This is HSJ’s fortnightly briefing covering quality, performance and finances in the mental health sector

Feedback and comments are welcome, so please feel free to email me in confidence.

Just to clarify

NHS England’s chief executive Simon Stevens could not have been clearer about what the mental health investment standard was when he was quizzed by MPs this week.

Appearing before the health select committee on Tuesday afternoon, Mr Stevens was asked what repercussions the 32 clinical commissioning groups who failed to raise mental health spending in line with their allocation growth would face.

He didn’t really address the specific point about repercussions, although one interpretation of his answer is “none at all”. Here’s the full quote: “There’s not a requirement on every single CCG to meet the mental health investment standard, the requirement is that across England in aggregate we meet the MHIS and our expectation is the vast majority of CCGs should do so.”

This is a very useful clarification, because I (like many others I have spoken to in the sector) was under the impression that it did require every single CCG to meet the national standard.

Fine print

After all, the Forward View into Action: Planning for 2015-16 guidance says: “We expect each CCG’s spending on mental health services in 2015-16 to increase in real terms, and grow by at least as much as each CCG’s allocation increase.”

And, Delivering the Forward View: NHS planning guidance for 2016-17 to 2020-21, says: “Commissioners must continue to increase investment in mental health services each year at a level which at least matches their overall expenditure increase.”

Moving the goal posts?

However, Stevens did not necessarily move the goalposts this week. The planning guidance for 2017-19 is a bit more ambiguous than the previous years. It merely said one of the national “must do” priorities is to meet the MHIS.

It does not define what that standard actually is though, leaving it open to interpretation, and it does not set it out as a specific requirement for each CCG.

The only hint we get is in one of the technical annexes where it says in relation to the standard: “In line with the previous two years, CCGs are required to continue to focus on investment in mental health services to ensure parity with other areas of investment.”

If we were basing our interpretation of the standard on the definition set out over the previous two years then we might expect it to apply to every commissioner.

Simon says

Apparently not though, based on what Mr Stevens told MPs this week.

The 2017-19 planning guidance says that when a CCG fails to achieve the mental health investment requirements without a “valid cause”, NHS England can consider regulatory sanctions including “in exceptional circumstances imposing directions on the CCG to increase its level of investment”.

Sounds clear enough to me – that Mr Stevens chose not to just say this to MPs leaves his options as open as possible.

But by dodging the question about the repercussions of not hitting the standard, Stevens is doing the sector a disservice. Yes, he may be right about the fact that the national picture is more important than what happens in every individual CCG.

What matters is if we muddy the waters we lose track of who is accountable for hitting it. If it is no longer every CCG accountable officer’s job, there is a risk that CCG AOs will no longer take personal responsibility.

We know mental health is receiving more money, although we also know data from the sector has to be better so we can judge whether the promised improvements have been made. But what the sector does not need is the extra difficulty of blurred lines of accountability.