Written evidence submitted by The British Association for Counselling and Psychotherapy (BACP)



The British Association for Counselling and Psychotherapy (BACP) is pleased to respond to this important inquiry on the introduction of Integrated Care Systems. We believe ICSs have a critical role to play to lead a genuine partnership of equals between the NHS local government and the voluntary and community sector to deliver person-centred care ensuring that mental and physical health are given equal importance in their decision-making processes and redressing the stark health inequalities that exist across the country.


BACP works to promote the role and relevance of the counselling professions in improving psychological wellbeing and mental health and to develop safe, ethical and competent practice. We are committed to improving equality, diversity, and inclusion (EDI) by creating ‘a profession for the future’, addressing systemic barriers within the profession to improve access to psychological therapies for all who need them.


BACP is the leading and largest professional body for counselling and psychotherapy in the United Kingdom with over 60,000 members, including 900 organisational members, most of which are VCSE sector, not for profit, providers of counselling and mental health and wellbeing support.



Preventing a postcode lottery of mental health support


We are supportive of the need for Integrated Care Systems (ICSs) to retain local autonomy and flexibility to tackle long-standing health inequalities to meet local need. However, there are three areas where we would welcome much stronger direction from Central Government to ensure a universal high-quality offer from across all 42 ICSs and thus prevent a postcode lottery of provision of mental health provision.


1) Greater consistency of approach in engaging voluntary and community sector partners, particularly those VCS partners working with marginalised communities, known to be at greatest risk of the impact of health inequalities.


2) Appropriate representation of Mental Health across ICS leadership structures to drive forward much needed parity of esteem between physical and mental health.


3) Clear direction from ICSs on tackling the Mental Health Crisis, with each ICS mandated to develop a fully funded post-covid mental health recovery plan for their area, supported by a robust workforce development strategy, providing strategic direction to rebuild primary and community mental health services.



This submission provides additional evidence to justify these proposals below.


1) Enhancing the role of the Voluntary and community sector


The role of the VCSE sector is critical in helping ICSs to deliver place-based planning and commissioning. The experience of BACP organisational members in their engagement with emerging ICSs has been mixed, reflecting a need for guidance and targets that bring about real involvement and the development of relationships with a full range of organisations that have trusted relationships with, and insights from, communities most impacted by health inequalities.


Organisations with relationships with more than one ICS have noted significant inconsistencies in approaches to involvement of VCSE organisations.


Issues raised by organisations include inconsistency in:



In balancing the autonomy of ICSs with the need to achieve their statutory duties, BACP calls on the inquiry to set clear mandate for ICBs to demonstrate active engagement of communities and the VCSE sector that goes beyond traditional committee-led processes and that create real relationships with a diverse range of community organisations, particularly those working with marginalised communities, known to be at greatest risk of the impact of health inequalities.



2) Local Leadership to drive real change in mental health investment and support


Whilst we welcome the clause in the Health and Care Act 2022 on Expected Mental Health Spending (3 12E), we are concerned that without effective representation of mental health leadership we will not see the required levels of increased investment across each of the 42 ICSs. There is an additional concern that health devolution could further exacerbate local variation in the quality of mental health provision.


BACP would like the Secretary of State for Health to give clear guidance to ensure that Mental Health leadership is fully represented on each ICS Board and ICS Partnership as well as playing a major role in place-based partnerships and neighbourhood networks. This would ensure that decisions on budgets and prioritisation would be informed by appropriate expertise.






3) A uniformed approach to delivery through Mental Health Recovery Plans in each ICS area to address longstanding inequalities


ICSs have a critical role to play in improving people’s mental health, improving the services they rely on, reducing health inequalities and improving access to mental health services for marginalised groups in need.


BACP supports the call from the Royal College of Psychiatrists and others, for each ICS to produce a fully funded mental health recovery plan, to ensure everyone with a mental illness can get the help they need when they need it, addressing the growing waiting lists and ensuring much earlier intervention. This should be supported by a robust workforce development strategy which includes recruitment, training and retention and wellbeing schemes to meet the mental health priorities of the local population.


October 2022