Kent & Medway ICB: DSF Loss, Long NHS Waits and Conflicts of Interest Concerns — What the Board Papers and Spending Data Reveal

The Kent and Medway Integrated Care Board (ICB) went into its November 2025 board cycle carrying two burdens at once: worsening financial weather, and a governance question that never quite goes away — who sits at the table when decisions are made about where NHS money flows.

The agenda pack is not short on virtue-signals about openness and culture. It includes a Freedom to Speak Up mid-year update, “Change-25” transition reporting, committee updates on inequalities and outcomes, and a declared aim to build a workforce where colleagues feel “valued”, where diversity is “celebrated”, and where the organisation is “fair and inclusive”. 

But the same papers also describe a system that is already off-track financially, trying to close a very large gap with programmes that are still being designed, and with a growing reliance on external consultancy to make the numbers work.

And then there is the ugly part: Deficit Support Funding (DSF).

What DSF is — and why losing it matters

DSF is, in plain terms, conditional top-up funding used by NHS England to support systems and organisations running deficits if they deliver agreed recovery plans. It is not a “free grant”; it is a lever — money released (or withheld) depending on delivery against plan. The DSF is lost because NHS trusts and integrated care boards fail to meet their agreed financial plans.

The November 2025 finance report in the board pack states bluntly that the system will lose deficit support funding for Q3 and potentially Q4 of up to £49m, and that this impact is not included in the risk-adjusted forecast. 

It is understood that Kent & Medway ICB has lost its Deficit Support Funding (DSF) for Q3 & Q4, triggering a £24.5m deterioration in the ICB’s revenue position, and that all acute trusts in Kent have lost their DSF as well — a system-wide withdrawal of support that turns an already difficult financial plan into something closer to a cliff edge.

The bad news first: the money

The finance paper (Month 7, 2025/26) sets out a picture that is technically precise — and politically grim:

• A year-to-date system deficit of £48m. 

• Financial risk of £144m sitting against the plan. 

• Efficiency savings of £141.8m delivered, but still £5.4m behind plan, with a remaining “unidentified” element (i.e., savings not yet fully pinned down) referenced in the report. 

• A risk-adjusted forecast that, even on the “base” position, is described as an adverse outturn of £203m, with the “stretch” position still adverse.

• A warning that many of the mitigations are not fully developed, and that some may impact quality and performance.

• A reminder — the kind that reads like a letter before action — that the ICB has a legal duty to break even, and that failure to deliver the plan would likely trigger regulatory action.

That is the financial context in which every other item in the pack should be read.

The “good”: transparency and at least some uncomfortable honesty

There is a case to be made that the pack is doing one important thing right: it records risks in black and white. It does not pretend the system is fine. It acknowledges pressures across urgent and emergency care, elective recovery, cancer performance, mental health, and primary care.

It also includes governance infrastructure that—on paper—should help accountability: a published declarations register, committee reporting lines, and public meeting minutes.

And crucially for anyone following the money, the ICB continues to publish “expenditure over £25k” files on its website — the basic building blocks needed for external scrutiny.

The “bad”: consultants, closed doors, and a narrow public window

The finance report explicitly references consultancy support: PA Consulting is cited as supporting Medway Foundation Trust on its financial improvement plan, and EY and Akeso are referenced as engaged in support work.

On its own, consultancy is not scandal. The scandal is when consultancy becomes the structural substitute for delivery capacity — particularly in a system also discussing workforce transition and savings that risk affecting services.

Transparency, too, has its own awkward footnotes. The public agenda timetable gives five minutes for public questions pertaining to the agenda.And the meeting minutes reference a “notice on meeting etiquette” being flagged to members of the public.

More pointedly, the September 2025 minutes record that contract awards were approved in Part 2 meetings (closed session) and then “presented” in Part 1. This may be lawful and sometimes necessary — but it is also the point at which public governance risks becoming retrospective theatre.

The “ugly”: DSF withdrawal meets a governance problem the system already knows it has

If the financial story is harsh, the governance story is sensitive.

The pack states that no new declarations of interest were made at the September 2025 board meeting and no conflicts were declared. That is a formal statement — but the register itself contains a long list of declared roles in organisations that could intersect with commissioning, digital health, private provision, or local authority trading.

Some examples from the November 2025 register:

• Cedi Frederick (Chair): owner of Article Consulting Ltd; owner of Consiliaris Digital (with shareholding >5%); and a director of Sage Green Homes Ltd, Sage Shared Ownership Ltd, and Sage Places Ltd, among other roles. Pictured below left

• Angela McNab (NED): non-executive director at Dimensions, trustee of Discovery (Dimensions group), and a shareholder in Rapidhealth.

• Elizabeth Butler (NED): non-executive director, Cora Healthcare Ltd (no shares). She fails to declare her directorship in KEB Welfare Ltd and CABRIS INVESTMENTS LTD.

• Dr Jonathan Bryant (GP partner member): GP partner at New Lyminge Surgery and White House Surgery; clinical director at Invicta Health CIC; shareholder (<5%) in Channel Health Alliance; plus further primary care and programme roles.

None of this is automatically wrongdoing. Declaring interests is the correct step; and each of them do this.

The harder question is what happens next: whether recusal is consistent, whether procurement routes are robust, and whether the register is precise enough for outsiders to follow the chain.

The spending cross-check: did any declared-interest organisations receive money?

Using the ICB’s published expenditure-over-£25k spreadsheets (September 2024 to November 2025), the payment trail shows significant sums going to organisations that are directly named in board members’ declarations — particularly those linked to Dr Jonathan Bryant:

• Invicta Health CIC: ~£1.63m

• Channel Health Alliance Ltd: ~£1.26m (including a month with reversing entries netting to zero)

• White House Surgery (The): ~£1.86m

• New Lyminge Surgery: ~£1.12m

These entities are explicitly declared in the board register in relation to Dr Bryant.

Again: GP provider payments can be legitimate and routine. The point is that the overlap is real, material in value, and structurally baked into how an ICB governs primary care. In a DSF-strained environment, where every commissioning choice is politically combustible, that overlap needs more than a generic assurance that interests are “managed”.

 Elizabeth Butler declares a non-executive role at  CORA HEALTHCARE LIMITED (Company No. 11272077).

• • But fails to declare her interests in, CORA HEALTH MSK LTD (Company No. 02337692) which was previously CONNECT HEALTH LIMITED until 30 June 2025, or her her directorship in CABRIS INVESTMENTS or KEB WELFARE LTD. This is of great concern, given the The Seven Principles of Public Life. We make it clear that none of these companies appear in ICB spend data between Sept 24 and Nov 25. 

The consequence is not a simple accusation; it is a governance red flag. In the real world of scrutiny — journalists, auditors, campaigners, and the public — that precision matters.

The Sonik warning from 2022 — now re-reading in the shadow of DSF loss

The November 2025 agenda does not exist in a vacuum. In August 2022, Save Our NHS in Kent (SONiK) published a “Crisis Report” by Carly Jeffrey titled “Conflicts of Interest and the Kent & Medway NHS new Integrated Care Board — A Recipe for Privatisation” 

That report raised concerns that are strikingly relevant to today’s cross-check:

• It argued that provider representatives — including from private providers — sitting on decision-making boards creates an inherent conflicts-risk.

• It highlighted Liz Butler as a non-executive director at Connect Health Ltd, described as a private provider holding NHS contracts, and criticised the limited public accountability of private providers receiving NHS funds.

• It recorded that a freedom of information request found £1.79m paid by NHS Kent and Medway to Connect Health Group Ltd between April 2020 and June 2022. 

• It noted that conflict mitigations (such as leaving the room or not voting) would be determined by the chair, and it raised questions about the chair’s own business interests. 

SONiK’s framing is campaigning, not neutral accountancy. But the factual spine of the concern — that board members can have declared external roles and that money flows through the system in ways that overlap with those roles — remains relevant, and is now sharpened by the DSF context.

In other words: when DSF is being withdrawn and the system faces an adverse outturn of the scale described in the November finance report, the tolerance for even the appearance of conflicted governance drops sharply.

What this leaves the public with

The November 2025 board pack shows an ICB trying to present control, grip, and values — while simultaneously describing a financial position that looks closer to structural failure than a temporary wobble.

It is not enough, in that context, to publish a register and say interests are “managed.” The public interest lies in the detail:

• whether declared interests are mapped to the correct Companies House entities (especially where brand names and reorganisations blur the trail);

• whether recusals are recorded consistently and specifically when related matters arise; 

• and whether key spending decisions are visible prospectively, rather than appearing first as faits accomplis following Part 2 approvals.

• That all directors declare all their interest openly and honestly matters especially given those in public office must abide by the The Seven Principles of Public Life, known as the Nolan Principles.

In a system where DSF has been lost — and where it is understood the same applies across Kent’s acute trusts — the stakes are no longer about tidy governance. They are about whether the public can trust that rationing decisions, redesigns, and commissioning choices are being made solely in the patient interest, under the pressure of a plan that is already breaking.

The inclusion of a person or entity in this blog post is not intended to suggest or imply that they have engaged in illegal or improper conduct. 

The Shepway Vox Team

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