How can commissioning support anti-racism? Unpicking the NHS Strategic Commissioning Framework

This April, the NHS ostensibly implemented its new Strategic Commissioning Framework. Announced in November 2025, it’s a document that’s unlikely to attract the attention of many outside the healthcare commissioning sphere. Look at the detail, however, and it’s clear the Department of Health and Social Care hopes this document will be quietly revolutionary for the way the service is run. 

Indeed, the framework is one of the more tangible mechanisms through which it hopes to operationalise its 10-year health plan and turn its now familiar three shifts – towards prevention, digital, and community – into a reality. 

Under the new framework, Integrated Care Boards (ICBs) will be expected to follow a continuous, structured cycle: understand local needs, develop 5-year health improvement plans, and then commission services to deliver them. One of the key differences from the status quo is that ICBs will be commissioning entire healthcare pathways, rather than individual piecemeal services. 

The overall aim is not only to achieve better financial control and oversight but, in theory at least, to break down organisational silos and put communities back at the centre of health and care planning. 

What could this mean for race equity? 

On paper, this new framework has the potential to transform the healthcare system’s approach to race equity. Its emphasis on population health management and data-driven decision making creates real opportunities for ICBs to systematically identify and respond to ethnic disparities across access, experience, and outcome. 

If we allow ourselves to dream bigger, the freedom granted by the framework could allow commissioners to meaningfully embed communities in designing the services they use; to fund more culturally adapted and community-led care; and to reframe prevention as a genuinely representative response to the self-identified needs of these communities. 

The greater focus on partnership with local government and VCSE organisations may also deliver the long-unrealised promise of ICBs: to work holistically across health, social care, housing, education, justice, and other sectors to loosen the grip of structural racism on our public services. 

Challenges ahead 

While welcoming the increase in autonomy and flexibility afforded by the new framework, and the potential empowerment of communities, there are challenges that commissioners will need to navigate if this framework is to deliver for racially marginalised communities. 

While the framework consistently references reducing “health inequalities”, it does not explicitly centre race equity, placing the onus on systems to ensure that ethnic health disparities are meaningfully addressed within this broader agenda. There is a real risk that this leads to a focus on geographical disparity, which, as we have argued elsewhere, often means focusing on where inequalities occur and failing to consider why they occur. Only a concerted focus on the causes of structural race inequity will ever meaningfully move the dial for these communities. 

The increasing reliance on data and analytics is also a double-edged sword. We know that the collection of ethnicity information from patients is inconsistent at best, meaning that while the framework offers the potential for a more granular understanding of population need, longstanding issues with ethnicity data quality and completeness risk services replicating existing inequity. Furthermore, commissioning responsibilities are set to be increasingly devolved, distributing the onus for delivery across systems and providers. In this scenario, maintaining clear accountability for race equity outcomes may become more challenging. 

How can commissioning support anti-racism? 

For those commissioners with a genuine interest in race equity in health, the task is clear. If the move towards whole-pathway, population-centred care is to work, it must start where it hopes to end: with the empowerment of communities themselves. Commissioners must take the broadest possible approach to gathering data and evidence about their populations – looking not only at the crude numbers but engaging in direct community listening to understand and tackle the often yawning gaps in access and outcomes experienced by racially marginalised communities. This community listening process must be one element of a holistic accountability mechanism that requires systems to demonstrate that they’re responding to the needs of local populations.  

Anti-racist strategic commissioning will mean building race into assumptions from the very start of the 5-year planning cycles; embedding accountability for race equity into internal governance structures; and taking serious steps to improve the quality of ethnicity data. 

Above all, it will require newly empowered commissioners to think carefully about what they are prioritising. We don’t tend to think of commissioning as a caring profession, but in this new world, it is vital that commissioners act with the utmost care in supporting some of the most vulnerable communities in society.