The Faculty of Dental Surgery (FDS) at the Royal College of Surgeons of Edinburgh has submitted its official response to the Scottish Government’s consultation on NHS Delivery, which proposes the creation of a single national organisation to drive transformation across health and social care.
Focused on the planned merger of NHS Education for Scotland and NHS National Services Scotland, the response was developed by the Dental Council in collaboration with the College’s Policy and Public Affairs Team. This aligns with similar actions taken by other professional bodies, including the RCN.
Section A: Establishing the new organisation to deliver national transformation: the case for change and immediate priorities
Key transformation tasks are being doing across various NHS entities in Scotland and the Scottish Government are looking to streamline this to our body doing this all- NHS Delivery.
1. Do you agree that creating a new national organisation to drive forward digital transformation and system change – beginning with the consolidation of NES and NSS into one organisation – is the right approach to deliver the ambitions set out in Scotland’s Population Health Framework and Service Renewal Framework?
The Royal College of Surgeons of Edinburgh (RCSEd) and its Faculty of Dental Surgery (FDS) agrees that creating a new organisation, consolidating the two organisations would come with advantages. The FDS believes that this would bring together certain work streams to avoid duplication. For example, through digital transformation, with a ‘once for Scotland’ approach. We fear, however, that innovation may come at the expense of stability in education.
However, we have significant concerns around the removal of a central body for training and education. Combining these two organisations may be detrimental to the education of staff and has the potential to be diluted down. Naturally, service pressures and service delivery will always be the new priority and under any further strain education and training will be the first things to be sacrificed as we will see these budgets being diverted to service recovery. Any merger or reconfiguration must not disrupt the close linkages between training, education and clinical performance. In order for this to work successfully, training and education would have to be ringfenced to ensure that the intended functions of NES are upheld in a new NHS Delivery model. Patient safety should always be the key focus of the NHS and the only way to uphold and ensure this is through education and training standards.
The proposal document includes very little about delivery of postgraduate medical education and training. NES has significant regulatory responsibilities, and it is concerning that there is minimal reference to any of these statutory duties, as well as the importance of education and training to ensure patient safety and a well-trained medical workforce. There needs to be much more emphasis on how the core education functions of NES will be retained and what this will look like in any new NHS Delivery body.
2. A. Do you agree with the proposed strategic objectives for the new organisation (driving innovation, delivering Once for Scotland services, and streamlining structures)?
Agree / Disagree / Don’t know
Please explain your response.
FDS supports these broad aims in principle. A unified approach to service improvement and innovation has potential benefits, provided that such initiatives are driven by clinical evidence and informed by frontline experience. However, they should not be limited exclusively to these. Education must be a priority in this merger, and NHS Delivery must make explicit reference to this in its strategic objectives. Strict maintenance of education and training, standards setting and valid and reliable assessment of training progress must also be at the heart of the new organisation.
The FDS stress that innovation must not come at the expense of stability in education, workforce development, or service delivery. The success of any approach will depend on strong engagement with clinicians, educators, and NHS Boards to ensure relevance and practicality.
The proposal document includes very little about delivery of postgraduate medical education and training. NES has significant regulatory responsibilities and it’s concerning that there is minimal reference to any of these statutory duties, as well as the importance of education & training to ensure patient safety and a well-trained medical workforce. There needs to be much more emphasis on how the core education functions of NES will be retained and what this will look like in any new NHS Delivery body.
2. B. Should the organisation consider additional strategic objectives?
Yes / No / Don’t know
If yes, please specify.
The FDS recommends that one additional strategic objective should be the explicit integration of clinical standards and workforce development within the national improvement agenda.
There is a clear overlap between raising clinical performance, advancing education and training, and embedding a culture of continuous improvement. Ensuring these elements are strategically aligned will maximise the impact of the new organisation.
3. Are there services or functions currently delivered by other Health Boards (in addition to what NES and NSS already do) that should be delivered only by NHS Delivery to improve consistency and reduce duplication? This includes consideration of capabilities that are perhaps fragmented across multiple bodies, where a clear lead organisation should be identified.
Free text response
The FDS considers that workforce data, digital learning platforms, and improvement programmes could benefit from greater national coordination to reduce duplication.
However, consolidation should not centralise decision-making to the extent that local responsiveness or specialist input is weakened. Any transfer of functions should follow robust consultation with professional bodies and service users.
In addition, Royal Colleges play a critical role in setting national professional standards. They are crucial stakeholders and work closely with NES to provide externality for quality assurance of training.
4. What areas of national delivery could be improved by NHS Delivery to make services more efficient or better joined-up?
Please tick all that apply:
• Redesigning how services could be planned or improved
• Making better use of data and digital tools
• Improving supply chains or procurement
• Supporting shared back-office services like HR or finance
• Strengthening workforce development and training
• Other (please indicate below)
Free text response
Uniformity of administration and digital processes throughout Scotland. It should make it easier to access patient records from different health boards.
5. Are there any existing services, programmes, or functions currently delivered by NES or NSS that you believe could be stopped, scaled back, or redesigned (or handed over to another Health Board) to better align with current priorities and system-wide impact?
Examples may include legacy services, low-impact initiatives, or areas of duplication with other bodies.
Free text response
Reforms should prioritise strengthening alignment and removing administrative duplication rather than reducing or fragmenting successful existing programmes.
6. Do you agree that NHS Delivery should lead the development of national digital capabilities (e.g. Electronic Health Records, digital inclusion, data architecture) for Scotland’s healthcare system?
Yes / No / Don’t know
Optional: Please explain your response.
The Faculty supports NHS Delivery assuming responsibility for digital transformation and national digital architecture, provided that this work is clinically led and aligned with service needs.
Digital tools have significant potential to improve patient care, training and system efficiency. However, digital transformation must be supported by investment in staff skills, infrastructure and data governance.
7. Should NHS Delivery be tasked with improving data sharing, data access and interoperability across health and social care?
Yes / No / Don’t know
Optional: Please explain your response.
Improved data sharing and interoperability are critical to supporting sage, efficient and coordinated care. FDS supports NHS Delivery leading this work, with a clear emphasis on data quality, ethical governance and clinical utility. Better access to timely and accurate data will also enhance training evaluation and research capabilities across Scotland.
8. Do you believe NHS Delivery should be tasked with the lead national support role in innovation development & adoption, service redesign, change management, improvement, and commissioning of health services?
Yes / Partially / No / Don’t know
Optional: Please explain your response. This may include areas where fragmented delivery or unclear accountability currently limits impact.
The Faculty supports NHS Delivery providing national coordination and support for innovation and service improvement, but clinical leadership must remain rooted in NHS Boards.
Section B: Longer Term Opportunities and Future Evolution
This section looks at how NHS Delivery would be used over time.
It will not be fully formed from day one, but will instead be a phased approach, firstly beginning with the consolidation of NES and NSS, and gradually expanding its remit and capabilities.
9. As NHS Delivery evolves in the longer term, what additional capabilities, functions or bodies should be considered for integration into a single national delivery capability that supports the aspirations of the Service Renewal Framework?
Free text response
Any expansion should only occur once the core merger of NES and NSS has been completed, stabilised and evaluated. FDS would strongly advise against early consolidation of education that could disrupt established pathways. It is imperative that an NHS Delivery model protects and supports the statutory functions of NES and that there is a clear arm of any new organisation that is dedicated exclusively to training and education.
10. What principles should guide decisions about future expansion of NHS Delivery’s remit and structure?
Free text response
Preservation of clinical and educational standards, transparency and accountability, Clear and demonstratable benefit to patient outcomes and workforce sustainability.
Data must be obtained on the performance pre and post change in key education and training milestones. Evidence must be provided to ensure that quality and standards are maintained. Additionally, it is essential that feedback from front-line staff is sought.
11. What mechanisms should be put in place to review and adapt NHS Delivery’s remit and performance post-launch?
Free text response
Suggestions may include:
Formal review after 12–24 months
Stakeholder engagement and feedback loops
To sufficiently assess NHS Delivery there must be a review done annually. As part of this review, it is imperative that there are feedback routes and sessions for clinicians to give their views on the merger. As part of these feedback opportunities, it is particularly important that the views of both trainers and trainees are sought. These groups are at the greatest risk of the proposed merger, with no substantial prioritisation of the training and education made in the proposals.