ICB Mergers and NHS England Abolition: CHC Impact 2026

CT
CareAdvocate Team·Article·2026-05-11·14 min read
Reviewed by legal professionals and social care professionals
NHS reform timeline showing the 1 April 2026 ICB mergers and the April 2027 NHS England abolition, highlighting their effect on CHC claims

Key Facts

  • 12 ICBs abolished, 6 new ICBs created on 1 April 2026 (NHS England, 2026)
  • NHS England fully abolished by April 2027 — slipped from the original October 2026 target (Institute for Government, 2026)
  • 50% combined NHS England + DHSC workforce reduction target (BMA, 2025)
  • 24% of CHC referrals already breach the 28-day decision deadline (NHS Digital, Q3 2025/26)
  • 18 months — the longest CHC backlog reported in some ICB areas (Compass CHC, 2026)
  • The "primary health need" legal test is unchanged since the National Framework, July 2022

On 1 April 2026, twelve NHS Integrated Care Boards (ICBs) ceased to exist. Six new ICBs took their place under the Integrated Care Boards (Establishment and Abolition) Order 2026, and a thirteenth ICB had its boundaries redrawn (NHS England, 2026). NHS England, the body that handles CHC Independent Reviews at appeal stage 2, is itself being absorbed into the Department of Health and Social Care by April 2027. For families with a live CHC case, the ICB merger is the more immediate practical concern.

If your relative is mid-Checklist, mid-Decision Support Tool (DST), or mid-appeal, you may not yet know which ICB now holds their file. A generic transition letter may have arrived in the post. Your named CHC nurse may have changed. The 28-day clock keeps ticking regardless.

TL;DR: Twelve ICBs were abolished and six new ICBs took their place on 1 April 2026, with NHS England itself due to be abolished by April 2027. Your right to NHS Continuing Healthcare has not changed — the "primary health need" test set by the National Framework (July 2022) still binds every successor ICB. But the people, paperwork and contact details around your case probably have. This guide explains what changed, what didn't, and the four written actions to take this week.

Which ICBs Were Abolished — and Which New Ones Replaced Them on 1 April 2026?

Twelve ICBs were abolished and six new ICBs were established on 1 April 2026 under the Integrated Care Boards (Establishment and Abolition) Order 2026 (NHS England, 2026). A thirteenth ICB — NHS Hampshire and Isle of Wight — had its boundary widened to absorb Hampshire wards from the abolished Frimley ICB. A second wave of mergers is planned for April 2027.

The six new ICBs and the ICBs they replaced are:

  • NHS Norfolk and Suffolk — replaces Norfolk and Waveney ICB and Suffolk and North East Essex ICB
  • NHS Essex — replaces Mid and South Essex ICB, incorporating West Essex and North East Essex
  • NHS Central East — replaces Hertfordshire and West Essex ICB, Bedfordshire, Luton and Milton Keynes ICB, and Cambridgeshire and Peterborough ICB
  • NHS Thames Valley — replaces Buckinghamshire, Oxfordshire and Berkshire West ICB and Frimley ICB (with East Berkshire incorporated)
  • NHS Surrey and Sussex — replaces Surrey Heartlands ICB and Sussex ICB, incorporating Surrey wards from Frimley
  • NHS North Central + North West London ICB — replaces North Central London ICB and North West London ICB

If your relative's care is commissioned by one of the abolished ICBs, the successor ICB now carries every legal duty the predecessor held — including any in-progress Checklist, DST, review or appeal. To find your new ICB by postcode, use our Find Your ICB tool.

A key practical consequence: case-handler email addresses, named nurse-assessors, and ICB postal addresses have all changed. Letters sent to the old ICB after 1 April 2026 may not have been forwarded automatically. If you wrote to the old ICB in the weeks before the merger and have not had a substantive reply, it is worth resending to the successor ICB this week.

Interactive · Find your new ICB

Which ICB handled your case before 1 April 2026?

Pick the abolished ICB and we’ll show you which new ICB now holds the file — plus the four written actions to take this week.

NHS England Is Being Abolished Too — What's the Timeline?

NHS England, which handles all CHC Independent Reviews at appeal stage 2, is being abolished and absorbed into the Department of Health and Social Care. The completion target was originally October 2026, but has now slipped to April 2027 (Institute for Government, 2026). The combined NHS England + DHSC workforce is being cut by 50% as part of the same reform (BMA, 2025).

ICBs themselves are also being instructed to cut their running budgets by 50%, with estimated redundancy costs of £1–1.2bn across the NHS (NHS Confederation, 2026). A separate strand of reform is moving specialised commissioning functions to seven new ICB hubs.

1 Apr 2026Phase 1ICB mergers12 → 6Late 2026PHSO becomesPublic ServiceOmbudsmanApr 2027NHS Englandabsorbed intoDHSCApr 2027Phase 2ICB mergersbeginNHS reform milestones for CHC familiesSources: NHS England (2026); Institute for Government (2026); PHSO (2026)

For families, the timeline matters because each milestone introduces operational disruption that can stall a CHC case. The April 2026 ICB mergers reset paperwork and contacts. The late-2026 ombudsman rebrand affects appeal letters. The April 2027 NHS England transfer affects in-flight Independent Reviews. None of these changes the underlying law — but each one creates an opportunity for a case to drift if no one is chasing it.

Has the Legal Test for CHC Eligibility Changed?

No. The "primary health need" test set out in the National Framework for NHS Continuing Healthcare (July 2022) still applies in full to every ICB in England. The mergers do not give a new ICB any extra power to refuse, withdraw, or reduce CHC funding (National Framework, 2022).

The Standing Rules — which are legally binding — require every ICB to "have regard to" the National Framework when deciding eligibility, identifying the responsible commissioner, and resolving disputes. The 2022 revision of the Framework made no substantive change to the primary health need test itself; it primarily incorporated the Health and Care Act 2022 changes that transferred CHC commissioning from the old Clinical Commissioning Groups to ICBs.

In other words, the legal architecture beneath your relative's CHC case is exactly what it was on 31 March 2026. What has changed is the people applying it. That is a meaningful operational risk during the transition period — but it is not a change in your rights.

What Happens to My Live Checklist, DST or Appeal?

Your case transfers automatically to the successor ICB. The 28-day Checklist clock does not reset. Existing decisions remain binding on the new ICB. But 24% of CHC referrals already miss the 28-day deadline (NHS Digital, Q3 2025/26), and backlogs of up to 18 months have been reported in some areas (Compass CHC, 2026), so families need to chase progress actively rather than assume continuity.

CHC 28-day decision target — Q3 2025/2676%on time76% — decided within 28 days24% — breach the deadlineSource: NHS Digital, NHS Continuing Healthcare statistics, Q3 2025/26

What this looks like in practice depends on which stage your case is at:

Pre-Checklist (no referral submitted yet). Submit it directly to the new successor ICB. Reference the original ICB you would have submitted to so the receipt is logged correctly. Use our free CHC eligibility screener first if you are not yet sure whether to refer.

Mid-DST or awaiting MDT. Write to the successor ICB to confirm the multi-disciplinary team meeting will go ahead and to request a named contact. Ask for written confirmation that the 28-day clock is still running from the original referral date.

In appeal at NHS England. Independent Review functions transfer to the Department of Health and Social Care by April 2027, but in-flight appeals continue under the existing process. The right to a stage-2 review and a stage-3 referral to the ombudsman is preserved. See our guide to how to appeal a CHC decision for each stage.

The risk during a merger is not that the law changes. It is that paperwork drifts, deadlines slip, and chase letters end up at the wrong address. That is a procedural problem, and procedural problems are easier to fix than substantive ones — provided you spot them early.

Why the Merger Could Actually Help Borderline Cases

Reorganisation creates an evidence opportunity. The new ICBs inherit thousands of files without inheriting the institutional context that produced each decision. In cases we've reviewed at CareAdvocate, the same care-need profile that was scored "moderate" by an outgoing ICB has been scored "severe" by a clinically fresh pair of eyes — and 2026 is a uniquely strong year for that kind of resubmission, particularly for relatives refused CHC in 2024 or 2025 by an ICB that has now ceased to exist.

The Nuffield Trust documented an almost five-fold variation in CHC eligibility rates across England, ranging from 3.4% to 57.9% of those assessed (Nuffield Trust, September 2025). Spending per recipient ranged from £32,558 in the lowest area to £133,201 in the highest. That variation cannot be explained by population health; it reflects inconsistent application of a single national framework. A successor ICB has no obligation to defend its predecessor's pattern of refusals.

A practical reframing: if a CHC decision was financially rather than clinically driven, the merger window is the moment to test it. The new ICB may be more open to a fresh look than the predecessor that issued the original refusal. Our CHC postcode lottery analysis explains the variation in more detail, and our ICB cost-cutting analysis covers the financial pressures behind it.

Four Practical Steps to Take This Week

If your relative has an active CHC case — at any stage — here are the four written actions that protect continuity through the merger.

Step 1 — Identify your new ICB

Use our Find Your ICB tool to enter your relative's postcode and confirm which of the six new ICBs (or thirteenth boundary-changed ICB) is now responsible. Make a note of the ICB's CHC team email address and postal address.

Step 2 — Request a named CHC nurse-assessor

Write a short letter to the new ICB asking for the name and contact details of the CHC nurse-assessor now responsible for your relative's case. State the date of the original Checklist or DST referral. ICBs are obliged to provide a named contact for active cases.

Step 3 — Get the 28-day clock confirmed in writing

In the same letter, request written confirmation that the 28-day Checklist decision deadline is running from the original referral date — not from the date of the ICB merger. If the ICB cannot meet 28 days, ask in writing what interim NHS funding arrangements apply.

Step 4 — Confirm any existing CHC decision is still in force

If your relative was already in receipt of CHC before 1 April 2026, request written confirmation from the new ICB that the existing decision remains in force pending the next scheduled review. Do not wait for the ICB to contact you. A short, factual letter creates a paper trail that protects against any administrative drift.

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What About Appeals — Does the NHS England Abolition Stop Them?

No. The right to challenge a CHC decision survives NHS England's abolition. Appeal functions are transferring to the Department of Health and Social Care by April 2027, with the Parliamentary and Health Service Ombudsman (rebranding to Public Service Ombudsman in late 2026) retaining the final-stage role.

In-flight Independent Reviews continue under the existing process. The legal grounds for appeal — incorrect application of the National Framework, procedural unfairness, factual errors in the DST — are unchanged. NHS England's letterhead may change. Your appeal does not.

If your relative is currently at stage 2 (Independent Review) or stage 3 (ombudsman), the most useful thing you can do is keep the file moving: respond promptly to any correspondence, submit any further evidence you hold, and ask in writing how the abolition transition will affect your case. A well-documented file is portable. A vague or outdated file is the one that gets lost in a transfer.

For a step-by-step walkthrough of each appeal stage, see our guide to appealing a CHC decision.


Citation Capsule — ICB mergers (1 April 2026): Twelve NHS Integrated Care Boards were abolished and six new ICBs took their place on 1 April 2026, with NHS Hampshire and Isle of Wight also receiving a boundary change. The mergers were enacted under the Integrated Care Boards (Establishment and Abolition) Order 2026, with a second wave of mergers planned for April 2027 (NHS England, 2026).

Citation Capsule — NHS England abolition: NHS England is being abolished and its functions absorbed into the Department of Health and Social Care, with the completion target slipping from October 2026 to April 2027. The combined NHSE and DHSC workforce is being cut by 50%, and ICB running budgets are being cut by the same proportion (Institute for Government, 2026; BMA, 2025).

Citation Capsule — CHC legal test: The "primary health need" test set out in the National Framework for NHS Continuing Healthcare (July 2022) is unchanged. ICB mergers do not give a successor ICB any new power to refuse, withdraw, or reduce CHC funding without a clinically justified reassessment under the same legal standard (National Framework, 2022).


The April 2026 ICB mergers and the April 2027 NHS England abolition are the largest structural change to NHS commissioning in a decade. For families with a live CHC case, the immediate risk is not that your rights have changed — they have not — but that paperwork, deadlines and contacts drift during the transition. The four-step action layer in this guide is how you stop that.

If your relative is on CHC, has just been refused it, or is awaiting a decision, this is the right week to put a short factual letter in writing to your new ICB. For a structured starting point, use our free CHC eligibility screener or read the full guide to NHS Continuing Healthcare funding.

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CT

CareAdvocate Team

Editorial Team

Our content is written with AI assistance and reviewed by a legal and regulatory professional, a senior social worker, and experienced local government social care professionals. Individual reviewers are not publicly named while still employed.

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