FOI2026/1879

This enquiry is submitted under the Freedom of Information Act 2000 and the public‑interest provisions relating to patient safety, governance transparency, and statutory compliance with NHS England’s July 2024 guidance, Guidance to integrated care boards on intensive and assertive community mental health care.

1. NB it seems the ICB hasn’t yet published the CMHT review that was completed last year, which might have clarified some of the public interest questions below (please does the ICB now have a date when the CMHT review completed last year will be published?)
2. Please, does the GM ICB Mental Health Transformation programme have a dedicated risk register, and who is the SRO? 

Section A: DIALOG+ Adoption and Care‑Planning Assurance

A1. Please confirm whether NHS Greater Manchester ICB, GMMH, or Pennine Care have considered, piloted, evaluated, or adopted DIALOG+ as a structured care‑planning tool, and provide copies of any option appraisals, business cases, evaluation reports, or minutes where DIALOG+ was discussed with the ICB Mental Health Transformation programme leads.

A2. If DIALOG+ has not been adopted, please provide the evidence base, evaluation framework, and governance rationale for selecting the Living Well model as the alternative care‑planning approach across all ten GM localities, including any comparative analysis undertaken between Living Well and DIALOG+.

A3. Please set out how NHS GM assures itself that care planning across GM is consistently co‑produced, person‑centred, and outcome‑focused in the absence of a standardised tool such as DIALOG+, including the metrics, audit tools, and quality‑governance mechanisms used to monitor care‑planning quality.

Section B: Assertive Outreach – Compliance with National Guidance and Post‑Gap‑Analysis Risks

B1. NHS England’s July 2024 guidance required all ICBs to complete a full review of assertive outreach provision by Q2 2024/25. Please confirm whether NHS GM’s “full gap analysis”, referenced in FOI 2025/1496, has been completed. If completed, please provide the findings relating to cohort size by locality, current case numbers managed via assertive outreach pathways, overlap with forensic, CRHTT, and CMHT caseloads, and the validated investment required to meet national standards.

B2. The May 2025 Board papers identify several strategic risks relating to assertive outreach implementation. Please confirm which of the following risks have been formally added to the ICB’s central risk register, including their current risk scores, named risk owners, and dates of last review: the £11m funding gap for assertive outreach implementation; the lack of resourced Neighbourhood Mental Health Teams in parts of GM; the risk of assertive outreach cohort marginalisation; fragmentation between health and social care; staff skills and confidence gaps in CMHTs; and variation and inconsistency across GMMH and Pennine Care.

B3. For any risks not added to the ICB risk register, please provide the governance rationale for non‑escalation and identify the alternative monitoring arrangements, committees, or assurance pathways through which these risks are being overseen.

B4. Please provide details of the immediate, intermediate, and long‑term actions taken by NHS GM since completion of the gap analysis to mitigate each of the risks identified above, including timescales for completion and any dependencies on provider‑level transformation programmes.

B5. Please describe the operational and governance interface between the assertive outreach transformation workstream and the wider Living Well / Neighbourhood Mental Health transformation, particularly for patients who fall between the two models or who require assertive engagement but are currently supported within CMHTs.

B6. NHS England’s 2025 system review found that only a few of forty‑two ICBs could provide full assurance of appropriate assertive outreach provision. Please set out evidence of how NHS GM’s position compares to the national picture and what lessons have been drawn from higher‑performing regions.

NHS Greater Manchester is aware of national discussions regarding variation in Assertive Outreach provision and assurance across England.

Section C: CMHT and Early Intervention – Inherent and Cumulative Risks

C1. Please confirm which risks relating to CMHT unallocated patients (634 as of September 2025), CMHT waiting times (average 236.7 days), and workforce capacity and burnout in CMHTs and Early Intervention Services have been formally recorded on the ICB risk register, including their current risk scores and named risk owners.

C2. Please provide details of the immediate actions taken to address the 634 unallocated CMHT patients, the 236.7‑day average waiting time, and workforce pressures in CMHTs and EIPs, including any surge plans, temporary staffing arrangements, or pathway redesigns.

C3. Please explain how NHS GM distinguishes between inherent risks and cumulative risks within its risk‑management framework for CMHTs and Early Intervention Services, and how this distinction informs escalation decisions to the ICB risk register.

C4. Please set out the governance and escalation pathways through which risks identified within CMHTs and EIPs are escalated to the ICB risk register including thresholds for escalation, responsible committees and reporting cycles.

Section D: Transparency, Publication, and Public Accountability

D1. Please confirm whether NHS GM will publish the full assertive outreach gap analysis findings, the relevant ICB risk‑register entries (with appropriate redaction), and the action plans and mitigation progress relating to community mental health, assertive outreach, CMHTs, and Early Intervention Services.

D2. Given the public interest in these matters, including the CMHT independent review concluded in October 2025 but not yet published, please confirm whether NHS GM will establish a regular public reporting mechanism, such as quarterly public briefings, covering community mental health transformation progress, assertive outreach implementation and risk mitigation, and CMHT/EIP performance indicators including waiting times, unallocated caseloads, and discharge rates.

1. At the time of responding to this request, NHS Greater Manchester is working through the necessary governance processes prior to publication. A publication date has not yet been confirmed.
2. Yes – there is a Risk Register. SRO: Manisha Kumar

A1. Yes – DIALOG+ has been considered. NHS Greater Manchester does not hold recorded information in the form of option appraisals, business cases or evaluation reports relating to DIALOG+.

A2. DIALOG+ is included within NHS Greater Manchester’s commissioning intentions for 2025/26, with phased implementation underway. NHS Greater Manchester does not hold a comparative analysis between Living Well and DIALOG+ as an alternative care-planning approach across all ten Greater Manchester localities.

A3. DIALOG+ is included within NHS Greater Manchester’s commissioning intentions for 2025/26, with phased implementation underway. NHS Greater Manchester does not hold a single standardised DIALOG+ assurance framework, audit tool or consolidated set of metrics demonstrating implementation across all ten localities at this stage. Care-planning quality is considered through established provider quality, programme and assurance arrangements.

B1. NHS Greater Manchester can confirm that work has been undertaken to review Assertive Outreach provision across Greater Manchester in response to NHS England requirements. This has included cohort identification exercises and caseload audits across Community Mental Health Teams (CMHTs) to understand the scale of need, population characteristics and impact on service capacity.

The review identified that:

• There is currently no consistent Greater Manchester-wide Assertive Outreach function, resulting in variation in service delivery and gaps in provision for individuals with the highest levels of risk and complexity.
• Cohort identification and caseload audits have been completed across CMHTs.
• Work has improved understanding of the population requiring Assertive Outreach support and strengthened approaches to risk management, care planning and family/carer involvement.

NHS Greater Manchester does not hold a final published dataset containing:

• cohort size by locality;
• current case numbers managed through Assertive Outreach pathways;
• overlap with forensic, CRHTT and CMHT caseloads; or
• a formally approved investment requirement to achieve national standards.

B2. The Assertive Outreach programme has not added each of the risks listed in the request as separate risks on the ICB’s central risk register.

Instead, an overarching Assertive Outreach strategic risk has been established through the Greater Manchester Community Mental Health Transformation Programme and has progressed through the programme’s governance process. The risk is currently owned by Lynzi Shepherd, Assistant Director of Mental Health Strategic Commissioning, and was last reviewed through the Community Mental Health Transformation Programme governance arrangements with the next update scheduled to be reported to the Mental Health Partnership Board.

The risk is recorded as:

“There is a risk that the current Assertive Outreach (AO) function across Greater Manchester is limited or absent, creating a gap in system-wide delivery and impacting patients requiring Assertive Outreach care.”

Current Risk Score: 16 (Likelihood 4 × Impact 4)

This overarching risk incorporates a number of interdependent risk themes including:

• Lack of dedicated investment and long-term funding requirements.
• Workforce capacity and high CMHT caseloads limiting the ability to deliver an Assertive Outreach approach.
• Variation in community and neighbourhood mental health provision across localities.
• Fragmentation across services and partnership working arrangements, including health and social care interfaces.
• Information-sharing and interoperability challenges.
• Inconsistency in delivery models across providers.
• Risks relating to engagement, continuity of care and support for individuals requiring an Assertive Outreach approach.

These risks are not managed as separate strategic risks because they are considered interconnected elements of the overall risk relating to the absence of a consistent and sustainable Greater Manchester-wide Assertive Outreach function. They continue to be monitored through the Assertive Outreach Working Group, Community Mental Health Transformation Programme governance, Community & Crisis Mental Health Strategic Group, Mental Health Partnership Board and associated provider governance arrangements.

B3. The individual risks listed in the request have not been escalated as separate strategic risks on the ICB’s central risk register because they are recorded and managed as interdependent components of the overarching Assertive Outreach strategic risk described in response to B2.

The alternative monitoring and assurance arrangements are the Assertive Outreach Working Group, Greater Manchester Community Mental Health Transformation Programme governance, the Community & Crisis Mental Health Strategic Group, the Mental Health Partnership Board and associated provider governance arrangements.

These arrangements provide oversight of the overarching risk, associated mitigating actions and any requirement for further escalation through NHS Greater Manchester’s risk management processes.

B4. NHS Greater Manchester holds an Assertive Outreach Action Plan which was developed following the review and gap analysis of Assertive Outreach provision across Greater Manchester.

The Action Plan includes actions relating to:

• establishment of the Greater Manchester Assertive Outreach Working Group;
• completion of cohort identification and caseload audit activity;
• strengthening of care coordination, safety planning and risk management processes;
• removal of discharge solely on the basis of non-attendance;
• review of exemplar models of practice, including learning from Leeds and Stockport;
• development of a Greater Manchester Assertive Outreach model and implementation approach; and

• staff skills and confidence gaps in CMHTs

• consideration of workforce, operational and commissioning requirements required to support future delivery.

The Action Plan is monitored through the Assertive Outreach Working Group and Community Mental Health Transformation governance arrangements. The plan contains a range of actions with associated leads and target dates.

The Action Plan does not map individual actions, timescales and success measures against each risk listed within the request as separate risk entries.

B5. Based on recorded programme information, Assertive Outreach is aligned within wider Community Mental Health and Neighbourhood Mental Health transformation arrangements.

Governance is through the Community & Crisis Mental Health Strategic Group and wider Community Mental Health Transformation Programme arrangements, with the Assertive Outreach workstream connected to the development of the wider Neighbourhood Mental Health Model.

NHS Greater Manchester does not hold, within the information reviewed for this response, a final agreed operational pathway or interface document setting out arrangements for all patients who fall between models or who require assertive engagement while currently supported within CMHTs.

B6. NHS Greater Manchester is aware of national discussions regarding variation in Assertive Outreach provision and assurance across England.

Local review work identified that Greater Manchester does not currently have a consistent Greater Manchester-wide Assertive Outreach model and that there is variation in provision across localities.

NHS Greater Manchester has met with colleagues from Leeds to understand their Assertive Outreach model.

NHS Greater Manchester does not hold, within the records reviewed for this response, a formal benchmarking analysis comparing Greater Manchester against specific higher-performing regions, nor a documented lessons-learned review from those systems.

C1. Based on the recorded information reviewed for this response, NHS Greater Manchester does not hold separate corporate risk register entries for each of the specific risks as worded in the request: CMHT unallocated patients, CMHT waiting times, and workforce capacity and burnout in CMHTs and Early Intervention Services.

Related issues, including demand and capacity pressures, waiting times, workforce availability, caseload management and safe allocation of patients, are managed through Community Mental Health Transformation Programme arrangements and associated provider performance, quality and assurance processes.

As the specific risks listed in the request are not held as separate corporate risk register entries, NHS Greater Manchester does not hold separate current risk scores or named corporate risk owners for those individual risks.

C2. NHS Greater Manchester, working with provider organisations, has implemented a range of actions to improve patient safety, strengthen clinical oversight and address pressures within Community Mental Health services.

Actions have included:

• Establishing oversight arrangements to improve visibility of unallocated caseloads and associated risks.
• Implementing “Safe and Stabilise” approaches to ensure ongoing clinical oversight and risk management for individuals awaiting allocation.
• Working with providers to review workforce requirements, service capacity and sustainable delivery models as part of wider transformation activity.

NHS Greater Manchester continues to work with provider organisations to improve access, reduce unwarranted variation and strengthen community mental health services through the wider transformation programme.

NHS Greater Manchester does not hold centrally a single consolidated record of all provider-level surge plans, temporary staffing arrangements or local workforce initiatives and therefore cannot provide comprehensive details in response to this request.

C3. NHS Greater Manchester manages risk in accordance with its corporate risk management framework.  Inherent risk refers to the level of risk present before controls or mitigations are applied. Cumulative risk refers to the combined impact of multiple interconnected risks across programmes, services or organisational boundaries which may affect the achievement of strategic objectives.

In determining whether escalation is required, NHS Greater Manchester considers factors including the severity of potential impact, likelihood of occurrence, effectiveness of existing controls, the extent to which risks are interdependent, and whether the risk presents a significant threat to delivery of organisational objectives or statutory responsibilities.

Where risks are assessed as having broader system-wide implications, they may be escalated through programme governance and, where appropriate, considered through the corporate risk management process.

C4. Risks relating to Community Mental Health and Early Intervention services are managed through a range of operational, programme, performance and quality governance arrangements.

Issues identified at service or programme level are reviewed through provider governance processes and relevant programme boards and assurance forums. Risks that cannot be adequately managed within existing controls, or which may materially impact the achievement of strategic objectives, may be escalated through NHS Greater Manchester governance arrangements for consideration within the corporate risk management framework.

Escalation routes include relevant transformation programme governance, quality and performance oversight arrangements and executive management structures, with reporting undertaken in accordance with established governance and risk management processes.

D1. NHS Greater Manchester is committed to transparency and accountability and routinely publishes information in accordance with statutory requirements, publication scheme obligations and corporate governance processes.

Information relating to Community Mental Health Transformation, programme progress, board reports and relevant public papers is published where appropriate through established governance arrangements.

At the time of response, NHS Greater Manchester cannot provide a commitment to publish specific documents, including full gap analysis findings, corporate risk register entries or programme documentation, as publication decisions are subject to ongoing governance, information governance, confidentiality and legal considerations. Any future publication decisions will be taken in accordance with relevant policies and statutory obligations.

D2. NHS Greater Manchester recognises the importance of public assurance regarding Community Mental Health services and transformation activity.

Progress relating to Community Mental Health Transformation is currently monitored through established governance arrangements, with relevant information reported through existing programme, executive and public governance processes where appropriate.

At present, NHS Greater Manchester has not made a formal decision to establish a separate quarterly public reporting mechanism specifically covering Assertive Outreach, Community Mental Health Transformation, CMHT performance, Early Intervention performance, waiting times, unallocated caseloads or discharge activity.

The organisation will continue to consider how best to provide meaningful public assurance through existing governance, reporting and engagement arrangements while ensuring information is accurate, proportionate and consistent with statutory reporting requirements.