FOI 2026/1688

I am writing to request the following information under the Freedom of Information Act 2000

1. Between 2020-2025 (or for as many years as records are available post CCG merger) how many requests have been received by your ICB/CCG to fund assessment and/or treatment for dissociation or dissociative disorders with independent or out of area providers, including but not limited to: The Centre for Dissociative Studies (CDS); The Pottergate Centre for Dissociation and Trauma; The Complex Trauma and Dissociation Clinic (CTAD); South London and Maudsley (SLaM) Trauma and Dissociation Service. To avoid low number suppression (eg. <5) please do not provide numbers broken down per locality or by year but one single figure for the entire ICB/CCG for the full time period.

2. Of these requests, how many were approved for funding? If there is low number suppression (eg. <5) please provide an overall percentage for how many requests were approved for the entire ICB/CCG for the full time period.

3. What is the typical cost to the ICB/CCG of:

1. • An initial assessment at each of these providers.
   • A course of treatment (e.g. per session, per year, or any other available metric)

4. Does your ICB/CCG commission a formal care pathway or policy for the assessment and/or treatment of dissociative disorders in your locality?

5. Are there any planned changes to the commissioning or provision of services for people with dissociative disorders (e.g. new services, contract reviews, funding changes)?

If any part of this request requires clarification, or would exceed the cost/time limit, I would be grateful for advice on how it might be refined.

1. In line with Section 16 of the FOI Act 2000 (advise and assist), NHS GM has provided the data requested for the period of 2025/26 (financial years) as this information had already been collated as part of an internal work programme. However, the requested information for earlier years is not held in a single, centrally accessible system and would require extensive searches across multiple platforms and records to identify, retrieve, and compile the data. To undertake this work would exceed the appropriate time limit set out under Section 12 of the Freedom of Information Act 2000.

Section 12(1)

Under the Freedom of Information Act 2000 (FOIA), this section of your request is exempt by virtue of the following exemption, Section 12(1). 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 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 as such information is held on various data bases over the 10 localities.

The scope of the request has been carefully considered. The work would involve reviewing records across approximately ten localities over multiple years, drawing on a combination of digital and analogue sources. For digital records, there is no automated coding or searchable field available to extract the required information, meaning each record would need to be individually accessed, read, and interpreted; the same manual approach would also apply to analogue records. This process would need to be replicated across all ten localities, significantly increasing the overall time required.

Based on a more detailed assessment, with each record taking approximately 12–15 minutes to locate, review, and extract the relevant information, reviewing in the region of 55–60 records per locality (approximately 550–600 records in total) would result in an estimated time of around 72 hours of work. This is approximately four times the statutory cost limit set under Section 12 of the Freedom of Information Act 2000 (£450, equivalent to 18 hours at £25 per hour). As such, it would not be feasible to complete the request within the cost limit.

On this basis, section 12 has been applied to the request for data for the years prior to 2025/26 as this would exceed the appropriate limit prescribed in the act.

2025/26 – 18

2. Please refer to the response to question 1 for years prior to 2025/26.

2025/26 – 17

3. 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 believe disclosure of this information would be likely to prejudice the commercial interests of the providers and the negotiating capabilities of NHS GM, particularly in relation to current ongoing negotiations, future commissioning, negotiation and value-for-money considerations.

• If a competitor charges a higher price, it would be to NHS GM’s commercial detriment, as it would risk upward pressure on prices
• If a competitor charges a lower price, it would be to that provider’s detriment, as that might causes market prices to lower to reduce their market share (and therefore revenue).

Balancing Test.

After considering the arguments outlined above, we have decided to withhold this information.

While we recognise the importance of transparency in relation to NHS commissioning arrangements, this is met through the publication of the contract register and summary details rather than the disclosure of full contractual documents.

To support transparency, the following information is available on our contract register (which is available via the NHS GM publication scheme “lists and registers” on our website).

• The name of the provider
• The service area or specialty commissioned
• The contract start and end dates
• The Contract Value
• Confirmation that the contract is based on the NHS Standard Contract

In line with section 16 of the FOI Act please find below a link to the register to assist you.

nhsgm-conreg-feb-25-final.pdf

4. NHS GM does not formally commission any pathways for this group.
5. At present, there are no formally approved or commenced changes to the commissioning or provision of services specifically for people with dissociative disorders.

However, the organisation is currently reviewing overall service spend and pathways across relevant areas, with the aim of identifying opportunities to improve value and patient pathways. This work is at an early, exploratory stage and has not yet resulted in any formal proposals, decisions, or timelines for change specific to dissociative disorder services.