a.

NHS England » Improvement framework: community language translation and interpreting services – (June 2025)

NHS England » Accessible Information Standard – implementation guidance

British Sign Language 5-year plan: Department of Health and Social Care (English and BSL versions) – GOV.UK – (July 2025)

Interpretation and Translation Advice and Guidance | Greater Manchester Integrated Care Partnership

Advancing Equality | Greater Manchester Integrated Care Partnership

Project: Interpretation and Translation Services | NHS Greater Manchester

Translation and Interpreter Services – Community Pharmacy Greater Manchester

NHS England Guidance for Commissioners / Primary Care Commissioning (Sept 2018)

**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 **

5b. As part of the review of Interpreting Services for Primary Care, the ICB has developed a ‘Framework of Requirements’ document which outlines our requirements for service access, delivery, and to provide guidance for all service users. This has been developed in line with the guidance.

5c. Patients from the d/Deaf community are facing continued challenges with accessing British Sign Language provision when accessing Primary Care Services particularly when trying to undertake what other patients may find a simple task of contacting their GP Practice to make an urgent or routine appointment. There is also a national shortage of fully qualified BSL interpreters which also makes it challenging for the d/Deaf community to have access adequate BSL support when they need it most. Pharmacies, Dentists, and Opticians also face challenges with on demand access to interpreters for patients/service users coming in from the high street, needing access to on-demand or urgent treatment and therefore Interpreters are required at short-notice. There are also an increasing number of rare languages and rare dialectics and therefore this can be challenging for suppliers to locate a rare language interpreter.

5d. There is not a specific Interpretation and Translation Digital Policy at this time. However, it is increasingly becoming a topic of discussion nationally due to the risks of being provided the wrong clinical information and patient data being stored and held on unauthorised devices, iClouds, or data centres, particularly overseas.

The main area of concern is the use of AI and features such as Google Translate within healthcare settings. Google Translate for example can retain personal data without patient / service user consent and there is no way of then tracking where that data then is stored, and it can also provide inaccurate information, which is a clinical safety risk.

5e.

**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 **

5f. Between 1 April 2025 and 31 March 2026, NHS Greater Manchester received 6 complaints and <5 PALS enquiries related to language access services.

Please note – The names of individuals have been removed from the attached documents. This information is exempt from disclosure under section 40 (2) of the Freedom of Information Act 2000 as it constitutes personal data where disclosure would be in breach of the Data Protection Act 2018. This exemption is not subject to the public interest test.