| Reference | FOI 2026/1798 |
|---|---|
| Description | FOI to the ICB regarding governance arrangements and requirements for organisations or individuals providing clinical training, competency assessment, clinical supervision, care plan review, or other clinical oversight services in relation to Personal Health Budget (PHB) packages. |
| Date Requested | 03/06/2026 |
| Date Replied | 01/07/2026 |
| Category | Continuing Health Care (CHC) |
I am writing to request information under the Freedom of Information Act 2000 regarding governance arrangements and requirements for organisations or individuals providing clinical training, competency assessment, clinical supervision, care plan review, or other clinical oversight services in relation to Personal Health Budget (PHB) packages.
Please provide the following information:
If any part of this request exceeds the cost limit, please provide the information that can be supplied within the limit and advise how the request may be refined.
1.
| Locality | |
| Bolton | We operate using the principles in NHS England » Guidance on direct payments for healthcare: Understanding the regulations
Governance in PHB arrangements includes:
· Ensuring engagement from the individual to develop a person-centred care plan to meet their identified health outcomes |
| Bury | Ensuring that care is delivered safely, effectively, and in line with the agreed care plan. Maintaining appropriate clinical oversight and accountability. Ensuring that providers are able to meet the assessed needs of the individual. Monitoring that funds are used appropriately and in accordance with agreed arrangements. |
| HMR | The systems, processes and controls in place to ensure PHB’s are safe, aligned with care needs and agreed outcomes, compliant and subject to robust oversight and monitoring. |
| Manchester | We also operate using the principles in NHS England » Guidance on direct payments for healthcare: Understanding the regulations
Whilst the following governance arrangements are contained within the auspices of Greater Manchester Continuing Health Care (Manchester) the frameworks, legal and governance that apply to our service. A PHB holder should expect and are entitled to the same quality assurance as any other service user. We have an ongoing relationship with Disability Positive Brokerage service which support our above responsibilities whilst also providing an independent service to PHB holders such as support with support planning, managing budgets and answering queries pertaining to the responsibilities of Direct Payment holders. Training and quality oversight of Personal Assistants is supported by Abuka Training . Governance in our PHB arrangements as described and detailed in the frameworks mentioned encompass all the following :-
· Ensuring engagement from the individual to develop a person-centred care plan to meet their identified health outcomes |
| Oldham | · Competency Documents
· DBS |
| Salford | Salford are unable to answer these questions as we commission via NCA community services and Salford Adult Social Brokerage service contract and therefore do not monitor or maintain the contract and training requirements. |
| Stockport | There is no specific definition in terms of governance there is however the general principles that apply in that the responsibility for authorising PHBs sits with NHS GM and each locality team and there is a need to ensure, health and well-being needs are being met, Safeguarding duties are fully met, where applicable best interests are met, that statutory obligations are met and we are fulfilling our responsibility in ensuring public funds are used to enable the individuals in receipt of a PHB to live independent and full lives whilst delivering value for money and using public funds appropriately. There is also a requirement for localities to ensure that PHBs are fully incorporated into a BAU approach and that the 6 PHB steps are implemented as per the PHB quality framework |
| Tameside | We operate using the principles in NHS England » Guidance on direct payments for healthcare: Understanding the regulations
Governance in PHB arrangements includes:
· Ensuring engagement from the individual to develop a person-centred care plan to meet their identified health outcomes |
| Trafford | Ensuring that care is delivered safely, effectively, and in line with the agreed care plan. Maintaining appropriate clinical oversight and accountability. Ensuring that providers are able to meet the assessed needs of the individual. Monitoring that funds are used appropriately and in accordance with agreed arrangements. |
| Wigan | Wigan locality operates the key principles identified by the Department of Health in order to give people control, keep them safe and protect NHS resources: please access NHS England » Guidance on direct payments for healthcare: Understanding the regulations for further details. |
2.
| Locality | |
| Bolton |
Clinical oversight or quality assurance – Assurance that the individual will inform us of any changes in need or concerns re staffing or the meeting their health needs. Reviewed during CHC statutory reviews in line with National Framework |
| Bury | Within the locality there is not a single consolidated specification covering all functions listed in 2. However, the following principles apply, that providers must demonstrate that they are able to safely meet the individual’s assessed care needs by agreeing with the contract. Providers are responsible for ensuring that staff are appropriately trained and competent to deliver care. Training and competency processes are recorded and maintained by the provider. Where required, providers are expected to work with secondary care services and specialist teams to support training and competency development, particularly for complex or specialist interventions. Governance arrangements for functions such as clinical training, competency assessment, supervision, care planning, and risk management are expected to be embedded within provider systems and overseen through commissioning arrangements. |
| HMR | All PHB holders must work in line with the agreed care and support plan and PHB policy to ensure PA’s receive both foundation training and delegated healthcare task training and achievement of competencies which must be maintained. This is subject to review by the ICB at both the CHC/ PHB review and annual audit to ensure that monies that have been provided have been utilised in the training and competency matrix for all PA’s. Care and support plans and care plans for PA’s to follow are in place – care and support plans are reviewed by PHB panel and practitioners at review to ensure they continue to be relevant to the individuals’ needs along with risk assessments. |
| Manchester | We have an ongoing relationship with Disability Positive Brokerage service which support our above responsibilities whilst also providing an independent service to PHB holders such as support with support planning, managing budgets and answering queries pertaining to the responsibilities of Direct Payment holders.
Training and quality oversight of Personal Assistants is supported by Abuka Training. |
| Oldham | · Clinical Training meeting per individual.
· Evidence of training and competency · Not currently requested, however some brokers provide this. · Copies of care plan documentation and annual reviews. · Risk assessment is completed by clinicians so not included. · Clinical oversight by use of nurses within case management packages or case managers from the ICB if no delegated healthcare task. |
| Salford | Salford are unable to answer these questions as we commission via NCA community services and Salford Adult Social Brokerage service contract and therefore do not monitor or maintain the contract and training requirements. |
| Stockport | Adherence to the principles set out in the delegated healthcare activities DOH&SC. Additionally Case Managers ensure that care delivered is in line with assessed need, that any necessary training and associated competencies are evidenced, that care plans reflect assessed needs and remain subject to review; clinical oversight and assurance is therefore retained by the allocated Case Manager. |
| Tameside |
|
| Trafford | Within the locality there is not a single consolidated specification covering all functions listed in 2. However, the following principles apply, that providers must demonstrate that they are able to safely meet the individual’s assessed care needs by agreeing with the contract. Providers are responsible for ensuring that staff are appropriately trained and competent to deliver care. Training and competency processes are recorded and maintained by the provider. Where required, providers are expected to work with secondary care services and specialist teams to support training and competency development, particularly for complex or specialist interventions.
Governance arrangements for functions such as clinical training, competency assessment, supervision, care planning, and risk management are expected to be embedded within provider systems and overseen through commissioning arrangements. |
| Wigan |
Risk assessment review – included within the support plan, regular CHC review and if appropriate refer to the PHB risk panel to support staff to consider specific requests and share decision making and risk management. |
3.
| Locality | |
| Bolton | · PHB Direct payment employer/Brokers/Third Party services undertake safe recruitment, employing staff with relevant skills and experience to meet the individual’s health needs.
· Personal Assistants are not required to hold professional qualifications for the role they undertake. · PHB Direct payment employer/Brokers/Third Party services are required to provide proof of employment liability insurance and renewals annually. Reviewed during PHB 3 month and annual reviews. · PHB Direct payment employer/Brokers/Third Party services are expected to arrange provision for staff to complete appropriate safeguarding training and to report to ICB any safeguarding concerns. ICB will advise if this meets the LA threshold for a SG concern to be submitted. · PHB Direct payment employer/Brokers/Third Party providers are required to provide confirmation of completion of newly recruited Personal Assistants completing training and annual renewals for existing staff. Core Mandatory Training: · Dignity in Care · Moving/Handling · Infection control · Nutrition/Hydration · Basic life support · Safeguarding Adults Level 1 · Safeguarding Children Level 1 · Handling Information · Medication management · Skin care (including tissue viability)
· Any identified person specific and/or bespoke training for clinically delegated healthcare tasks should be sourced. See question 2. |
| Bury | The locality does not hold a single document specifying minimum thresholds for all roles for care providers to our knowledge. However, where healthcare tasks are delegated, training is expected to be provided by a competent trainer. PHB guidance requires appropriate safeguarding arrangements, employer responsibilities (including insurance) and ongoing risk assessment and monitoring. In locality we would predominantly use a broker to ensure that these checks have been done. |
| HMR | Training providers are required to provide training within their scope of practice and be registered organisations for the delivery of healthcare training. |
| Manchester | · PHB Direct payment employers and our Brokerage staff with relevant skills and experience to meet the individual’s health needs..
· PHB Direct payment employer/Brokers/Third Party services are required to provide proof of employment liability insurance and renewals annually. Reviewed during PHB 3 month and annual reviews. · PHB Direct payment employer and Brokerage are expected to arrange provision for staff to complete appropriate safeguarding training · PHB Direct payment employers and Brokerage are required to provide confirmation of completing training inc annual renewals for existing staff. |
| Oldham | Basic manual handling, IPC, basic life support, personal care and safe feeding training.
Registration with professional bodies for clinical staffs. Insurance usually provided via brokerage or personally in self-managed packages and awareness of all safeguarding protocols. |
| Salford | Salford are unable to answer these questions as we commission via NCA community services and Salford Adult Social Brokerage service contract and therefore do not monitor or maintain the contract and training requirements. |
| Stockport | There are no minimum requirements – each case is considered individually and any training, skills knowledge and expertise required is identified accordingly. In terms of insurance the PHB recipient for direct payments is required to have the relevant insurance in place. |
| Tameside | · Direct payment employer / Brokers / Third Party services undertake safe recruitment, employing staff with relevant skills and experience to meet the individual’s health needs
· PA’s do not hold professional qualifications in the role they undertake · Direct payment employer / Brokers / Third Party services are required to provide proof of employment liability insurance and renewals annually · Direct payment employer / Brokers / Third Party services are expected to provide staff appropriate safeguarding training and to report to ICB any safeguarding concerns. ICB will advise if this meets the LA threshold for a SG concern to be submitted · Direct payment employer / Brokers / Third Party providers are required to provide confirmation of completion of new recruited PA’s completing training and annual renewals for existing staff Core Mandatory Training: · Dignity in Care · Moving/Handling · Infection control · Nutrition/Hydration · Basic life support · Safeguarding Adults Level 1 · Safeguarding Children Level 1 · Handling Information · Medication management · Skin care (including tissue viability)
· Person specific and/or bespoke training for clinical delegated tasks should be sourced. See question 2 |
| Trafford | The locality does not hold a single document specifying minimum thresholds for all roles for care providers to our knowledge. However, where healthcare tasks are delegated, training is expected to be provided by a competent trainer. PHB guidance requires appropriate safeguarding arrangements, employer responsibilities (including insurance) and ongoing risk assessment and monitoring. In locality we would predominantly use a broker to ensure that these checks have been done. |
| Wigan | PHB ethical framework providers, direct payment employer, third Party services undertake safe recruitment, employing staff with relevant skills and experience and provide appropriate training to meet the individual’s health needs with the relevant qualification and experience to provide the care and support or delegated health task.
Services commissioned by GM ICB Wigan locality will be subject to the current contractual requirements under the safeguarding policy for both children and vulnerable adults. Individuals/direct payments commissioning services will follow best practice in relation to safeguarding, vetting, and barring, ensuring that providers are registered with CQC or equivalent regulatory bodies. PA’s employed via a direct payment with associated costs including insurance will be covered within the budget and are explicit within the support plan. PA’s do not need to comply with legislation that will require them to have indemnity cover if practicing unless they are a member of a regulated health profession however it is recommended that all PA’s do take out indemnity insurance on an individual basis or via a union membership. |
4.
| Locality | |
| Bolton | · PHB Direct payment employer is expected to undertake employer training to develop knowledge and understanding of managing incident reporting/safeguarding/risk management related to staff employment utilising their employment liability insurer for guidance.
· PHB Brokers have credibility following ICB due diligence/Third Party services are CQC registered and therefore ICB would expect them to be CQC compliant with all governance requirements. |
| Bury | The locality within the ICB utilises shared PHB and Direct Payment and Personal Assistant guidance. We use provider contracts and service level agreements adhered to via the EPR System. We also use National and local guidance relating to delegated healthcare tasks. These also require providers to have robust governance arrangements in place. |
| HMR | As registered practitioners with their individual professional bodies, they are responsible for ensuring they are operating within their scope of practice and relevant policies/ safeguarding measures in place. |
| Manchester | Not instructed in the ICB PHB policy |
| Oldham | All framework standard policies and procedures needs to be in line with the ICB requirement as held by the ICB. |
| Salford | Salford are unable to answer these questions as we commission via NCA community services and Salford Adult Social Brokerage service contract and therefore do not monitor or maintain the contract and training requirements. |
| Stockport | This is not stipulated in the ICB PHB policy. |
| Tameside | · Direct payment employer is expected to undertake employer training to develop knowledge and understanding of managing incident reporting / safeguarding / risk management related to staff employment utilizing their employment liability insurer for guidance
· Brokers have credibility following ICB due diligence/ Third Party services are CQC registered and therefore ICB would expect them to be CQC compliant with all governance requirements |
| Trafford | The locality within the ICB utilises shared PHB and Direct Payment and Personal Assistant guidance. We use provider contracts and service level agreements adhered to via the EPR System. We also use National and local guidance relating to delegated healthcare tasks. These also require providers to have robust governance arrangements in place. |
| Wigan | Wigan locality operate an ethical framework in conjunction with the LA, with provider contracts and robust governance arrangements in place including appropriate policies and procedures to maintain standards expected to meet the individuals assessed needs.
Where an individual or their representative/nominee choose to take on a direct payment with support from locality and the PHB risk panel, as the principal person they retain the level of responsibility and liability, for all contracts and agreements with care providers and employees, ensuring appropriate safeguards, training, risk management and duty of care are in place. |
5.
| Locality | |
| Bolton | See questions 2 and 3 with regards to training and competencies. |
| Bury | The locality within the ICB gains assurance through a combination of agreement that the provider is able to meet the individual’s assessed needs and that they confirm that they agree to the requirements for Training, competency assessment and sign-off processes. Ongoing clinical oversight and governance arrangements. Also Monitoring arrangements associated with, Care planning, Direct payment agreements and PHB reviews – which should be completed at least annually. |
| HMR | A training matrix is provided to the trainer detailing by the ICB the training/ competencies required. This has to be completed for all individuals prior to commencement of the PHB and competencies maintained – this is reviewed as part of the PHB/ CHC review and at financial audit. |
| Manchester | Via our Training Provider as detailed |
| Oldham | Through engagement with healthcare educators procured by the ICB for this purpose, training commissioned via the PHB will only be provided by a certified provider. |
| Salford | Salford are unable to answer these questions as we commission via NCA community services and Salford Adult Social Brokerage service contract and therefore do not monitor or maintain the contract and training requirements. |
| Stockport | At clinical reviews all aspects of care delivery is considered against assessed needs as well as the competency of staff providing care and any associated training needs. |
| Tameside | See Q2 & Q3 re training and competencies |
| Trafford | The locality within the ICB gains assurance through a combination of agreement that the provider is able to meet the individual’s assessed needs and that they confirm that they agree to the requirements for Training, competency assessment and sign-off processes. Ongoing clinical oversight and governance arrangements. Also Monitoring arrangements associated with, Care planning, Direct payment agreements and PHB reviews – which should be completed at least annually. |
| Wigan | Please refer to Q 2/3 responses |
6.
| Locality | |
| Bolton | See question 2, employer training insurance support is available to advise. |
| Bury | The ICB does not hold a single policy specifying all such requirements, however, we do ask commissioned providers to confirm that they have a structured approach to the training of staff that competency assessments are completed and that where necessary there is clinical supervision and oversight is in place. |
| HMR | There is no formal agreement in place with the training provider to detail this. |
| Manchester | As detailed above |
| Oldham | · No
· No · No · No · Would need to be considered as part of the individual clinician’s revalidation to be provided on request. |
| Salford | Salford are unable to answer these questions as we commission via NCA community services and Salford Adult Social Brokerage service contract and therefore do not monitor or maintain the contract and training requirements. |
| Stockport | This is not stipulated in the ICB PHB policy |
| Tameside | Refer to Q2 – employer training insurance support |
| Trafford | The ICB does not hold a single policy specifying all such requirements, however, we do ask commissioned providers to confirm that they have a structured approach to the training of staff that competency assessments are completed and that where necessary there is clinical supervision and oversight is in place. |
| Wigan | Please see response to Q2/4 |
7.
| Locality | |
| Bolton | No |
| Bury | The locality is not aware that ICB does hold a specific policy prohibiting the use of independent practitioners. All providers, including individual practitioners, must demonstrate that they are Suitable to meet the individual’s needs and are able to operate within appropriate governance and safeguarding arrangements. |
| HMR | They need to be registered organisations in order to undertake the activity. |
| Manchester | Registered in order to practice |
| Oldham | No |
| Salford | Not permitted |
| Stockport | Yes they would be permitted however, see Q3 also |
| Tameside | No |
| Trafford | The locality is not aware that ICB does hold a specific policy prohibiting the use of independent practitioners. All providers, including individual practitioners, must demonstrate that they are Suitable to meet the individual’s needs and are able to operate within appropriate governance and safeguarding arrangements. |
| Wigan | The locality is not aware of a specific policy prohibiting the use of independent practitioners, sole traders or freelance clinicians however if an individual wishes to purchase a service which is a regulated activity they will need to inquire as to whether their provider is registered with the Care Quality Commission (CQC). Activities such as district nursing which are required to be delivered by a registered member of a professional body can only be delivered by a person with the necessary qualification and registration. Direct payments cannot be used to purchase these activities from an unregistered individual service. The Risk Enablement Panel would also provide a forum to support staff to consider specific requests and share decision making and risk management for the use of independent practitioners and establish what core NHS services can be provided in the first instance. Please see response to Q3 for governance. |
8.
| Locality | |
| Bolton | There is not currently an approved provider list, accreditation process, or quality assurance process for providers delivering these services. |
| Bury | The ICB does have an approved list of providers. In locality we are not aware of a central accreditation process specifically for PHB training and competency services. |
| HMR | There is not at present, but this will form part of the transformation work moving forward. |
| Manchester | The ICB does not have a list |
| Oldham | We have a small number of approved providers that are accredited to our financial framework. |
| Salford | Salford are unable to answer these questions as we commission via NCA community services and Salford Adult Social Brokerage service contract and therefore do not monitor or maintain the contract and training requirements. – Not within the ICB CHC team |
| Stockport | No |
| Tameside | There is not currently an approved provider list, accreditation process, or quality assurance process for providers delivering these services |
| Trafford | The ICB does have an approved list of providers. In locality we are not aware of a central accreditation process specifically for PHB training and competency services. |
| Wigan | Wigan locality have an ethical provider framework in conjunction with the LA for domiciliary and complex care agencies/third party organisations. |
9.
| Locality | |
| Bolton | PHB Direct payment employer/Brokers/Third Party services determine suitability via their own due diligence. They continue to use providers based on positive outcomes and audits. |
| Bury | We are not aware of a single codified list of criteria. We would note that as previously mentioned, in practice, providers must demonstrate their ability to safely meet assessed needs and thereby demonstrate appropriate training and competency arrangements. The provider would be expected to access to clinical expertise, including specialist input where required. They should have the ability to maintain governance, safeguarding and oversight arrangements. |
| HMR | The needs of the individual and the scope of practice of the trainer who are bound by their professional code of conduct. |
| Manchester | Previous history, evidential sharing of information, quality service provision in line with the ICB’s governance Framework |
| Oldham | Previous history, evidential sharing of information, quality service provision in line with the ICB’s governance Framework |
| Salford | Salford are unable to answer these questions as we commission via NCA community services and Salford Adult Social Brokerage service contract and therefore do not monitor or maintain the contract and training requirements. |
| Stockport | Consideration would be given to whether they are registered to deliver the service |
| Tameside | Direct payment employer / Brokers / Third Party services determine suitability via their own due diligence. They continue to use providers based on positive outcomes and audits. |
| Trafford | We are not aware of a single codified list of criteria. We would note that as previously mentioned, in practice, providers must demonstrate their ability to safely meet assessed needs and thereby demonstrate appropriate training and competency arrangements. The provider would be expected to access to clinical expertise, including specialist input where required. They should have the ability to maintain governance, safeguarding and oversight arrangements. |
| Wigan | Please see response to Q8 |
10.
| Locality | |
| Bolton | PHB Direct payment employer/Brokers/Third Party services are obligated to:
· Provide adequate information to assist in financial auditing (frequency directed by ICB). · Participate in individual PHB holder CHC reviews (frequency directed by ICB). · Engage in continuous open communication between ICB nurse and PHB Direct payment employer/Brokers/Third Party services. |
| Bury | The ICB requires that PHB’s are monitored and reviewed on an ongoing basis. They are assessed for continued suitability and safe delivery of care when they are reviewed, and the individual or care provider can contact the ICB if there are any changes at anytime prior to the review as necessary. |
| HMR | Not at present but will form part of the transformation work moving forward. |
| Manchester | PHB Direct payment employer/Brokers/Third Party services are obligated to:
· Provide adequate information to assist in financial auditing (frequency directed by ICB). |
| Oldham | The ICB requires that the individual case managers actively monitor the providers, therefore no subjective assessment. |
| Salford | Salford are unable to answer these questions as we commission via NCA community services and Salford Adult Social Brokerage service contract and therefore do not monitor or maintain the contract and training requirements. |
| Stockport | No |
| Tameside | Direct payment employer / Brokers / Third Party services are obligated to:
· Provide adequate information to assist in financial auditing (frequency directed by ICB) · Participate in individual PHB holder CHC reviews (frequency directed by ICB) · Engage in continuous open communication between ICB nurse and Direct payment employer / Brokers / Third Party services. |
| Trafford | The ICB requires that PHB’s are monitored and reviewed on an ongoing basis. They are assessed for continued suitability and safe delivery of care when they are reviewed, and the individual or care provider can contact the ICB if there are any changes at anytime prior to the review as necessary. |
| Wigan | PHB’s are monitored by the Individualised care team, direct payment advisors and finance through regular reviews, support plans and audits. |
11.
| Locality | |
| Bolton | Not held |
| Bury | The ICB holds relevant documentation including, PHB and Direct Payment guidance. Support Plans and Service Level Agreements relating to PHB with the provider and or Broker. |
| HMR | This is the policy and training matrix that we follow pending finalisation of the GM policy |
| Manchester | The ICB holds relevant documentation including, PHB and Direct Payment guidance. Support Plans and Service Level Agreements relating to PHB with the provider and or Broker. |
| Oldham | No |
| Salford | Salford are unable to answer these questions as we commission via NCA community services and Salford Adult Social Brokerage service contract and therefore do not monitor or maintain the contract and training requirements. |
| Stockport | Not available |
| Tameside | We do not hold any |
| Trafford | The ICB holds relevant documentation including, PHB and Direct Payment guidance. Support Plans and Service Level Agreements relating to PHB with the provider and or Broker. |
| Wigan | Wigan locality holds relevant documentation including a legacy PHB policy and PHB risk enablement panel TOR and DP guidance until the GM PHB policy is agreed. Governance frameworks relating to the commissioning or approval of providers delivering these functions are maintained in conjunction with the local authority as part of the ethical framework. |
12.
| Locality | |
| Bolton | There are no restrictions on new providers. |
| Bury | In locality we are not aware that the ICB operates a formal exclusion list. However, providers must, demonstrate that they can safely and effectively deliver care. They need to provide assurance that they maintain appropriate governance, training and supervision arrangements and be able to meet the needs of the individual as agreed within the care plan. Where these criteria are not met, the provider would not be considered suitable for that package of care. |
| HMR | As previous – the trainer needs to operate within their scope of practice. |
| Manchester | Any requests for an alternative care provider to be commissioned would be dealt with on a case by case basis. |
| Oldham | The ICB would require copies of the structures, policies, protocols and standards of care guidance to be considered prior to any commissioning taking place. The provider will also need to confirm to the locality’s agreed financial framework. Due diligence with CQC and other locality providers for local intelligence. |
| Salford | Any requests for an alternative care provider to be commissioned would be dealt with on a case by case basis. |
| Stockport | NA |
| Tameside | There are no restrictions on new providers. |
| Trafford | In locality we are not aware that the ICB operates a formal exclusion list. However, providers must, demonstrate that they can safely and effectively deliver care. They need to provide assurance that they maintain appropriate governance, training and supervision arrangements and be able to meet the needs of the individual as agreed within the care plan. Where these criteria are not met, the provider would not be considered suitable for that package of care. |
| Wigan | Please see response to Q4 |