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Subject: Integrated Commissioning Status: For Publication

Report to: Health and Wellbeing Board Date: 30 June 2015

Report of: Sheila Downey, Director of Adult Services Gail Hopper, Director of Children’s Services Lesley Mort, Chief Officer, HMR CCG Wendy Meston, Interim Director of Public Health Author: Chris O'Gorman

Author Email: wendy.meston@rochdale.gov.uk Tel: 01706 927089

Comments from Statutory Officers:

Section 151 Officer - Yes Monitoring Officer - Yes

Key Decision: No

1. Purpose of Report 1.1 The purpose of this report is to brief member of the Health and Wellbeing Board

on progress in developing integrated commissioning arrangements for health and social care services, in the borough of Rochdale, and in the development of a Locality Plan which forms part of the local planning processes for the Greater Manchester Devolution Agreement as it relates to health and social care.

1.2 In this report, the term ‘integrated commissioning’ is used to refer to formal arrangements between NHS Heywood, Middleton and Rochdale Clinical Commissioning Group and Rochdale Borough Council to work together to plan, design, procure, and monitor all, or very nearly all, of the health and care services which currently commissioned separately by both organisations. If approved, these arrangements would cover at least £380m of joint expenditure which would be managed through one or more pooled funds.

3. Background

2. Recommendations 2.1 The Health and Wellbeing Board is asked to: 2.1.1 note the establishment of the Integrated Commissioning Board 2.1.2 appoint the members and substitutes of the Integrated Commissioning

Board having received nominations from both Council and Clinical Commissioning Group

2.1.3 note the progress of the large-scale integrated commissioning programme 2.1.4 note the development of a Locality Plan in line with the expectations of the

Greater Manchester Devolution Agreement

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3.1 Health and Wellbeing Board last received an update on the integrated

commissioning programme on 31 March 2015. At this meeting, the Board approved proposals to create a governance structure for integrated commissioning, reporting to Health and Wellbeing Board. The Board also approved in principle the terms of reference for an Integrated Commissioning Board.

3.2 The purpose of the ICB is to commission high quality health, social care and

allied services for the people of the borough of Rochdale, in order to meet assessed population, community and individual need, within the financial resources of the pooled fund(s) over which the ICB has control. The ICB would manage the pooled fund(s) established under section 75 of the NHS Act 2006, whereby prescribed health related functions of Rochdale Borough Council (RBC) and prescribed functions of NHS Heywood, Middleton and Rochdale Clinical Commissioning Group (HMR CCG) are exercised, and health and health-related services commissioned. The initial pooled fund has been created from 1 April 2015 for the Better Care Fund.

3.3 For the ICB to undertake fully its role, it will require the delegation of

executive power from RBC for the commissioning and purchasing of the services within scope of the Board, which shall include all section 75 agreements in place in the Borough of Rochdale. Full Council approved the establishment of the ICB at its meeting on 19 May 2015 and delegated to it appropriate powers to commission and purchase the services in scope.

3.4 RBC and HMR CCG have now prepared a working version of the terms of

reference for the ICB (Appendix 1) and these need final agreement before approval by the Chair and Vice-chair of Health and Wellbeing Board, as agreed at the HWB meeting on 31 March 2015.

3.5 In addition, both RBC and HMR CCG need to present their nominees for

membership of the ICB. Appointments then need to be made by HWB and a schedule of meetings agreed at the earliest possible convenience. At this point, the existing Programme Board, will be able to transfer its functions of overseeing the establishment of integrated commissioning arrangements, to the Integrated Commissioning Board

3.6 With respect to wider, integrated commissioning developments, a Cabinet

workshop on integrated commissioning was held on 4 June 2015 to explore local plans and their connection with the Greater Manchester Devolution Agreement. This session was very well attended, and supportive of the direction of travel towards large-scale integrated commissioning. Cabinet agreed to meet with the Governing Body of HMR CCG in a joint session to consider proposals for large-scale integrated commissioning in more detail; this joint session is currently being arranged.

3.7 It is hoped that at, or shortly after, the planned joint meeting of Cabinet and

Governing Body, approval can be given to a trial or shadow period of running for large-scale integrated commissioning arrangements (i.e., in addition to the already-established Better Care Fund), in order to test their effectiveness in advance of formal implementation at a later date. The ICB would then oversee the shadow period of ‘at scale’ integrated commissioning as well as being the decision-maker for the Better Care Fund.

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3.8 Health and Wellbeing Board will want to note that, as a result of careful consideration by key stakeholders, led by the Interim Director of Public Health, it has been agreed in principle between the Council and CCG to include public health and community wellbeing within the planning for large scale integrated commissioning in the borough.

4. Financial mapping 4.1 Both HMR CCG and RBC have undertaken a joint mapping of the potential

financial contributions each organisation might make to integrated commissioning arrangements (i.e., to one or more pooled funds). If the integration model was based on 2014/15 controllable budgets, the following contributions would be made in respect of children and adult’s services,

Children’s services

Partner Indicative initial annual contribution

(2014/15 baseline)

NHS Heywood, Middleton and Rochdale CCG

£25m

Rochdale Borough Council £46m

Adult services

Partner Indicative initial annual contribution

(2014/15 baseline)

NHS Heywood, Middleton and Rochdale CCG

£252m

Rochdale Borough Council £56m

4.2 This mapping exercise is currently being updated with 2015/16 budget

information. Alongside the mapping, financial planning and forecasting is being undertaken in the context of the Locality Plan (see section 7 below); this work includes clarifying the Rochdale Borough financial ‘gap’, i.e., the forecast difference between income to the CCG and Council and their expenditure to meet need without significant service reform and changes to the pattern of demand. Opportunities arising from integrated commissioning are expected to make a significant difference, over time, in closing this gap. The 2015/16 budget information adjusted for the financial gap of each organisation should underpin the financial plan for integrated commissioning.

4.3 The implications arising from this financial mapping exercise are clear: the

scale of the planned integration involves the large majority of current expenditure from the CCG, and from adult’s and children’s services in RBC (not including schools).

5. Programme plan 5.1 The establishment of integrated commissioning arrangements in Rochdale

Borough is complex and involves a large number of people. The arrangements are therefore underpinned by a programme plan, which is currently overseen by a Programme Board (chief officers and finance leads). The programme plan includes attention to a wide range of issues including the following:

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• Workforce (team structures and any hosting arrangements by one or other organisation)

• Organisational development and change

• Policy and procedural working

• Development of an integrated commissioning strategy

• Development of a reporting dashboard

• Creation of a benefits realisation plan

• Development of a consistent approach to procurement 5.2 At present, the Programme Board is confirming the leadership arrangements

for these workstreams within the programme plan, with a view to full delivery of the plan by 31 December 2015 (subject to Cabinet and Governing Body approval, and then to HWB approval) and a ‘go live’ date of 1 April 2016.

6. Better Care Fund 6.1 As noted above, the Better Care Fund (BCF) is, of course, already a formal

integrated commissioning arrangement between HMR CCG and RBC, which reports to HWB. Whilst much smaller in scope than the anticipated range of ‘at scale’ integrated commissioning, the BCF provides a valuable test bed for the CCG and Council to work together as commissioners.

7. Greater Manchester Devolution Agreement 7.1 The importance of the Greater Manchester Devolution Agreement to local

arrangements for integrated commissioning cannot be overstated. Each borough within the city region is expected to have an effective infrastructure to support the devolution of health and social care resources to Greater Manchester, and to ensure the effective delivery of the strategic plan to create a financially and clinically sustainable service for local people.

7.2 To assist in the achievement of alignment between local planning and

strategic planning at city region level, each locality within Greater Manchester has been asked to prepare a Locality Plan, to demonstrate how integrated commissioning will work at local level, and what plans will be taken forward for service redesign. These Locality Plans will form the basis of the city region’s Strategic Plan. The following description of the Plans is based on a briefing from the Greater Manchester health and social care team.

7.3 The proposed framework is for the Strategic Plan to have 4 chapters as

follows:

• Strategic direction – the vision for health and social care in Greater Manchester delivered through a sustainable approach

• Locality and sector plans – the aggregation of Locality Plans (the foundation for the Greater Manchester plan)

• Greater Manchester transformation proposals – new models and strategies to deliver transformation across Greater Manchester

• Financial plan and enablers – how this will be delivered (to include estates, workforce and information management and technology (IM&T) considerations)

7.4 As noted, the Strategic Plan will be built from an aggregation of the 10

Locality (place-based) Plans, incorporating those objectives which are being

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shaped at a sector level along with Greater Manchester-level activities (such as for specialised NHS services).

7.5 In summary, the intention is that the Strategic Plan will:

• Describe the reform of public services in order to improve the health and wellbeing of all residents of Manchester and includes the role of wider public services, social support and self-care, not just the reconfiguration of existing health and social care.

• Focus on the interests and outcomes of patients and people in Greater Manchester, and supports organisations to collaborate to prioritise those interests.

• Be shaped by Greater Manchester commissioners, providers, patients, carers and partners together.

• Have a strong focus on the delivery of new models of care in order to improve outcomes and identify the opportunities that devolution brings.

• Support the rebalancing away from unplanned care towards planned care and support

• Be supported by work on care models and clinical pathways to deliver a plan for clinical as well as financial sustainability.

• Set out the level of ambition that needs to be achieved across Greater Manchester.

7.6 The Locality Plans which will underpin this Strategic Plan are not intended to

be lengthy documents – the strength of the Locality Plans as seen by the Greater Manchester Devolution team will be in the locality-based discussions

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and agreements that take place to develop the working document. A common framework for the structure and scope of the plans is summarised above.

7.7 All stakeholders and partners within the Locality are expected to sign off and

demonstrate Board- or equivalent-level and organisation agreement to, and communication of, the plan.

7.8 The locality planning discussion and resulting document is expected to describe:

• How population health outcomes will be improved.

• What will be required to achieve clinical and financial sustainability.

• How the plan builds on what already exists within localities and it is a true place-based, not organisational plan.

• How it demonstrates a shift in thinking from the delivery of reactive unplanned services to proactive planned services based on agreed pathways.

• How it uses the Greater Manchester Strategic Plan framework as its overarching structure. This will enable aggregation and benchmarking of each Locality Plan into a Greater Manchester plan, but it should remain true to the Locality needs and ambition.

• Financial plan and enabling workstreams. To include agreed financial assumptions and what transition investment funding is required.

• Those productivity and performance metrics which will capture and describe the shifts in activity arising from reform.

7.9 The first draft of the Locality Plan is to be submitted at the end of June 2015,

with the second (final) version in August 2015.

7.10 In August 2015, Greater Manchester will itself need to submit to HM Treasury an investment case that demonstrates how upfront investment can enable the achievement of financial balance within the five year comprehensive spending review (CSR) process. This will be informed by the aggregation of the first cut of Locality Plans. Once the investment case is submitted, the strategic planning process will continue to December 2015, to refine the approach, secure meaningful engagement with residents and local stakeholders and develop the detail of both local and collective reform.

7.11 In Rochdale Borough, development of the Locality Plan is being led by Ian

Mello, Director of Commissioning and Provider Management for the CCG, and by Dianne David, Assistant Director – Adult Services, for the Council. The first draft of the Locality Plan will be presented for information to the July 2015 meeting of the HWB.

8. Financial implications 8.1 The establishment of integrated commissioning arrangements impacts

considerably on the financial planning of both RBC and HMR CCG. As noted in the body of the report, a financial plan is being developed alongside financial analysis underpinning the Locality Plan. Further detailed work will be required throughout the year on the establishment of pooled fund(s) and their risk management, as appropriate.

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9. Legal Implications 9.1 The establishment of integrated commissioning arrangements is expected to be undertaken under s75 of the NHS Act 2006. A new s75 agreement (i.e., separate from the Better Care

Fund agreement) will be required and an initial draft has already been produced.

10. Personnel Implications 10.1 It is the intention of HMR CCG and RBC, subject to engagement, consultation

and formal decision as appropriate, to create integrated commissioning teams to support the delivery of integrated commissioning arrangements. It is not the partners’ intention to transfer the employment of any staff from one partner to another, nor to make any changes to terms and conditions.

11. Corporate priorities 11. The development of integrated commissioning addresses a number of

corporate priorities. Integrated commissioning is expected to offer new opportunities between the Council and the NHS to help build success and prosperity for local people, both through improved health and wellbeing and also through access to training and employment. It is also, of course, specifically focused on the protection of vulnerable people of all ages, whose health and social care needs are expected to be best addressed by the integrated commissioning of services.

12. Risk assessment implications 12.1 There integrated commissioning programme has a risk and issues log which

the Programme Board regularly monitors. A summary of key risks will form part of the proposals in principle for Cabinet and Governing Body to agree to move to a trial or shadow period of integrated commissioning during 2015/16.

13. Equalities Impacts 13.1 Workforce equality impacts assessment There are no workforce equality issues directly arising from this report. An initial equality impact assessment will be completed prior to any decision to enter a shadow or trial integrated commissioning arrangement. 13.2 Equality/Community Impact Assessments There are no equality/community issues arising from this report. An initial equality impact assessment will be completed prior to any decision to enter a shadow or trial integrated commissioning arrangement.

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APPENDIX 1: Integrated Commissioning Board

Terms of reference

WORKING VERSION 1. Purpose The purpose of the Integrated Commissioning Board (ICB) is to commission high quality health, social care and allied1 services for the people of the borough of Rochdale, in order to meet assessed population, community and individual need, within the financial resources of the pooled fund(s) over which the ICB has control. The ICB manages the pooled fund(s) established under section 75 of the NHS Act 2006, whereby prescribed health-related functions of Rochdale Borough Council (RBC) and prescribed functions of NHS Heywood, Middleton and Rochdale Clinical Commissioning Group (HMR CCG) are exercised, and health-related services commissioned. The ICB should maintain a strategic overview and assurance role on behalf of the Health and Wellbeing Board (HWB) to ensure implementation and delivery of the agreed high-level strategies and outcomes, set jointly by HMR CCG and RBC. The ICB will approve the associated strategic plans and work programmes prepared by the operational commissioning programme leads (see scope below). The ICB will approve integrated workforce development strategies and plans. During 2015/16, the ICB will govern the Better Care Fund and will have wider responsibilities over the shadow arrangements for large-scale integrated commissioning for children, adults, and public health and wellbeing. These shadow arrangements are subject to approval by RBC Cabinet and the CCG Governing Body. 2. Scope The scope of the ICB shall include all s75 agreements in place in the borough of Rochdale, covering children and young people, adults, and public health and wellbeing services as required. The ICB shall also include within its scope the Better Care Fund from the outset (1 April 2015). The ICB will govern three operational commissioning programmes which are expected presently to consist of:

• Children and young people’s integrated commissioning

• Adults’ integrated commissioning

• Public health and community wellbeing integrated commissioning Each of these three programmes will have its own management arrangements which will report to the ICB. A member of the ICB will act as the Senior Responsible Owner (SRO) for each of these operational commissioning programmes and each SRO will report on progress and key issues to each meeting of the ICB.

1 ‘Allied services’ in this context means those services within the arrangements for children’s integrated commissioning which are neither health nor social care but include, e.g., the youth service, youth offending service and services to maximise participation and skills.

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Further information about the roles of the operational commissioning programmes is included in the organogram at appendix A. The ICB will not consider or deal with any matters relating to individual patients, users or carers including complaints (which will be managed through existing complaints procedures) or requests for specific treatments or services (which will be managed through existing procedures, e.g., the CCG Individual Funding Request (IFR) process). The ICB will review patient experience data from, and feedback relating to commissioned services and priority areas, including data from complaints and satisfaction surveys, but this data will be presented at ‘aggregate’ rather than individual level. 3. Authority The ICB has been established by NHS Heywood, Middleton and Rochdale Clinical Commissioning Group and Rochdale Borough Council, and thus its authority and decision-making powers derive from these two organisations (the ‘Partners’). The ICB must at all times act within the level of delegated authority as agreed by the Partners. The ICB will be established as a Regulation 10 Committee under Statutory Instrument 2000 617 and in line with the NHS Bodies and Local Authorities Partnership Regulations 2000. 4. Accountability The ICB reports to the HWB and through the HWB to the Cabinet of RBC and the Governing Body of HMR CCG. The HWB will ensure that regular and comprehensive reporting occurs between the HWB and Cabinet and Governing Body covering all key issues arising from the work of the ICB, thereby providing assurance to both Partners that their commissioning responsibilities, as delegated to the ICB, are being fully and effectively discharged and that due process is being followed. The ICB will, in setting its agenda for each meeting, ensure that the draft agenda is approved by both HMR CCG and RBC, through the Chair. The ICB Chair may be called to any meeting of the Cabinet or Governing Body in order to describe the work of the ICB, to provide assurance, answer questions and be held to account. The work of the ICB will be scrutinised by the Health Overview and Scrutiny Committee; ICB chair and other members will be required to attend the Overview and Scrutiny Committee as requested. 5. Approach to commissioning under s75 NHS Act 2006 The integrated commissioning arrangements between the Partners will be based in the first instance on a pooled fund.

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Within the scope of the integrated commissioning arrangements agreed between the Partners, each partner will take the lead on defined aspects of the commissioning programme. The ICB will decide which organisation is the lead commissioner for each scheme or service. It is not expected that the agreed lead commissioner role will involve the delegation of statutory functions from RBC to HMR CCG or vice versa. This approach to lead commissioning will be subject to further consideration as the arrangements evolve and become embedded within the commissioning system. 6. Statutory form The ICB is a sub-committee of the Health and Wellbeing Board and follows the procedures for a Council sub-committee. The ICB will provide regular, detailed report to Cabinet of the Council and the Governing Body of the CCG.

7. Objectives The objectives of the Integrated Commissioning Board are: 7.1 To govern the arrangements for integrated commissioning in the Borough of

Rochdale, providing assurance to HMR CCG and RBC that their statutory responsibilities are being met, their strategic objectives are being addressed and that their combined resources are being used to best effect.

7.2 To be held to account to HMR CCG and RBC for the achievement of the

agreed commissioning strategies and plans. 7.3 To prepare for approval by the Health and Wellbeing Board an integrated

commissioning strategy, setting out the specific goals and outcomes for commissioning in the borough of Rochdale, and the intentions of the Partners to redesign health, social care and allied services in order to meet need, reflect best practice, and make best use of ‘the Rochdale pound’. The integrated commissioning strategy will describe how the outcomes and objectives set out in the s75 Agreements and the high-level strategic goals and outcomes of HMR CCG and RBC are to be achieved.

7.4 To commit the resources within the pooled fund to achieve the objectives of

the integrated commissioning strategy, within the level of delegated resources assigned to it.

7.5 To be responsible for developing a joint financial plan to underpin the overall

commissioning strategy and providing direction in relation to investments and savings to be made by both partners.

7.6 To prepare an annual work-plan and budget for approval by the Health and

Wellbeing Board to implement the agreed integrated commissioning strategy. The work-plan will include the priorities for each operational commissioning programme for that year.

7.7 To oversee the implementation of the integrated commissioning strategy and

the annual work-plan, allocating resources from within the pooled fund(s) and directing the work of commissioners and commissioning groups in order to fulfil the requirements of the strategy

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7.8 To set the standards for, and to monitor and review the outcomes and performance of commissioned services in line with the integrated commissioning strategy and work-plan, identifying areas for improvement and areas of good practice, taking action where outcomes and performance fall short of requirements

7.9 To set the quality and safety standards for, and to monitor and review the

outcomes and performance of commissioned services in line with the integrated commissioning strategy and work-plan, identifying areas for improvement and areas of good practice, taking action where outcomes and performance fall short of requirements

7.10 To ensure that the prescribed health-related functions of RBC and the

prescribed functions of HMR CCG are properly and effectively discharged through the pooled fund, and the integrated commissioning arrangements as appropriate

7.11 To ensure the engagement of stakeholder groups, including users, patients

and carers, providers and community organisations, in the commissioning cycle including where appropriate the co-design of commissioned services, the formulation of the integrated commissioning strategy and the annual work-plan.

7.12 To provide assurance to the Health and Wellbeing Board of the quality and

safety of commissioned services, of the proper and effective use of the resources in the pooled fund(s), and of the achievement of the agreed strategy, work-plan and outcomes.

7.13 To hold to account operational commissioning groups, and the individual

commissioning teams of the Partners, for the performance and delivery of commissioning programmes as required by the integrated commissioning strategy, the annual work-plan, and the s75 Agreements.

7.14 To conduct all business in accord with the terms of the s75 Agreements

including the standards on partnership behaviours and the code of conduct on conflicts of interest

7.15 To have cognisance at all times of the Greater Manchester integrated

commissioning arrangements as they develop in the context of the Greater Manchester Devolution Agreement, and to assure alignment between arrangements in the borough of Rochdale and those of the city region.

7.16 To identify, record, mitigate and manage all risks associated with integrated

commissioning, including the maintenance of a risk register which shall be included on the corporate risk registers of both HMR CCG and RBC.

7.17 To review regular performance and financial monitoring reports and ensure, if

required, appropriate actions are taken to ensure annual delivery of expected performance targets and approved schemes within permitted budget for the financial year.

7.18 During 2015/16, to oversee the development and establishment of integrated

commissioning arrangements in the borough, ensuring that the requirements of both HMR CCG and RBC are met, that they are based on best practice,

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and strategic alignment to the intent of the Greater Manchester Devolution Agreement is maintained.

8. Delegated powers The ICB shall have agreed levels of delegation from the Governing Body of HMR CCG and Leader of RBC to allocate and spend the resources of the pooled fund(s) and to implement the agreed integrated commissioning strategy. For the avoidance of doubt, neither Partner is permitted by law, nor intends to, delegate its accountabilities for its statutory functions to the other party or to the ICB. 9. Membership The membership of the ICB will be fourteen members in total, as follows

• Three members of the Governing Body of HMR CCG, consisting of 1 lay member and 2 clinical leads

• Clinical Chair, HMR CCG

• Chief Officer, HMR CCG

• Director of Commissioning and Provider Management, HMR CCG

• Chief Finance Officer, HMR CCG

• Three Cabinet members of RBC, namely the Lead Member for Children’s Services, the Lead Member for Adults Services and the Lead Member (or their deputy) for Health and Wellbeing

• Director of Adult Services, RBC

• Director of Children’s Services, RBC

• Director of Public Health, RBC

• Director of Finance, RBC In the event of a vote, each of these members shall have one vote; the chair shall not have a casting vote. All decisions shall be made by a simple majority of each Partner; at each meeting, neither partner shall be permitted to outvote the other simply by means of having a greater number of attendees. Where attendance is not equal at any meeting, those members present from one Partner who exceed the number of members present from the other shall be deemed non-voting for the purposes of the meeting. These non-voting members will be selected on the basis of their place in alphabetical order of attendees’ given (sur-) names. Nominated substitutes are permitted to attend in the absence of the Board member where notification is provided in line with the Council’s procedure. Non-voting advisors, or other (non-voting) co-optees, may be invited to join the Board as required. 10. Quorum A quorum is reached when there are at least 4 members from each partner present (i.e., a balanced majority of 8 out 14 members). As stated in clause 8 above, where

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attendance is not equal at any meeting, those members present from one Partner who exceed the number of members present from the other shall be deemed non-voting for the purposes of the meeting. 11. Chairing and administration The chair will rotate on annual basis between a clinical or lay member of the Governing Body of HMR CCG and a Cabinet member of RBC. There will always be an annually appointed vice-chair from the organisation which that year is not providing the chair. The administration of the Board will be the responsibility of the Partners, to be agreed between them. 12. Meeting in public The ICB will meet in public when exercising its substantive powers, namely over the Better Care Fund during 2015/16. It may, by resolution, exclude the public from a meeting (whether during the whole or part of the proceedings) whenever not to do so would be prejudicial to the public interest by reason of the confidential nature of the business to be transacted or for other special reasons stated in the resolution and arising from the nature of that business or of the proceedings. As such meetings may consist of part 1 (open to the public) and part 2 (closed). It respect of its role in overseeing the establishment of integrated commissioning arrangements during the shadow period of operation (during 2015/16), the ICB will meet in private. 13. Sub-groups The ICB will establish such operational groups and other sub-groups, both as standing groups and task-and-finish groups, as it requires. In particular, the ICB will establish the sub-groups necessary to manage the operational commissioning programmes for children, adults, and public health and wellbeing. The ICB will, in establishing operational groups and sub-groups be cognisant of the fact that its primary purpose is governance, as opposed to management, and that it therefore should be assured that appropriately robust and effective management arrangements for the delivery of commissioning programmes within the permitted budget are in place. 14. Frequency and location of meetings The ICB will normally meet monthly at Number One Riverside, but may meet more frequently if required. 15. Declarations of interest Members of the ICB will follow the Council’s code of conduct. Any declarations of interest will be made by members and/or attendees at the commencement of each

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meeting, and will be recorded in the meeting minutes. Members with a conflict of interest will not take part in decision-making on relevant issues, and may be asked temporarily to leave the meeting. Further guidance on the management of conflicts of interest will be found in the conflicts of interest guidance which will include the statutory guidance issued to the CCG in December 2014 [Gateway reference 0272]. 16. Review These terms of reference will be reviewed on an annual basis by the ICB, and by the Health and Wellbeing Board and the Governing Body of HMR CCG. 17. Approvals These terms of reference were approved as follows: Governing Body, NHS Heywood, Middleton and Rochdale CCG on [date] Cabinet, Rochdale Borough Council on [date] Health and Wellbeing Board [date] CCOG/Programme Board/LM/IM/JM/7 April 2015 this version 5 June 2015

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