How to Prepare your ICS for New NHSE Green Plan Guidance

In October 2020, the Greener NHS unveiled its strategy titled ‘Delivering a Net Zero National Health Service.’ The report emphasized the dire consequences of unchecked climate change on healthcare, linking environmental degradation to an increase in major diseases such as heart conditions, asthma, and cancer. It outlined a roadmap for the NHS to achieve net zero carbon emissions by 2040 for the emissions within its direct control, and by 2045 for those emissions it can indirectly influence. NHS England has pledged to reach net-zero carbon emissions by 2040 for its Carbon Footprint and by 2045 for its Carbon Footprint Plus, aiming for an 80% reduction by 2032 and 2039 respectively, using 1990 as the baseline year.

The 2021/22 NHS Standard Contract mandated that trusts develop a Green Plan outlining their methods for emission reduction, aligning with national trajectories. These Green Plans are intended to articulate an NHS Trust’s commitment to sustainability, resilience, and carbon emission reduction, consistent with national objectives. Subsequently, the Greener NHS provided guidance for trusts on creating a Green Plan [1]. Updated in June 2021, this guidance is valid until the conclusion of the current financial year, which is January 2025 for trusts. All trusts had to publish a Green Plan by 14^th January 2022.

Current Green Plan Themes

• Workforce and system leadership.
• Sustainable models of care.
• Digital transformation.
• Travel and transport.
• Estates and facilities.
• Medicines.
• Supply chain and procurement.
• Food and nutrition.
• Adaptation.

The Green Plan strategies were proposed to be implemented over a three-year period. Consequently, Trusts that established a 3–4-year strategy will find that their Green Plans have either expired or are nearing the conclusion of their effective period, with the end of this financial year, 24/25, marking the official completion of the cycle.

While NHS trust providers are responsible for achieving carbon reduction to net-zero, Integrated Care Boards (ICBs) and Integrated Care Systems (ICSs) play a crucial role in accelerating sustainability progress through strategic and supportive actions. As strategic commissioners, ICSs can prioritise and organise sustainability initiatives with suppliers and partners.

The Health and Care Act 2022 outlines the legal duties of ICSs regarding net-zero, emphasising strategic decisions on statutory emission reductions. The objectives of ICBs include:

ICS Objectives

• Supporting carbon reduction initiatives.
• Considering the goals and needs of health system partners
• Reducing health inequalities.
• Enabling economic growth.

The Standard Contract 2024/25, the Care Quality Commission (CQC), and the NHS provider licence also require ICSs to develop and maintain Green Plans. NHS England is now requesting that ICSs refresh and re-publish their Green Plans, with new guidance expected in autumn 2024/25 to support NHS organisations. These Green Plans should comply with ICSs’ legal obligations and detail how the ICS will oversee the implementation of Trust-level Green Plans.

NHS England has the authority to impose sanctions if ICBs or ICSs fail to comply with their legal duties, including their oversight and supportive roles in sustainability. Therefore, it is crucial to develop a robust Green Plan at the ICS level.

ICS Green Plan Specific Requirements

In Green Plans, ICSs could include the following information:

• Changes made to the commissioning and reconfiguration of services related to carbon reduction and sustainability, clearly outlining responsibilities within the healthcare system and the methods for implementation.
• Coverage of the Green Plan from each Trust/provider.
• Consideration of processes for cross-organisational decision-making regarding carbon reduction and sustainability.

This cross-organisational approach is key. Green plans between partners shouldn’t be conflicting. An ICS GP should be able to identify opportunities between Trusts in the system to achieve goals in the most financially, socially, and environmentally sustainable way possible.

Many of the requirements upon Trust level Green Plans are applicable to ICS GPs too:

Trust / ICS Green Plan Requirement Synergies

• Ensure the Plan reflects the latest guidance and evidence, incorporates learnings to date, and remains aligned with national net-zero ambitions.
• Engage with local stakeholders to increase buy-in.
• Ideally, set the Plan over a 3-year timeframe.
• Include SMART actions for each priority area to maximise the likelihood of successful implementation.
• Prioritise interventions that improve patient care and population health, reduce health inequalities, and promote the efficient use of resources.

New Green Plans for ICSs are expected to be required from early next year, with guidance anticipated to be released this autumn. However, this timeline may extend beyond 2024. Consequently, there may only be a few months available to refresh Green Plans, making it crucial for your ICS to begin preparations as soon as possible.

WRM have significant experience of developing NHS Green Plans, having supported over 25 Sustainable Development Management Plans (SDMPs) and Green Plans over the last decade. In 2022, we supported the following ICSs with the development of their Green Plans.

Joined Up Care Derbyshire (JUCD) ICS

JUCD desired a Green Plan which provided the ICS with oversight and accountability over the achievement of the NHS’s Carbon Footprint and Carbon Footprint Plus targets, including the ability to monitor progress against these trajectories and support the delivery of wider healthcare objectives. WRM undertook a thorough review and analysis of the carbon footprints and sustainability interventions from healthcare providers across the system. We then led a workshop to identify mutually beneficial economic, social and environmental opportunities between system partners. The project resulted in a sustainability strategy and action plan underpinned by the system’s collective ambition to reduce health inequalities. Plans for action included sharing electric vehicle infrastructure, rolling out best clinical practice, and collectively investigating its carbon footprint to ensure a standardised accounting approach.

Cambridgeshire and Peterborough ICS

The ICS desired a Green Plan which provided it with a framework for managing and tracking its sustainability progress, with an emphasis on partner engagement and strategic alignment with wider healthcare objectives. WRM undertook a comprehensive review and analysis of sustainability interventions committed to by healthcare providers across the system before facilitating a series of one-to-one and group workshops with Trust-level stakeholders to gather information on and identify mutual opportunities between the system partners. The project resulted in a Green Plan framed by the system’s strategic priorities of sustainable procurement, circular economy activities, and adaptation to extreme weather events.

Looking for more information? Sign up to our FREE ICS Green Plan Refresh Webinar here.