Category Archives: Government

The Dash Review: the future of the CQC

Steve Brine @BrineHealth is a Strategic Adviser at GK Strategy. He was a Health Minister (2017-2019), Government Whip, and is a former chair of the Health & Social Care Select Committee. Here, he reflects on the future regulatory landscape for adult social care.

Context is everything when it comes to social care. Well, almost everything because you can’t forget the politics. On one hand, despite a grand pledge in the Labour Party manifesto to “undertake a programme of reform to create a National Care Service”, we have nothing happening at all.

On the other we have the Dash Review (and now Dash 2.0), the Ten Year Plan, the next phase of the spending review and of course, the Budget which brought a further £600m to prop up the service.

Taken on face value, a national care service is of course a very (very) big deal. This could literally mean the nationalisation of the entire social care sector – akin to how local voluntary hospitals were brought under national public ownership in the 1940s – or it could mean, well, whatever you want it to. Perhaps that’s the point. The truth is, right now, we’re none the wiser and nor I suspect are Ministers.

More immediate, not least for investors and those looking for a little certainty in the sector, is the major NHS Ten Year Plan consultation launched last week. As I understand it, everything is in scope for this programme of work led by Paul Corrigan and Sally Warren with the exception of, wait for it, adult social care. Meanwhile, the Dilnot reforms have been kicked down the road (again) which means the spending cap will now not be introduced next year as planned. Andrew Dilnot is reportedly furious and the great immovable object of NHS reform seems further away than ever before.

What we do know is Penny Dash is in the ascendancy with this government. Shortly after Lord Darzi produced his 163-page diagnosis of the NHS, Dash published her full report into the operational effectiveness of CQC. The Dash review found significant failings in the organisation which it said ’has lost credibility in the health and social care sectors’ and led Wes Streeting to say it was no longer fit for purpose. It found that the CQC’s ability to identify poor performance and support quality improvement has deteriorated and says this has undermined the health and social care sector’s capacity and capability to improve care.

Alongside Dash, a parallel review was led by Prof Sir Mike Richards (former chief inspector of hospitals) looking at CQC’s controversial single assessment framework. Sir Mike (one of the best officials I worked with while a Minister) recommends a fundamental reset of the organisation and a return to the previous organisational structure, with at least three chief inspectors leading sector-based inspection teams at all levels.

And as if that weren’t enough, Dash gets a 2.0 moment as this month we learn the way patient safety is regulated and monitored is to be completely overhauled in England. With the swoosh of a Minister’s pen; the CQC, the National Guardian’s Office, Healthwatch England and local Healthwatch services, the Health Services Safety Investigations Body, the Patient Safety Commissioner and NHS Resolution are all set to be reviewed.

Whatever the future of Henrietta Hughes (the Patient Safety Commissioner) or Helen Vernon (who leads NHS Resolution) one name here is to stay is Julian Hartley. Currently Chief Executive of NHS Providers he will take over as the head of the CQC in December. Julian is a smart appointment. A nice guy (but don’t be fooled) who exudes calm and is fiercely organised. He will find an organisation on its knees and I am sure a massive rebuild on his hands.

It is clear that Penny Dash has listened to the voices of care providers, resulting in a clear set of recommendations so Julian Hartley will benefit from that oven-ready piece of work. Equally, I suspect the Richards review findings will not meet too much resistance. Expect a re-set to a standardised approach to inspections and for line management of such to come back under the auspices of the Chief Inspector of Hospitals. I wouldn’t be surprised to see a completely re-born and re-branded CQC that focuses on safety as well as efficiency, outcomes and use of resources – you can be sure Rachel Reeves will make that a red line.

Ministers will, in my experience, find that the desire to do the Ten Year Plan minus adult social care doesn’t survive contact with political reality. And so between now and the Spring, and indeed the final throes of the comprehensive spending review to come, furious negotiations between DHSC, Angela Rayner (who is responsible for council funding) and HMT are the order of the day.

And when all is said and done, we will find out whether the work of change has great substance or everything looks and feels very familiar.

GK Strategy Analysis of Labour’s 2024 Budget

GK Strategy – Budget 2024 Update

Labour’s new era for agriculture: Can political stability drive agri-tech innovation?

GK Senior Adviser James Allan analyses the government’s agriculture policy plans and the opportunities that could arise for investors.

With the Labour government now in power, some may wonder if the food, farming and agriculture sectors are about to see a major shift – a shift from being an important constituent of the then Conservative administration of 14 years to lower down the political list of priorities within Labour’s “mission led” government.

The Autumn Budget on 30 October will partly address this concern and end the speculation about potential changes to agriculture property relief and Defra’s agricultural budget. But with a Party of a different political hue now occupying the corridors of power, it’s worth considering whether Labour’s pro-growth messaging of “political stability” to attract private sector investment extends to the food, farming and agriculture (FFA) sectors, and if so, to what extent.

Why Labour must harvest more than just political stability

To attract private investment, ‘political stability’ alone is not sufficient – it needs to be backed up by policy substance and public investment, and with long-term strategic thinking. From aquaculture to viticulture, solar farms to biodiversity, food pricing and standards to foods high in fat, salt and sugar, there are many agendas and issues at play. These will all be playing out against a political backdrop with a renewed sense of momentum, a government with a greater willingness to intervene in the name of public health, an entire mission focused on decarbonisation, and a tight fiscal environment impacting the potential for significant public investment.

The first 100 days for the new government have proved that governing isn’t easy. Political pinch points and missteps aside, a common thread in the criticisms levelled against Labour ministers has been the absence of a defining vision for the sector to provide the framework for policy thinking and development; not least for food security which is set to become one of the defining political issues of the parliament. Without this overarching vision for the sector, the ability for businesses to plan their own investment and growth strategies becomes much more difficult and limits the ability of government to ‘crowd in’ private capital to drive growth.

The sowing of early seeds positive for UK investors

There are a few positive and recent developments of note. First, the Farming Minister, Daniel Zeichner, has confirmed the government’s intention to introduce secondary legislation which will bring to reality the regulatory regime of the Genetic Technology (Precision Breeding) Act 2023.[1] This will help to simplify the authorisation process for bringing new products to market from 1o years to an estimated 12 months.[2] Investors should note the government’s familiar caveat of “as soon as parliamentary time allows” which means the introduction of secondary legislation is unlikely to be imminent and will compete with an already packed legislative calendar. Speeding up routes to market will be welcomed by investors backing early-stage or growth-stage companies involved in gene editing, crop efficiency technologies, or those innovating in climate-resistant crop varieties. The streamlined regulatory environment lowers barriers, creating the potential for significant returns more quickly. Zeichner has also confirmed 43,000 Seasonal Worker visas for the horticulture sector and 2,000 for the poultry sector for 2025. Accompanied by a few additional measures to simplify free-range labelling requirements, this signals that the Defra ministerial team is actively listening to the sector and willing to flex policy to meet operational challenges and remove barriers to growth.[3]

Secondly, the government has secured access to the US market for British beetroot farmers, boosting export opportunities and attributed to the efforts of DEFRA’s agri-food attaché in the US.[4] This establishes an interesting precedent for securing market access outside of more formal and comprehensive free trade agreements, and creates attractive investment opportunities in companies that produce export-ready, high-quality British agricultural goods. Crucially, produce by produce access deals averts the political tightrope of negotiating comprehensive trade deals, not least one with the US which has long been the envy of previous Conservative Prime Ministers. For investors and argi-businesses on the lookout for export opportunities, engaging with DEFRA’s eleven attaches located in British embassies and consulates in Canada, Mexico, Brazil, Kenya, The Gulf, India, Japan, China, Thailand and Vietnam will be important to replicate this success.

Thirdly, there is recognition in government of the long and fraught dissatisfaction among farmers concerning the future viability of the agricultural sector.[5] The Labour ministerial team perceives a lack of confidence among farmers as the rationale for needing to optimise Environmental Land Management schemes as part of a wider new deal for farmers. The precise details of this new deal have yet to be clarified but the government has signalled a focus on:

Trade deals undercutting low welfare and low standards
Maximising public sector purchasing power to back British produce
A land-use framework to balance nature recovery and long-term food security

A latter focus on food security will be important for investors seeking opportunities which align with Labour’s aim to make the UK more self-reliant in the food and energy sectors, but especially where technological innovation contributes to more efficient and resilient farming processes and produce. Defending their record in government and playing in safe political territory, this was a focus of a recent opposition day debate in Parliament where several Conservative MPs made the case for greater public investment in new farming technologies to safeguard the nation’s food supply.[6] However, as noted by DEFRA Secretary, Steve Reed, the government’s ability to do so is up for consideration in the upcoming Budget and next year’s Spending Review and therefore competes with other public spending priorities.

A wet start for the farming sector

This year’s harvest of the five key crops – wheat, winter and spring barley, oats and oilseed rape – saw a decrease of 15% compared to the 2023 harvest with an estimated loss of £600m in revenue for English farmers due to considerable wet weather.[7] The impact has extended beyond these core crops with a south Devonshire winemaker reporting a 70% decrease in expected volumes compared to 2023 and another winemaker noting heightened disease pressures due to constant rain. For the British viticulture industry, the wet weather year of 2024 follows a boom in capital investment and overseas wine producers buying into the UK as a hedge against climate change. Rural and farming communities might not be this government’s traditional supporter base but neglecting the sector – with its sub-sector growth gems like viticulture – risks undermining long-term food security and economic growth not just farmers but the broader economy and consumers alike.

[1] DEFRA, New legislation to support precision breeding and boost Britain’s food security (Sept-23 link)

[2] DEFRA, Impact Assessment – Impact Assessment – Genetic Technology (Precision Breeding) Bill (Mar-22 link)

[3] DEFRA, Government provides certainty to horticulture and poultry businesses (Oct-24 link)

[4] DEFRA, British beetroot growers to put down roots in US market (Sept-24 link)

[5] DEFRA, Government to restore stability for farmers as confidence amongst sector low (Aug-24 link)

[6] House of Commons, Opposition day debate on farming and food security (Oct-24 link)

[7] Energy & Climate Intelligence Unit, England has second worst harvest on record with fears mounting for 2025 (Oct-24 link)

GK Strategy Briefing – October 2024 Budget

GK Strategy Pre-Budget Briefing: GK Associate Hugo Tuckett takes a look at what we’re expecting to see in the government’s first Budget on Wednesday 30 October

Political Context

The government will hold its first budget on Wednesday 30 October. Ministers will want to use it as an opportunity to reset the political agenda given the turbulence of recent weeks which has seen the Prime Minister lose his Chief of Staff Sue Gray and pay back more than £6,000 in gifts after a row over donations.

Labour’s election manifesto was light on tax and spend measures. The Party identified four revenue raising levers to utilise to fund its reforms to public services. These are: further reforming non-dom tax loopholes, applying VAT and business rates to independent schools, ending the carried interest tax loophole and increasing stamp duty on purchases of residential property by non-UK residents. The Party estimated this would raise just over £7 billion in additional revenue for the exchequer.¹ The manifesto also included a commitment not to increase national insurance, the basic, higher or additional rates of income tax, or VAT. Given these represent approximately two-thirds of tax revenue, this forces the Chancellor to focus on maximising returns from a series of smaller pots to fund Labour’s spending priorities.

In July 2024, the Treasury completed an audit of public spending which identified a £22 billion black hole in the public finances. The government said this represents an in-year overspend and does not constitute an estimate of how much additional funding might be allocated to departments moving forward or how much additional borrowing may be required.² The Chancellor will therefore have to pursue a series of tax rises to close this gap in the public finances and support additional investment in departments moving forward.

Potential Measures

The following list sets out a series of measures that GK has assessed are likely to be included in the upcoming budget:

Employer pension contributions: The pushback the Chancellor received following her decision to end winter fuel payments for pensioners not in receipt of pension credit (which cut the relatively small amount of c.£1.5 billion from the government’s annual welfare bill) reduces the likelihood of her pursuing a large number of small tax rises to balance the books. Instead, the government is likely to target 3-5 measures which collectively bridge the gap in the public finances. GK’s assessment is that the Chancellor is likely to reform the NICs treatment of employer pension contributions by levying employer NICs on employer pension contributions. If levied at the full rate (13.8%), this would raise around £17 billion per year. This covers approximately three-quarters of the £22 billion figure identified in the Treasury’s audit of public spending and would end what the Institute for Fiscal Studies (IFS) describes as “the generous NICs treatment of employer pension contributions… [which are] opaque and poorly targeted.”³

Inheritance tax: The government is likely to close several loopholes in the inheritance tax system. Politically, Labour is not as sensitive about reforming inheritance tax as previous Conservative administrations. This provides the Chancellor with a freer hand to make changes without encountering pressure from her Party’s backbenchers. Reforms to the inheritance tax system are likely to include ending reliefs for business assets (including those held in the AIM market), agricultural property, and gifts to charities. This is estimated to raise c.£2.4 billion in revenue.⁴

Capital gains tax: We expect the Chancellor Rachel Reeves to increase rates of capital gains tax. This is, however, likely to constitute a shift of only a few percentage points given concerns about maintaining the UK’s international competitiveness. Unlike the Conservatives, Labour did not commit to freezing capital gains during the election campaign. As the Party has ruled out increases to income tax, national insurance and VAT, it has few levers to pull to raise revenue to fund its spending commitments. Capital gains tax is an attractive revenue raiser for the government given it is paid by a small number of individuals each year (who broadly sit outside Labour’s electoral base) and it fits with its wider commitment not to raise taxes on “working people”.⁵

Carried interest: Reforms to the tax treatment of carried interest which would see rates align with the higher rate of income tax (45%) are unlikely to be contained in the upcoming budget. Instead, we expect a compromise agreement to be reached whereby rates are lifted, albeit not significantly, to fulfil the Party’s manifesto commitment to “close this loophole”.⁶ Although it was one of Labour’s few tax raising measures it committed to pre-election, internal Treasury analysis has now revealed that the policy could have a “net cost to the exchequer”. This is because wealthy individuals could choose to leave the UK rather than pay the money and deter investment. Treasury civil servants estimate the rise could cost as much as £350 million per annum after five years.⁷

Debt measure: The Chancellor is likely to reform the UK’s debt measure to support public investment in infrastructure projects. Speaking at Labour Party Conference in October 2024, Rachel Reeves said that “it’s time the Treasury moved on from just counting the costs of investment in our economy to recognising the benefits too.” This suggests that the Treasury’s fiscal rules will be altered to allow the government to offset “assets”, against the wider national debt, thereby freeing up more money for investment. This is likely to amount to c.£50 billion worth of additional headroom.⁸ Importantly, the move will not allow Reeves to increase day to day spending, as Labour has said this must be met entirely from annual tax receipts.

¹Labour Party, Change, 13.06.24
²HM Treasury, Fixing the foundations: public spending audit 2024-24, 02.08.24
³IFS, Raising revenue from reforms to pensions taxation, 11.09.24
⁴IFS, Raising revenue from closing inheritance tax loopholes, 18.04.24
⁵Financial Times, IFS urges Labour Party to make ‘serious reforms’ to capital gains tax, 06.10.24
⁶Labour Party, Change, 13.06.24
⁷The Times, Labour poised for U-turn over tax plans for investment gains, 04.10.24
⁸The Times, Rachel Reeves hopes for £50bn windfall with fiscal rules rejig, 26.09.24

Wales says BOGOF to unhealthy food & drink

GK Associate Director Thea Southwell Reeves analyses the Welsh government’s progress on regulating unhealthy food.

This week, the Welsh government took an important step towards tightening the regulatory environment around high fat, sugar and salt (HFSS) food. The measures include prohibiting retailers from offering promotions such as buy-one-get-one-free and three-for-two offers on unhealthy foods; a ban on free drink refills in restaurants; and preventing retailers from placing HFSS food in certain locations in stores. Worth noting, these regulations are also set to apply online so website entry pages, shopping basket and payment pages will all need to comply.

The consultation is open until midnight on 23 September and is seeking views from industry on the draft regulations and their proposed enforcement approach. If the proposals are approved by the Senedd, the legislation is likely to come into force in 2025.

These proposed changes form part of a broad range of approaches, both voluntary and regulatory, that the Welsh government is said to be considering to encourage the food and retail sector to produce, promote, and ultimately sell, healthier food and drink.

The increased regulation of HFSS foods has been on the table for years and is also being explored by Holyrood and Westminster. A consultation on Scotland’s ambitious HFSS regulations closed in May and the King’s Speech included measures to restrict the advertising of junk food to children, along with the sale of high-caffeine energy drinks to children. The cost-of-living crisis has derailed anything more ambitious in Westminster… for now.

Industry has, for the most part, been critical of moves to tighten legislation, arguing that they disproportionately impact the small food and drink producers and make selling food complex and costly. However, for businesses that are nimble, the rules represent an opportunity to gain advantage over non-compliant brands or big brands that are slow to adapt. In a similar vein, producers who can emphasise a healthier product range in marketing and brand positioning are set to attract consumers who are looking to reduce their HFSS intake.

GK Strategy is a political advisory firm. We help investors, business leaders and organisations to engage with policymakers and advise on the political, policy and regulatory aspects of M&A processes.

To discuss what the Welsh government’s consultation may mean for you and how you can engage with policy debates in the year ahead, please reach out to Thea@gkstrategy.com.

The GK Post-Election Breakfast Event

GK Strategy Adviser Rebecca McMahon reviews the GK Post-Election Breakfast Event.

The coming weeks and months will see the new Labour government pressing ahead with its agenda for government, and getting to grips with a number of difficult challenges facing the UK, from sluggish growth, to growing NHS waiting lists, to precarious local authority finances.

GK Strategy was delighted to host a panel discussion this week looking at how the government will tackle some of these issues, and how it will prioritise its time and resources to deliver on its ambitious policy pledges. GK was joined by former Minister and Health Select Committee Chair, Steve Brine, and Head of Research at Labour Together, Christabel Cooper, who shared their insights into the government’s approach, and some of the inevitable obstacles it will face in the coming months.

Both panelists agreed that while the list of public policy challenges inherited by Starmer and his team is by no means a short one, Labour ministers will now be deciding on areas where urgent action is most needed.

Reforming the UK’s planning system was identified as one of the priority areas for Starmer’s new administration. Our two panelists noted that the new Government’s ambition in this area has already been illustrated by repealing the de facto ban on onshore wind, re-introducing mandatory housing targets, and pledging to update the National Planning Policy Framework via consultation by the end of the Party’s first month in power.

As a policy area with implications for multiple sectors – including housebuilding, the green economy and major infrastructure– planning reform to unlock private investment will be at the core of the new Labour Government’s agenda. As Chancellor of the Exchequer Rachel Reeves set out in her first speech following her appointment, its ultimate success will rely on “unlocking private investment that we so desperately need”.

Healthcare and the future of the NHS was another policy area which featured prominently. Steve Brine pointed out that under current spending plans, funding for the health service is projected to rise at a lower rate than during the austerity years. Meanwhile, the NHS Workforce Plan continues to be underfunded and the outcome of the Health Secretary’s talks with the junior doctors uncertain. He noted that while the Government will soon have to make difficult spending decisions, there would be an emphasis on creating an investor-friendly NHS to support Labour’s ambitions to “crowd in” private investment to improve efficiency and health outcomes.

There was a consensus that Labour’s perspective on the use of the private sector in supporting the delivery of public services is a pragmatic one. Labour’s ‘wide but shallow’ majority – achieving 64% of parliamentary seats on roughly 34% of the vote – means that the Party will need to reassure voters that it is making headway on its policy programme. Our panelists agreed that working with the private sector will be key to successfully demonstrating this.

Please do get in touch via rebecca.mcmahon@gkstrategy.com if you are interested in attending future events or would like to set up a call to discuss the year ahead in politics.