Health Policy InsightEditor’s blog Monday 26 July 2010: 6 impossible things pre-breakfast - abolishing FT prudential borrowing limit unmodelled
“Why, sometimes I've believed as many as six impossible things before breakfast”.
The White Queen, Through The Looking Glass, Lewis Carroll
I expect an organisation whose very name announces an intention of independence to live up to its promise. It's not idealism; just the Ronseal Test - it should do what it says on the tin.
That is what I expect of Monitor - the independent regulator of NHS foundation trusts. To give them their full title.
Which was why I was a bit surprised to read that the Coalition government's proposals on provider regulation suggest "removing statutory borrowing limits that are not imposed on voluntary or private providers".
So I emailed Monitor's communications team to this effect:
"The consultation document explicitly mentions the abolition of the statutory borrowing limit for NHS foundation trusts. Could you please confirm that this is what Monitor refers to as the prudential borrowing limit?
"And could you let me have a copy of any economic modelling or other analysis that Monitor has done, contributed to, commissioned or seen from the DH over the impact this could have on FTs' financial viability?
"Given the Coalition government's emphasis on data and financial transparency, clearly there would be no reason for such documents not to be put into the public domain, and they would clearly not be 'commercial in confidence'".
Reasonably promptly, I got the following reply:
"I can confirm that statutory borrowing limit is what Monitor refers to as the prudential borrowing limit. We have not carried out any modelling or other analysis. These are currently Government proposals out for consultation. If you have any more questions on this I suggest you contact the DG (sic) press office".
Which is much less than I think one could reasonably deem a full answer to my question.
Hence my FOI request to the DH this evening reads:
"Under the 2000 FOI Act, I wish to request release of the following:
"Any consultation, advice, economic modelling or other related analysis that the DH, ministers or their special advisers (salaried or seconded) have commissioned, seen or participated in regarding today's consultation proposals to remove the prudential borrowing limit that applies to NHS foundation trusts (FTs).
"Please note from the email exchange below that independent FT regulator Monitor specifically deny having carried out any modelling or other analysis. This is clearly an extremely limited answer or denial to the question I asked.".
The Lansley is a vamp
I have come to understand, if not accept, that current policy is not merely extempore, but practically vamping.
Improvisation has its charms. They are limited.
I would not feel like much of an independent regulator if I had known this proposal were to be included in a consultation and I had not done any economic modelling or analysis of what it might mean.
In such circumstances, I would feel like even less of a policymaker.