I'm indebted to my friend Dr Phil Hammond, and to a correspondent of Phil's, for pointing out that in contravention of its own rules, the Department of Health has made several significant revisions to its PCT clustering guidance without amending the guidance's 'information page'.

Updated drafts of guidance should always carry an acknowledgment to that effect on the information page.

You can download the original, unrevised PCT clustering guidance document here, and the latest iteration here. The DH's changes are listed below. (We reviewed the document last week.)

On one level, it's hard to be too surprised by this going on in policyland.

SOS Lansley's appointment of NHS Supreme Soviet Chair Sir David Nicholson as CE-designate of the NHS Commissioning Board without so much as a hint of due process was jaw-dropping. It was also far from the only example of the 'tap-on-the-shoulder' school of personnel that has become commonplace.

On another, it's worrying for several reasons.

The redisorganisation of the NHS, with PCTs clustering into abolition-reinvention as pre-2006 health authorities, is putting a lot of people out of work who have given the NHS many years of service.

The Coalition Government's politics have already shown these people ample contempt, in introducing a policy which was absolutely hidden from view and despite the Coalition Agreement's promising to do quite the opposite.

The civil service, however, should treat its own with the civility implicit in its own name - and also with competence.

By rushing out an unfinished guidance document, and then revising it without acknowledging that they have had to do so (on legal advice, the amendments seem to suggest), the DH staff involved who have tried to cover up their mistake have compounded the fault.

An equally clear message from this is that DH internal governance processes are allowing important policy documents to be published before they are adequately finished. The revisions, listed below, relate to important governance and pay issues. They should have been 'war-gamed', or at least road-tested, with front-line staff - but obviously weren't.

This does not inspire confidence, so early in such a huge transition.

More to the point, it suggests that in future, the DH may simply revise other guidance documents without acknowledging that they are doing so.

The amendments to the document
P. 14 (of new, revised document)
Para 3.3 – additional paragraph under ‘Comply with statute’

“PCT Care Trust and PCT Care Trust Plus boards are subject to additional statutory requirements which must continue to be met as part of a cluster arrangement. A PCT Care Trust or PCT Care Trust Plus board must continue to contain at least one nonexecutive nominated from each relevant local authority. In addition, the single executive team within a cluster where there is one or more Care Trust must contain an individual who has experience of the health-related functions of the local authority or authorities covered by the Care Trust.”

…

P. 15 (of new. revised document)
Deletion of line, revision of original text and additional lines under ‘3.5 Implementation principles’, in ‘Clear decision-making’ paragraph

Line deleted - “However, where mutual agreement cannot be reached the relevant SHA will make the final decision” – in original text, this appears after first line.

Additional, new line added - “The relevant Appointments Commissioner will need to agree the NED Board structure if changes to statutory appointments are envisaged.”

…

P. 16 (of new revised document)
Para 4.4 Added clause to second sentence – text underlined in the following – “The role of the non-executives that do not meet on the cluster board would need to be established and could include liaison with local stakeholders or supporting the development of GP consortia”.

…

P. 17 (of new revised document)
Under ‘Potential advantages’, clause added to last line of third bullet point, underlined in the following – “However, once the cluster is operational, there may be a higher workload for the executive team in servicing the PCT boards depending upon the meeting cycle agreed”.

…

P. 21 (of new revised document)
Added phrase to opening line of para 5.3:

Original line: “5.3 Discussions should take place with those office holders that do not have a role within the adopted governance model to identify whether they can make any other alternative contribution locally or whether their resignation will be required.”

Replacement line (addition underlined): “5.3 If the model adopted makes this necessary, discussions should take place with those office holders that do not have a continuing role within the adopted governance model to identify whether they can make any other alternative contribution locally or whether their resignation will be required.”

…

p. 21 (of new, revised document)
New final line added to para 5.5 – “Schemes of Delegation should also describe how the statutory PCT Board will hold the Cluster Board to account for effective delivery of its delegated functions.”

…

p. 22 (of new, revised document)
Entire new paragraph added: “Remuneration 5.6 The remuneration for PCT Chairs is based on the weighted population covered by the PCT. Where a single Chair is appointed to all constituent PCT boards and undertakes chairing responsibilities across the cluster, the remuneration calculation will be based on the combined population size covered by the constituent PCTs. This approach is in line with pay arrangements for chief executives undertaking shared responsibilities across organisations as set out in the VSM Pay Framework. Non-executive directors will be remunerated at their current level.”