Comment

Representation ID: 26463

Received: 22/07/2024

Respondent: NHS Property Services

Draft Policy HWB4 focuses on the provision or improvement of community facilities and services to
meet local needs. NHSPS supports the provision of sufficient, quality community facilities but does
not consider the proposed policy approach to be effective in its current form. Where healthcare
facilities are included within the Local’s Plan definition of community facilities, policies aimed at
preventing the loss or change of use of community facilities and assets can potentially have a harmful
impact on the NHS’s ability to ensure the delivery of essential facilities and services for the
community.
The NHS requires flexibility with regards to the use of its estate to deliver its core objective of
enabling excellent patient care and support key healthcare strategies such as the NHS Long Term
Plan. In particular, the disposal of sites and properties which are redundant or no longer suitable for
healthcare for best value (open market value) is a critical component in helping to fund new or
improved services within a local area. Requiring NHS disposal sites to explore the potential for
alternative community uses and/or to retain a substantial proportion of community facility provision
adds unjustified delay to vital reinvestment in facilities and services for the community.
All NHS land disposals must follow a rigorous process to ensure that levels of healthcare service
provision in the locality of disposals are maintained or enhanced, and proceeds from land sales are
re-invested in the provision of healthcare services locally and nationally. The decision about whether
a property is surplus to NHS requirements is made by local health commissioners and NHS England.

Sites can only be disposed of once the operational health requirement has ceased. This does not
mean that the healthcare services are no longer needed in the area, rather it means that there are
alternative provisions that are being invested in to modernise services.