Framework agreement between the Department of Health and Social Care and the Human Tissue Authority: 2026 to 2029
Published 26 October 2026
Applies to England, Northern Ireland and Wales
Introduction
This framework agreement has been agreed between the Department of Health and Social Care (DHSC) and the Human Tissue Authority (HTA) in accordance with HM Treasury’s (HMT) managing public money (MPM) handbook (as updated from time to time) and has been approved by HMT.
The framework agreement sets out:
- the broad governance framework within which HTA and DHSC operate
- HTA’s core responsibilities
- the governance and accountability framework that applies between the roles of DHSC and HTA
- how the day-to-day relationship works in practice, including in relation to governance and financial matters
The document does not convey any legal powers or responsibilities, but all parties agree to operate within its terms.
References to HTA include all its subsidiaries and joint ventures that are classified to the public sector and central government for national accounts purposes. If HTA establishes a subsidiary or joint venture, there shall be a document setting out the arrangements between it and HTA, agreed with DHSC.
Copies of the document and any subsequent amendments have been placed in the libraries of both Houses of Parliament and made available to members of the public on HTA’s website and on GOV.UK.
This framework agreement should be reviewed and updated at least every 3 years unless there are exceptional reasons that render this inappropriate that have been agreed with HMT and the principal accounting officer (PAO) of DHSC. The latest date for review and updating of this document is October 2029.
Objectives
DHSC and HTA share the common objective of maintaining public and professional confidence by ensuring that the removal, storage and use of human tissue and organs are undertaken safely, ethically and with proper consent. To achieve this HTA and DHSC will work together in recognition of each other’s roles and areas of expertise, providing an effective environment for HTA to achieve its objectives through the promotion of partnership and trust and ensuring that HTA also supports the strategic aims and objectives of DHSC and wider government as a whole.
Classification
HTA has been classified as a central government organisation by the Office for National Statistics (ONS) and the HMT Classifications team.
It has been administratively classified by the Cabinet Office as a non-departmental public body (NDPB).
Purposes, powers and duties, and aims
Purposes
HTA is an independent regulator established under the Human Tissue Act 2004 (the HT Act). Its remit and general functions are set out in sections 14 and 15 of, and schedule 2 to, that Act.
Powers and duties
HTA’s powers and duties are set out in the HT Act, in particular in part 2.
HTA’s statutory duties include:
- licensing organisations that remove, store and use human tissue for certain purposes under the HT Act
- licensing organisations involved in preparing tissues and cells for use in patient treatment as required by the Human Tissue (Quality and Safety for Human Application) Regulations 2007 (as amended)
- licensing organisations involved in organ procurement and transplantation as required by the Quality and Safety of Organs Intended for Transplantation Regulations 2012 (as amended)
- superintending compliance with the requirements of the legislation and HTA’s codes of practice
- assessment of living organ donations to ensure donors are protected from duress or coercion, and that no reward is offered or given
- providing information, advice and guidance to the public and professionals about the nature and purpose of activities within HTA’s remit
- monitoring developments relating to activities within HTA’s remit and advising the Secretary of State, the relevant Northern Ireland department or Welsh ministers on related issues
Aims
HTA’s mission is to be an excellent regulator for the use of human tissue with consent and safety, sustaining public and professional confidence, today and in the future.
HTA’s strategic aims are set out in the HTA strategy 2024 to 2027. These are to:
- be further recognised across the health and wider systems as having a valuable role in the regulation and growth of life sciences. Professionals and the public are assured on the safe and trusted use of human tissue and cells
- be a more outcome focused and proportionate regulator with the ability to comment authoritatively on the totality of our insight, quantify our impact and demonstrate our value. We use our expert voice to be open about challenges in sectors and lever improvement and change on areas of concern
- provide greater consistency and evidence-based assessment of risk and action taken. Our actions help to anticipate and identify actual and early warning signs of shortfalls in expected practice. We openly bring about change with any remedial action being timely, responsive to risk and impactful. Our commitment is unwavering in the safe use of human tissue
- be less reliant on manual processes by strengthening digital capacity and capability in ways of working to support a future sustainable operational excellence
- demonstrate an ongoing commitment to investing and developing HTA’s workforce. Staff have the technical expertise and capability to deliver open and credible regulation. We demonstrate we are resilient, responsive, efficient and effective, with a strong reputation as an expert regulator with great staff
From these strategic aims, HTA has set out 4 priorities in the 3-year document. These are to make further improvements in:
- our approach to regulation
- trust and confidence in HTA by stakeholders in the use and storage of human tissue
- how we use information
- our efficiency and effectiveness
Governance and accountability
HTA shall operate corporate governance arrangements that, so far as is practicable and in the light of the other provisions of this framework agreement or as otherwise may be mutually agreed, accord with good corporate governance practice and applicable regulatory requirements and expectations.
In particular (but without limitation), HTA should:
- comply with the principles and provisions of the Corporate governance code for central government departments (as amended and updated from time to time) to the appropriate extent and in line with their statutory duties, or specify and explain any non-compliance in its annual report
- comply with MPM
- in line with MPM, have regard to the relevant functional standards as appropriate and in particular those concerning finance, commercial and counter fraud
- take into account the codes of good practice and guidance set out in annex A of this framework agreement, as they apply to arm’s length bodies (ALBs)
- in line with MPM annex 3.1, provide an account of corporate governance in its annual governance statement, including the board’s assessment of its compliance with the code with explanations of any material departures. To the extent that HTA does intend to materially depart from the code, DHSC should be notified in advance and their agreement sought to this approach
Role of DHSC
The responsible minister
The Secretary of State for Health and Social Care will account for HTA on all matters concerning HTA in Parliament.
The Secretary of State is responsible for the policy framework within which HTA operates and has statutory powers in relation to the activities to which the HT Act applies. The Secretary of State also has powers in respect of HTA, which are set out in the HT Act.
These are the power to:
- by regulations, add to the activities within the remit of HTA (section 14(4))
- require advice from HTA on activities within HTA’s remit (section 15(f))
- through regulations, add to, vary or omit activities for which an HTA licence is required (section 16(5))
- approve the HTA code of practice before publication (section 29(1))
- appoint the chair and the non-executive members of HTA, and determine their terms of appointment and remuneration (schedule 2)
- remove or suspend the chair and non-executive members (schedule 2)
- direct HTA, with the approval of HMT, as to the form HTA’s accounts must take and to give a notice specifying the date by which the accounts must be submitted to the Secretary of State, the Welsh ministers, the relevant Northern Ireland department and the Comptroller and Auditor General (C&AG) (schedule 2)
Under schedule 2 of the HT Act, the Secretary of State is also responsible for providing HTA with funding.
Appointments to the board
The chair is appointed by the Secretary of State for Health and Social Care under paragraph 1(a) of schedule 2 to the HT Act. This appointment is subject to the Public Appointments Order in Council and as such must comply with the Governance Code on Public Appointments.
Non-executive members are appointed by the Secretary of State for Health and Social Care under paragraph 1(b) of schedule 2 to the HT Act. These appointments are also subject to the Public Appointments Order in Council and as such must comply with the Governance Code for Public Appointments.
The terms of appointment of the chair and other members shall be determined by the Secretary of State for Health and Social Care and shall be for a term not exceeding 3 years.
As set out in paragraph 1 of schedule 2 to the HT Act, of the non-executive members:
- a number that the Secretary of State for Health and Social Care sees fit are appointed by the Secretary of State
- one is appointed by the Welsh ministers
- one is appointed by the relevant Northern Ireland department
All such appointments should have regard to the principle that appointments should reflect the diversity of the society in which we live, and appointments should be made taking account of the need to appoint boards which include a balance of skills and backgrounds.
Other ministerial powers and responsibilities
The Secretary of State is also responsible for:
- the policy framework within which HTA operates
- setting the performance framework within which HTA will operate, including approving HTA’s strategy and business plan
- providing guidance and direction to ensure the strategic aims and objectives of HTA are consistent with those of DHSC and the government
- matters regarding spending approvals, acquisitions, disposals and joint ventures, in line with delegations as set out in the delegation letter
The principal accounting officer
The PAO is the Permanent Secretary of DHSC.
The PAO of DHSC designates the chief executive as HTA’s accounting officer (AO) and ensures they are fully aware of their responsibilities. The PAO issues a letter appointing the AO, setting out their responsibilities and delegated authorities.
The respective responsibilities of the PAO and AOs are set out in chapter 3 of MPM.
The PAO is accountable to Parliament for the issue of grant-in-aid to HTA. The PAO, usually through the sponsor team, is also responsible for advising the Secretary of State on:
- an appropriate framework of objectives and targets for HTA in the light of DHSC’s wider strategic aims and priorities
- an appropriate budget for HTA in the light of DHSC’s overall public expenditure priorities
- how well HTA is achieving its strategic objectives and whether it is providing value for money
- the exercise of the ministers’ statutory responsibilities concerning HTA
The PAO, through the sponsor team, is also responsible for ensuring arrangements are in place to:
- monitor HTA’s activities and performance
- address significant problems in HTA, making such interventions as are judged necessary
- periodically, and at such frequency as is proportionate to the level of risk, carry out an assessment of the risks both to DHSC and HTA’s objectives and activities in line with the wider departmental risk assessment process
- inform HTA of relevant government policy in a timely manner
- bring ministerial or departmental concerns about the activities of HTA to the full HTA board and, as appropriate, to the departmental board, requiring explanations and assurances that appropriate action has been taken
The senior departmental sponsor
A director is appointed as the senior departmental sponsor who acts as HTA’s designated, consistent point of contact within DHSC and manages their overall relationship with DHSC. The senior departmental sponsor acts as the link at executive level between HTA and senior officials of DHSC, and with ministers.
While the senior departmental sponsor role is facilitative and recognises the need for direct engagement between HTA and other parts of DHSC and ministers, it also supports the Secretary of State and Permanent Secretary in holding HTA to account.
The senior departmental sponsor is also responsible for agreeing the objectives for, and reviewing the contribution of, the chair of HTA.
The sponsor team
The HTA sponsor team in DHSC supports the senior departmental sponsor and is the primary contact for HTA. The responsible senior civil servant for this relationship is the director of the directorate that the sponsor team is a part of. They are the main source of advice to the Secretary of State on the discharge of their responsibilities in respect of HTA. They also support the PAO on their responsibilities towards HTA.
The sponsor team will liaise regularly with counterparts in HTA to support effective corporate relationships and co-ordinate assurance and accountability functions.
Officials of the sponsor team will liaise regularly with HTA officials to review:
- performance against plans
- achievement against targets
- expenditure against its departmental expenditure limit and annual managed expenditure allocations
HTA and the sponsor team will hold quarterly accountability meetings. The sponsor team will also take the opportunity to explain wider policy developments that might have an impact on HTA.
Information will be provided to DHSC by HTA including (not an exhaustive list):
- quarterly business scorecards that show performance against agreed key performance indicators and monthly budgetary performance returns to finance
- monthly updated strategic risk register
- annual governance statement
The processes in place to enable DHSC and HTA to review performance include:
- quarterly accountability meetings between HTA and the sponsor team
- attendance of officials from DHSC, as observers, of the full authority and HTA Audit and Risk Assurance Committee
HTA will also prepare an annual report of the 12 months ending on 31 March, setting out:
- its activities
- how it has discharged its statutory duties
- what progress it has made towards its objectives
- what activities it proposes to undertake in the succeeding 12-month period
Resolution of disputes between HTA and DHSC
Any disputes between DHSC and HTA will be resolved in as timely a manner as possible. DHSC and HTA will seek to resolve any disputes through an informal process in the first instance. If this is not possible, then a formal process will be used to resolve the issue, overseen by the senior departmental sponsor. Failing this, the senior departmental sponsor will ask the relevant policy director general to oversee the dispute. The director general may then choose to ask the Permanent Secretary to nominate a non-executive member of DHSC’s board to review the dispute, mediate with both sides and reach an outcome, in consultation with the Secretary of State.
Freedom of Information requests
Where a request for information is received by either party under the Freedom of Information Act 2000, or the Data Protection Act 1998 or Data Protection Act 2018, the party receiving the request will consult with the other party prior to any disclosure of information that may affect the other party’s responsibilities.
Reporting on legal risk and litigation
HTA shall provide a quarterly update to the sponsor on the existence of any active litigation and any threatened or reasonably anticipated litigation. The parties acknowledge the importance of ensuring that legal risks are communicated appropriately to the sponsor in a timely manner.
In respect of each substantial piece of litigation involving HTA, the parties will agree a litigation protocol which will include specific provisions to ensure appropriate and timely reporting on the status of the litigation and the protection of legally privileged information transmitted to the sponsor to facilitate this. Until such time as a protocol is agreed, the parties will ensure that:
- material developments in the litigation are communicated to the sponsor in an appropriate and timely manner
- legally privileged documents and information are clearly marked as such
- individual employees handling the legally privileged documents are familiar with the principles to which they must adhere to protect legal privilege
- circulation of privileged information within government occurs only as necessary
HTA governance structure
Chief executive
Appointment
The chief executive of HTA is appointed by the board of HTA at the discretion of the chair and with the approval of the Secretary of State for Health and Social Care.
Responsibilities of HTA’s chief executive as accounting officer
The chief executive as AO is personally responsible for:
- safeguarding the public funds for which they have charge
- ensuring propriety, regularity, value for money and feasibility in the handling of those public funds
- the day-to-day operations and management of HTA
In addition, they should ensure that HTA as a whole is run on the basis of the standards, in terms of governance, decision making and financial management, that are set out in annex 3.1 of MPM. These responsibilities include the below and those that are set in the AO appointment letter issued by the PAO of DHSC.
Responsibilities for accounting to Parliament and the public
Responsibilities to Parliament and the public include:
- signing the accounts and ensuring that proper records are kept relating to the accounts and that they are properly prepared and presented in accordance with any directions issued by the Secretary of State
- preparing and signing a governance statement for inclusion in the annual report and accounts, covering corporate governance, risk management and oversight of any local responsibilities
- ensuring that effective procedures for handling complaints about HTA in accordance with Parliamentary and Health Service Ombudsman’s principles of good complaint handling are established and made widely known within HTA and published on HTA’s website
- acting in accordance with the terms of MPM and other instructions and guidance issued from time to time by DHSC, HMT and the Cabinet Office
- ensuring that as part of the above compliance they are familiar with and act in accordance with:
- any governing legislation
- this framework agreement
- any delegation letter issued to body
- any elements of any settlement letter issued to DHSC that is relevant to the operation of HTA
- any separate settlement letter that is issued to HTA from DHSC
- ensuring they have appropriate internal mechanisms for the monitoring, governance and external reporting regarding compliance with any conditions arising from the above documents
- giving evidence, normally with the PAO, when summoned before the Public Accounts Committee on HTA’s stewardship of public funds
Responsibilities to DHSC
Responsibilities to DHSC include:
- establishing, in agreement with DHSC, HTA’s corporate and business plans in the light of DHSC’s wider strategic aims and agreed priorities
- informing DHSC of progress in helping to achieve DHSC’s policy objectives and demonstrating how resources are being used to achieve those objectives
- ensuring that:
- timely forecasts and monitoring information on performance and finance are provided to DHSC
- DHSC is notified promptly if over or under spends are likely and that corrective action is taken
- any significant problems whether financial or otherwise (and whether detected by internal audit or by other means) are notified to DHSC in a timely fashion
Responsibilities to the board
The chief executive is responsible for:
- advising the board on the discharge of their responsibilities as set out in this document, in the founding legislation and in any other relevant instructions and guidance that may be issued from time to time
- advising the board on HTA’s performance compared with its aims and objectives
- ensuring that financial considerations are taken fully into account by the board at all stages in reaching and executing its decisions, and that financial appraisal techniques are followed
Managing conflicts
The chief executive should follow the advice and direction of the board, except in very exceptional circumstances with a clear cut and transparent rationale for not doing so.
If the board, or its chair, is contemplating a course of action involving a transaction which the chief executive considers would infringe the requirements of propriety or regularity or does not represent prudent or economical administration, efficiency or effectiveness, is of questionable feasibility or is unethical, the chief executive, in their role as AO, should reject that course of action and ensure that the board has full opportunity to discuss the rationale for that rejection.
Such conflicts should be brought to the attention of the PAO and the responsible minister as soon as possible.
Furthermore, and if agreed with the responsible minister, the AO must write a letter of justification to the chair of the board setting out the rationale for not following the advice and recommendation of the board, and copy that letter to the HMT officer of accounts.
If the responsible minister agrees with the proposed course of action of the board, it may be appropriate for the minister to direct the AO in the manner as set out in MPM paragraph 3.6.6 onwards.
HTA board
Composition of the board
HTA will have a board in line with good standards of corporate governance and as set out in its establishing statute and in the guidance in annex A of this framework agreement.
The role of the board shall be:
- to direct HTA
- to deliver its:
- objectives, in accordance with the purposes as set out above
- statutory, regulatory and common law duties
- responsibilities under this framework agreement
The detailed responsibilities of the board shall be set out in the terms of reference. Remuneration of the board will be disclosed in line with the latest guidance in the government financial reporting manual (FReM).
The board will consist of a non-executive chairperson and such number of other non-executive members, appointed by the Secretary of State, as the Secretary of State thinks fit who have a balance of skills and experience appropriate to directing HTA’s business. Not less than half of the members are persons who do not have, and have not had, a professional interest in any of the sectoral activity within the remit of HTA.
The balance of skills across HTA’s board may include members who have experience of:
- legal and regulatory expertise
- leading digital transformation
- professional experience in any of the sectors regulated by HTA
- experience of organ donation and transplantation either from a patient or practitioner perspective
There are no executives serving as board members. The board consists exclusively of independent non-executive members, as determined in the relevant legislation and appointed by the Secretary of State, with, in addition, a non-executive selected by the National Assembly of Wales and a non-executive selected by the relevant Northern Ireland department. The board ensures that the executives are supported and constructively challenged, through the chief executive and AO.
The senior executives, known as the HTA senior management team, including the finance director (suitably qualified as set out in annex 4.1 of MPM) and the chief executive, as AO, will attend the regular, published meetings of the board.
Board committees
The board may set up such committees as necessary for it to fulfil its functions. As is detailed below, at a minimum this should include an Audit and Risk Assurance Committee chaired by an independent and appropriately qualified or experienced non-executive member of the board.
While the board may make use of committees, it retains responsibility for, and endorses, final decisions. The chair should ensure that sufficient time is allowed at board meetings for committees to report on the nature and content of discussion, on recommendations and on actions to be taken. Appointments, succession planning and remuneration must be within the strict parameters laid down by ministers and HMT.
Where there is disagreement between the relevant committee and the board, adequate time should be made available for discussion of the issue with a view to resolving the disagreement. Where any such disagreement cannot be resolved, the committee concerned should have the right to report the issue to the sponsor team, PAO and the responsible minister. They may also seek to ensure the disagreement or concern is reflected as part of the report on its activities in the annual report.
The chair should ensure board committees are properly structured with appropriate terms of reference. The terms of each committee should set out its responsibilities and the authority delegated to it by the board. The chair should ensure that committee membership is periodically refreshed and that individual independent non-executive directors are not over-burdened when deciding the chairs and membership of committees.
Duties of the board
The board is specifically responsible for:
- establishing and taking forward the strategic aims and objectives of HTA consistent with its overall strategic direction and within the policy and resources framework determined by the Secretary of State
- providing effective leadership of HTA within a framework of prudent and effective controls which enables risk to be assessed and managed
- ensuring that the financial and human resources are in place for HTA to meet its objectives
- reviewing management performance
- ensuring that the board receives and reviews regular financial and management information concerning the management of HTA
- ensuring that it is kept informed of any changes which are likely to impact the strategic direction of HTA or the attainability of its targets, and determining the steps needed to deal with such changes and where appropriate bringing such matters to the attention of the responsible minister and PAO, either directly or through the executive team or sponsorship team
- ensuring that:
- any statutory or administrative requirements for the use of public funds are complied with
- the board operates within the limits of its statutory authority and any delegated authority agreed with DHSC, and in accordance with any other conditions relating to the use of public funds
- in reaching decisions, the board takes into account guidance issued by DHSC
- ensuring that as part of the above compliance they are familiar with:
- this framework agreement
- any delegation letter issued to HTA
- any elements of any settlement letter issued to DHSC that is relevant to the operation of HTA
- any separate settlement letter that is issued to HTA from DHSC
- ensuring that they have appropriate internal mechanisms for the monitoring, governance and external reporting regarding any conditions arising from the above documents and ensuring that the chief executive and HTA as a whole act in accordance with their obligations under the above documents
- demonstrating high standards of corporate governance at all times, including by using the independent audit committee to help the board to address important financial and other risks
- in consultation with DHSC, setting performance objectives and remuneration terms linked to these objectives for the chief executive which give due weight to the proper management and use of public resources
- determining all such other things that the board considers ancillary or conducive to the attainment or fulfilment by HTA of its objectives
The board should ensure that effective arrangements are in place to provide assurance on risk management, governance and internal control.
The board should make a strategic choice about the style and shape of risk management and should lead the assessment and management of opportunity and risk. The board should ensure that effective arrangements are in place to provide assurance over the design and operation of risk management, governance and internal control in line with HMT’s Orange Book management of risk - principles and concepts.
The board must set up an Audit and Risk Assurance Committee, chaired by an independent and appropriately qualified non-executive member, to:
- provide independent advice
- ensure that DHSC’s Audit and Risk Assurance Committee is provided with routine assurances, with escalation of any significant limitations or concerns
The board is expected to assure itself of the adequacy and effectiveness of the risk management framework and the operation of internal control.
The chair’s role and responsibilities
The chair is responsible for leading the board in the delivery of its responsibilities. Such responsibility should be exercised in the light of their duties and responsibilities as set out in:
- their appointment letter
- the priorities in the chair’s letter issued to them by DHSC
- the statutory authority governing HTA
- this document
- the documents and guidance referred to within this document
Communications between HTA’s board and the responsible minister should normally be through the chair.
The chair is bound by the code of conduct for board members of public bodies, which covers conduct in the role and includes the Nolan principles of public life.
In addition, the chair is responsible for ensuring that:
- HTA’s affairs are conducted with probity, including by monitoring and engaging with appropriate governance arrangements
- policies and actions support the responsible minister’s and, where relevant, other ministers’ wider strategic policies and, where appropriate, these policies and actions should be clearly communicated and disseminated throughout HTA
The chair is responsible for:
- formulating the board’s strategy
- ensuring that the board takes proper account of guidance provided by the responsible minister or DHSC when reaching decisions
- promoting the efficient and effective use of staff and other resources
- delivering high standards of regularity and propriety
- representing the views of the board to the general public
The chair also has an obligation to ensure that:
- the work of the board and its members is reviewed and that they are working effectively, including ongoing assessment of the performance of individual board members with a formal annual evaluation and more in-depth assessments of the performance of individual board members when being considered for re-appointment
- in conducting assessments, the views of relevant stakeholders including employees and the sponsor team are sought and considered
- the board has a balance of skills appropriate to directing HTA’s business, and that all directors including the chair and chief executive continually update their skills, knowledge and familiarity with HTA to fulfil their role both on the board and committees. This will include, but not be limited to, skills and training in relation to financial management and reporting requirements, risk management and the requirements of board membership within the public sector
- board members are fully briefed on terms of appointment, duties, rights and responsibilities
- they, together with the other board members, receive appropriate training on financial management and reporting requirements and on any differences that may exist between private and public sector practice
- the responsible minister is advised of HTA’s needs when board vacancies arise
- there is a board operating framework in place setting out the role and responsibilities of the board, consistent with the government code of good practice for corporate governance
- there is a code of practice for board members in place, consistent with the Cabinet Office code of conduct for board members of public bodies
Individual board members’ responsibilities
Individual board members shall:
- comply at all times with the code of conduct for board members of public bodies, which covers conduct in the role and includes the Nolan principles of public life as well as rules relating to the use of public funds and to conflicts of interest
- demonstrate adherence to the 12 principles of governance for all public body non-executive directors as appropriate
- not misuse information gained in the course of their public service for personal gain or for political profit, nor seek to use the opportunity of public service to promote their private interests or those of connected persons or organisations
- comply with the board’s rules on the acceptance of gifts and hospitality, and of business appointments
- act in good faith and in the best interests of HTA
- ensure they are familiar with any applicable guidance on the role of public sector non-executive directors and boards that may be issued from time to time by the Cabinet Office, HMT or wider government
Management and financial responsibilities and controls
Delegated authorities
HTA’s delegated authorities are set out in the delegation letter. This delegation letter may be updated and superseded by later versions which may be issued by DHSC in agreement with HMT.
In line with MPM annex 2.2, these delegations will be reviewed on an annual basis.
HTA shall obtain DHSC’s and, where appropriate, HMT’s prior written approval before:
- entering into any undertaking to incur any expenditure that falls outside the delegations or which is not provided for in HTA’s annual budget as approved by DHSC
- incurring expenditure for any purpose that is or might be considered novel or contentious, or which has or could have significant future cost implications
- making any significant change in the scale of operation or funding of any initiative or particular scheme previously approved by DHSC
- making any change of policy or practice which has wider financial implications that might prove repercussive or which might significantly affect the future level of resources required
- carrying out policies that go against the principles, rules, guidance and advice in MPM
Spending authorities
Once the budget has been approved by DHSC, HTA has authority to incur expenditure approved in the budget without further reference to DHSC, on the following conditions:
- HTA shall comply with the delegations set out in the delegation letter. These delegations shall not be altered without the prior agreement of DHSC and as agreed by HMT and Cabinet Office as appropriate
- HTA shall comply with MPM regarding novel, contentious or repercussive proposals
- inclusion of any planned and approved expenditure in the budget shall not remove the need to seek formal departmental approval where any proposed expenditure is outside the delegated limits or is for new schemes not previously agreed
- HTA shall provide DHSC with such information about its operations, performance, individual projects or other expenditure as DHSC may reasonably require
Banking and managing cash
HTA shall maximise the use of publicly procured banking services (accounts with central government commercial banks managed centrally by Government Banking).
HTA shall only hold money outside Government Banking service accounts where a good business case can made for doing so and HMT consent is required for each account to be established. Only commercial banks that are members of relevant UK clearing bodies may be considered for this purpose.
Commercial accounts, where approved, shall be operated in line with the principles set out in MPM.
The AO is responsible for ensuring that HTA has a banking policy as set out in MPM and for ensuring that the policy is complied with.
Procurement
HTA shall ensure that its procurement policies are aligned with and comply with UK and international procurement regulations such as the Procurement Act 2023.
HTA shall establish its procurement policies and document these in a procurement policy and procedures manual.
In procurement cases where HTA is likely to exceed its delegated authority limit, procurement strategy approval for the specific planned purchase must be sought from DHSC’s sponsor team.
Competition promotes economy, efficiency and effectiveness in public expenditure. Works, goods and services should be acquired through competition unless there are convincing reasons to the contrary. The form of competition chosen should be appropriate to the value and complexity of the goods or services to be acquired.
Contracts awarded without competition shall be limited and exceptional, and a quarterly report explaining those exceptions should be sent to DHSC.
Procurement by HTA of works, equipment, goods and services shall be based on an appraisal of options and value for money. That means securing the best mix of quality and effectiveness for the least outlay over the period of use.
HTA shall:
- engage fully with DHSC and government-wide procurement initiatives that seek to achieve value for money from collaborative projects
- comply with all relevant procurement policy notes issued by Cabinet Office
- co-operate fully with initiatives to improve the availability of procurement data to facilitate the achievement of value for money
- ensure their commercial capability is developed in line with Government Commercial Function people standards
HTA shall comply with both:
These standards apply to the planning, delivery and management of government commercial activity, including management of grants in all departments and ALBs, regardless of commercial approach used. They form part of a suite of functional standards that set expectations for management within government.
Risk management
HTA shall ensure that the risks that it faces are dealt with in an appropriate manner, in accordance with relevant aspects of best practice in corporate governance, and develop a risk management strategy, in accordance with HMT’s Orange Book management of risk - principles and concepts.
HTA shall promptly notify DHSC of any operational and financial risks arising from their activities that may have a potentially significant impact on them, DHSC, another health and care body or the wider system. These will be discussed in meetings they have with the senior departmental sponsor and the sponsor team. Such risks shall also be notified by HTA’s risk function or board to DHSC’s risk team and may be escalated to DHSC’s Audit and Risk Committee (ARC) for consideration. The chair of the HTA’s Audit and Risk Assurance Committee shall also escalate any risk concerns to the department’s risk team and may be asked to attend DHSC’s ARC to explain the risks. It is the responsibility of HTA and the sponsor team to keep each other informed of significant risks to, or arising from, the operations of HTA within the wider system.
Counter fraud and theft
Commitment to counter fraud
HTA acknowledges that fraud, bribery and corruption pose significant risks to public funds and the integrity of health services. Both parties agree that preventing, detecting and responding to fraud is a shared responsibility and a priority under the government’s counter fraud standard.
Fraud reporting and co-operation
HTA should:
- adopt and implement policies and practices to safeguard itself against fraud and theft
- take all reasonable steps to prevent and detect fraud within its operations
- keep records of and prepare and forward to DHSC an annual report on fraud and theft suffered by HTA and notify the DHSC Anti-Fraud Unit (AFU) and, where appropriate, the NHS Counter Fraud Authority (NHSCFA) of any unusual or major incidents as soon as possible
- manage the prevention, detection and recovery of fraud losses in HTA. Where trained resource is in place, this includes the investigation of fraud, bribery and corruption, working with law enforcement partners as appropriate
- report detected loss from fraud, bribery, corruption and error, alongside associated recoveries and prevented losses, to the counter fraud centre of expertise in line with the agreed government definitions as set out in the counter fraud standard
- co-operate fully with DHSC and NHSCFA in any investigation or assurance activity, including providing timely access to relevant information, staff and systems
Notification and escalation
Where fraud is identified or suspected, HTA must notify DHSC without delay and follow agreed escalation protocols. Serious cases should be reported immediately to DHSC AFU at reportingfraud@dhsc.gov.uk.
Compliance and assurance
HTA should act in line with guidance issued by the Government Counter Fraud Function and in compliance with the procedures and considerations set out in MPM annex 4.9 and the counter fraud standard. This includes:
- completing fraud risk assessments
- implementing proportionate controls
- participating in periodic reviews or audits as requested by DHSC
- taking all reasonable steps to appraise the financial standing of any firm or other body with which it intends to enter a contract or to provide grant or grant-in-aid
HTA will maintain effective counter fraud arrangements aligned with DHSC’s counter fraud strategy and MPM guidance.
Culture and training
HTA will promote a culture of integrity and vigilance, ensuring staff are aware of fraud risks and know how to report concerns. Training and awareness activities should be embedded within governance and operational processes.
Staff
Broad responsibilities of staff
Within the arrangements approved by the Secretary of State for Health and Social Care and HMT, HTA will have responsibility for the recruitment, retention and motivation of its staff. The broad responsibilities towards its staff are to ensure that:
- the rules for recruitment and management of staff create an inclusive culture in which:
- diversity is fully valued
- appointment and advancement is based on merit
- there is no discrimination against employees with protected characteristics under the Equality Act 2010
- the level and structure of its staffing, including grading and staff numbers, are appropriate to its functions and the requirements of economy, efficiency and effectiveness
- the performance of its staff at all levels is satisfactorily appraised and HTA performance measurement systems are reviewed from time to time
- its staff are encouraged to acquire the appropriate professional, management and other expertise necessary to achieve HTA’s objectives
- proper consultation with staff takes place on important issues affecting them
- adequate grievance and disciplinary procedures are in place
- whistleblowing procedures consistent with the Public Interest Disclosure Act 1998 are in place
- a code of conduct for staff is in place based on Cabinet Office’s code of conduct for board members of public bodies
Staff costs
Subject to its delegated authorities, HTA shall ensure that the creation of any additional posts does not incur forward commitments that will exceed its ability to pay for them.
Pay and conditions of service
HTA’s staff are subject to levels of remuneration and terms and conditions of service (including pensions) within the general pay structure approved by DHSC and HMT. HTA has no delegated power to amend these terms and conditions.
If Civil Service terms and conditions of service apply to the rates of pay and non-pay allowances paid to the staff and to any other party entitled to payment in respect of travel expenses or other allowances, payment shall be made in accordance with the Civil Service management code and the annual Civil Service pay remit guidance, except where prior approval has been given by DHSC to vary such rates.
Staff terms and conditions should be set out in an employee handbook, which should be provided to DHSC together with subsequent amendments.
HTA shall abide by public sector pay controls, including the relevant approvals process dependent on its classification as detailed in the senior pay guidance and the public sector pay and terms guidance.
HTA shall operate a performance-related pay scheme that shall form part of the annual aggregate pay budget approved by DHSC, and where relevant with due regard to the senior pay guidance.
The travel expenses of board members shall be tied to the rates allowed to senior staff of HTA. Reasonable actual costs shall be reimbursed.
Pensions, redundancy and compensation
Compensation scheme rules and pension scheme rules shall reflect legislative and HMT guidance requirements regarding exit payments.
HTA staff shall normally be eligible for a pension provided by the NHS Pension Scheme. Staff may opt out of the occupational pension scheme provided by HTA, but the employer’s contribution to any personal pension arrangement, including stakeholder pension, shall normally be limited to the National Insurance rebate level.
Any proposal by HTA to move from the existing pension arrangements, or to pay any redundancy or compensation for loss of office, requires the prior approval of DHSC. Proposals on severance must comply with the rules in chapter 4 of MPM.
HTA shall seek approval from DHSC’s Remuneration, Exits and Governance Committee for recruiting to executive and senior managers’ posts or paying above the relevant ceilings in the executive and senior managers’ pay framework. All applications will need approval from the HTA sponsor team before being considered by the committee.
Business plans, financial reporting and information management
Corporate strategy and business plans
HTA shall submit to DHSC a draft of the corporate strategy covering 3 years ahead. The draft should be submitted in line with the agreed timetable established by DHSC. HTA shall agree with DHSC issues to be addressed in the strategy and the timetable for this. The strategy shall reflect HTA’s statutory and/or other duties and, within those duties, the priorities set from time to time by the responsible minister (including decisions taken on policy and resources in the light of wider public expenditure decisions). The strategy shall demonstrate how HTA contributes to the achievement of DHSC’s medium-term plan and priorities and aligned performance metrics and milestones.
HTA shall also submit to DSHC a draft annual business plan for delivery of the corporate strategy. The annual business plan shall include targets and commitments for the year immediately ahead and shall be linked to budgeting information so that resources allocated to achieve specific objectives can be readily identified by DHSC. The annual plan will also include some initial intentions for years 2 and 3, consistent with the corporate strategy.
Subject to any commercial considerations, the corporate strategy and business plans should be published by HTA on their website and separately be made available to staff.
The following matters should be included in one of the relevant governance documents (including corporate strategy, annual business plan, annual review, and the annual report and accounts):
- critical objectives and commitments and associated performance targets for the forward years, and the strategy for achieving those objectives
- critical non-financial performance targets
- a review of performance in the preceding financial year, together with comparable outturns for the previous 3 years, and an estimate of performance in the current year
- alternative scenarios and an assessment of the risk factors that may significantly affect the execution of the strategy but that cannot be accurately forecast
- other matters as agreed between DHSC and HTA
Budgeting procedures
Each year, in the light of decisions by DHSC on the updated draft business plan, DHSC will send to HTA by an agreed date:
- a formal statement of the annual budgetary provision allocated by DHSC in the light of competing priorities across DHSC and of any forecast income approved by DHSC
- a statement of any planned change in policies affecting HTA
The approved annual business plan will:
- take account of both approved funding provision and any forecast receipts
- include a budget of estimated payments and receipts together with a profile of expected expenditure and drawdown of any departmental funding and/or other income over the year
These elements form part of the approved business plan for the year in question.
Grant-in-aid and any ring-fenced grants
Any grant-in-aid provided by DHSC for the year in question will be voted in DHSC’s supply estimate and be subject to parliamentary control.
The grant-in-aid will normally be paid in monthly instalments based on written applications showing evidence of need. HTA will comply with the general principle that there is no payment in advance of need. Cash balances accumulated during the year from grant-in-aid or other Exchequer funds shall be kept to a minimum level consistent with the efficient operation of HTA. Grant-in-aid not drawn down by the end of the financial year shall lapse. Subject to approval by Parliament of the relevant estimates provision, where grant-in-aid is delayed to avoid excess cash balances at the year end, DHSC will make available in the next financial year any such grant-in-aid that is required to meet any liabilities at the year end, such as creditors.
If DHSC provides HTA with separate grants for specific ring-fenced purposes, it would issue the grant as and when HTA needed it on the basis of a written request. HTA would provide evidence that the grant was used for the purposes authorised by DHSC. HTA shall not have uncommitted grant funds in hand, nor carry grant funds over to another financial year.
Annual report and accounts
HTA must publish an annual report of its activities together with its audited accounts after the end of each financial year. HTA shall provide its finalised (audited) accounts in line with the agreed annual timetable established by DHSC for the accounts to be consolidated within DHSC’s accounts. A draft of the report should be submitted to DHSC 2 weeks before the proposed publication date. The accounts should be prepared in accordance with the relevant statutes and specific accounts direction issued by DHSC, as well as with HMT’s FReM.
The annual report and accounts shall:
- cover any corporate, subsidiary or joint ventures under its control
- comply with FreM and in particular have regard to the illustrative statements for an NDPB
- outline main activities and performance during the previous financial year and set out a summary of forward plans
Information on performance against critical financial targets is included in the annual report and subject to the auditor’s consistency opinion. The report and accounts shall be laid in Parliament and made available on HTA’s website, in accordance with the guidance in FreM.
Reporting performance to DHSC
HTA shall operate management, information and accounting systems that enable it to review in a timely and effective manner its financial and non-financial performance against the budgets and targets set out in the corporate and business plans.
HTA shall inform DHSC of any changes that make achievement of objectives more or less difficult. It shall report financial and non-financial performance, including performance in helping to deliver ministers’ policies, and the achievement of critical objectives regularly through its quarterly meetings with DHSC.
HTA’s performance shall be formally reviewed by DHSC 4 times a year.
The responsible minister shall meet the chair and chief executive once a year.
Information sharing
DHSC has the right of access to all HTA records and personnel for any purpose including, for example, sponsorship audits and operational investigations.
HTA shall provide DHSC with such information about its operations, performance, individual projects or other expenditure as DHSC may reasonably require.
DHSC and HMT may request the sharing of data held by HTA in such a manner as set out in central guidance except insofar as it is prohibited by law. This may include requiring the appointment of a senior official to be responsible for the data sharing relationship.
As a minimum, HTA shall provide DHSC with information monthly that will enable DHSC to monitor satisfactorily:
- HTA’s cash management
- its drawdown of grant-in-aid
- forecast outturn by resource headings
- other data required for the Online System for Central Accounting and Reporting (OSCAR)
- data as required in respect of its compliance with any Cabinet Office controls pipelines or as required to meet any condition as set out in any settlement letter
Internal audit
HTA shall:
- ensure that DHSC’s internal audit team have complete access to all relevant records
- ensure that any arrangements for internal audit are in accordance with the Global Internal Audit Standards
- set up an audit committee of its board in accordance with the corporate governance in central government departments: code of good practice and the Audit and Risk Assurance Committee handbook
- forward the audit strategy, periodic audit plans and annual audit report, including the HTA’s head of internal audit opinion on risk management, control and governance, as soon as possible to DHSC
- keep records of, and prepare and forward to DHSC an annual report on, fraud and theft suffered by HTA and notify DHSC of any unusual or major incidents as soon as possible
- share with DHSC information identified during the audit process and the annual audit opinion report (together with any other outputs) at the end of the audit, in particular on issues impacting on DHSC’s responsibilities in relation to financial systems within HTA
External audit
The National Audit Office (NAO) audits HTA’s annual accounts, which are then certified by C&AG. NAO lays the accounts before Parliament, together with the report.
If HTA has set up and controls subsidiary companies, HTA shall, in the light of the provisions in the Companies Act 2006, ensure that C&AG has the option to be appointed auditor of those company subsidiaries that it controls and/or whose accounts are consolidated within its own accounts. HTA shall discuss with DHSC the procedures for appointing C&AG as auditor of the companies.
The C&AG:
- shall consult DHSC and HTA on who shall undertake the audits on their behalf, the NAO or a commercial auditor, although the final decision rests with C&AG
- has a statutory right of access to relevant documents including, by virtue of section 25(8) of the Government Resources and Accounts Act 2000, those held by another party in receipt of payments or grants from HTA
- shall share with DHSC information identified during the audit process and the audit report (together with any other outputs) at the end of the audit, in particular on issues impacting on DHSC’s responsibilities in relation to financial systems within HTA
- shall consider requests from departments and other relevant bodies to provide regulatory compliance reports and other similar reports at the commencement of the audit. Consistent with C&AG’s independent status, the provision of such reports is entirely at C&AG’s discretion
C&AG may carry out examinations into the economy, efficiency and effectiveness with which HTA has used its resources in discharging its functions. For these examinations, C&AG has statutory access to documents as provided for under section 8 of the National Audit Act 1983. In addition, HTA shall provide, in conditions to grants and contracts, for C&AG to exercise such access to documents held by grant recipients and contractors and sub-contractors as may be required for these examinations. HTA shall use its best endeavours to secure access for C&AG to any other documents required by C&AG which are held by other bodies.
Reviews and winding up arrangements
Review of HTA’s status
HTA will be reviewed as part of the wider Public Bodies Reviews Programme, at a time determined by DHSC’s ministers and their PAO.
Arrangements in the event that HTA is wound up
DHSC shall put in place arrangements to ensure the orderly winding up of HTA. In particular, it should ensure that the assets and liabilities of HTA are passed to any successor organisation and accounted for properly. (In the event that there is no successor organisation, the assets and liabilities should revert to DHSC.)
To this end, DHSC shall:
- have regard to Cabinet Office public bodies guidance on winding up ALBs
- ensure that procedures are in place in HTA to gain independent assurance on important transactions, financial commitments, cash flows and other information needed to handle the wind-up effectively and to maintain the momentum of work inherited by any residuary body
- specify the basis for the valuation and accounting treatment of HTA’s assets and liabilities
- ensure that arrangements are in place to prepare closing accounts and pass them to C&AG for external audit, and that, for non-Crown bodies, funds are in place to pay for such audits. It shall be for C&AG to lay the final accounts in Parliament, together with their report on the accounts
- arrange for the most appropriate person to sign the closing accounts. In the event that another ALB takes on the role, responsibilities, assets and liabilities, the succeeding ALB’s AO should sign the closing accounts. If DHSC inherits the role, responsibilities, assets and liabilities, DHSC’s PAO should sign
HTA shall provide DHSC with full details of all agreements where HTA or its successors have a right to share in the financial gains of developers. It should also pass to DHSC details of any other forms of clawback due to HTA.
Other matters
Partnership working
To support the development of their relationship, DHSC and HTA have agreed to a set of shared principles. These are:
- working together with each other, and with DHSC’s other ALBs, for patients, people who use services and the public, demonstrating their commitment to the values of the NHS as set out in the NHS Constitution for England
- respect for the importance of autonomy throughout the system, and the freedom of individual organisations to exercise their functions in the way they consider most appropriate
- recognition that the Secretary of State is ultimately accountable to Parliament and the public for the system overall. HTA will support DHSC in the discharge of its accountability duties, and DHSC will support HTA in the same way
- working together openly and positively - this includes working constructively and collaboratively with other organisations within and beyond the health and social care system
To support this, HTA and DHSC will follow an ‘open book’ approach. In the case of issues with an impact on the development or implementation of policy, DHSC can expect to be kept informed by HTA. In the same way, DHSC will seek to keep HTA apprised of developments in policy and government. There are likely to be some issues where DHSC or HTA will expect to be consulted by the other before DHSC or HTA makes either a decision or a public statement on a matter. DHSC and HTA will make clear which issues fall into this category in good time. The sponsor team will be responsible for ensuring that this works effectively.
To support the Secretary of State and the PAO in their accountability functions, HTA must provide the Secretary of State with such information relating to the exercise of its functions as he or she may request. It is therefore expected that DHSC will, when required, have full access to HTA’s files and information. If necessary, the senior departmental sponsor’s team will be responsible for prioritising these requests for information.
Communications between DHSC and HTA
DHSC and HTA shall co-operate and work collaboratively across all aspects of communication and marketing activities, to deliver impactful and cost-effective communications in the context of their shared accountability to Parliament and the public.
The basic principles are that DHSC and HTA shall:
- collaborate regularly and share information to ensure communications are aligned and to amplify their impact
- commit to undertaking this collaboration and information sharing in a timely manner
- share content with the public, media or other stakeholders
- ensure that, as a system, they are communicating with the public, workforce and their stakeholders in a co-ordinated manner so as to not confuse or undermine another part of the system
To achieve this, DHSC and HTA communications teams will have regular check-in points, including for the heads of communication and media and marketing teams, to agree communication plans. In particular, HTA and DHSC will give each other sufficient advance notice of public facing communications to allow for necessary clearances with the relevant teams as set out in the communications and marketing guidance annex of the ALB’s schedule of delegations.
Relations with DHSC’s other ALBs
HTA will work in partnership with DHSC and its other ALBs, in the interests of patients, people who use services and the public, to maximise the health and wellbeing gain for the population and to work to the values set out in the NHS Constitution.
DHSC and its ALBs have complementary but distinct roles within the system to ensure that service users receive high-quality services that provide value for public money. Details of the working arrangements with other ALBs and important bodies will, where appropriate, be agreed and set out in a partnership agreement.
Transparency
HTA is an open organisation that carries out its activities transparently. It demonstrates this by:
- proactively publishing on its website information on areas including:
- payF
- diversity of the workforce
- performance
- the way it manages public money
- the public benefits achieved through its activities
- supporting those who wish to use its data by publishing the information within guidelines set by Cabinet Office
HTA is not subject to the Public Bodies (Admission to Meetings) Act 1960, but it holds at least one board meeting in public each year, in line with the spirit of the legislation. HTA will publish an annual report. This will include a governance statement, which is to be reviewed by the senior departmental sponsor.
To underpin the principles of good communication, ‘no surprises’ and transparency, HTA and DHSC have put in place arrangements for managing communications.
HTA’s non-executive board members operate within and comply with:
- the general principles of the corporate governance guidelines set out by HMT
- Cabinet Office’s code of conduct for board members of public bodies
- HTA’s rules on disclosure of financial interests, including those of board members
HTA has developed a code of conduct for all staff, which complies with the principles in Cabinet Office’s model code for staff of executive non-departmental public bodies. This includes rules on conflicts of interest, political activity and restrictions on lobbying.
HTA will take all necessary measures to ensure that:
- patient, personal and/or sensitive information within its care and control is well managed and protected through all stages of its use, including through compliance with the Data Protection Act
- it provides public assurance in respect of its information governance practice by completing and publishing an annual information governance assessment using an agreed assessment mechanism
- it meets its legal obligations for records management, accountability and public information by compliance with relevant standards, including government and NHS codes of practice on confidentiality, security and records management
HTA’s senior information risk owner and Caldicott Guardian will work together to ensure that both patient and other personal information are handled in line with best practice in government and the wider public sector.
Public and parliamentary accountability
DHSC and its ALBs share responsibility for accounting to the public and to Parliament for policies, decisions and activities across the health and care sector. Accountability to Parliament will often be demonstrated through parliamentary questions, MPs’ letters and appearances before parliamentary committees. Accountability to the public may be through the publication of information on HTA’s website, as well as through responses to letters from the public and responses to requests under the Freedom of Information Act 2000.
DHSC and its ministers remain responsible to Parliament for the system overall, so will often have to take the lead in demonstrating this accountability. Where this is the case, HTA will support DHSC by, among other things, providing information for ministers to enable them to account to Parliament. In its turn, DHSC provides leadership to the system for corporate governance, including setting standards for performance in accountability.
HTA, however, has its own responsibilities in accounting to the public and to Parliament, and its way of handling these responsibilities has been agreed with DHSC. In all matters of public and parliamentary accountability, DHSC and its ALBs will work together considerately, co-operatively and collaboratively. Any information provided by HTA is to be timely, accurate and, where appropriate, consistent with information provided by DHSC. To facilitate this, DHSC and HTA have agreed a public and parliamentary accountability protocol that sets out how they will work together to secure the confidence of the public and Parliament, and to maintain the service levels that MPs and the public have come to expect. This will be reviewed, as a minimum, every 3 years, alongside this framework agreement.
Equalities
The public sector equality duty (PSED) requires HTA, as a public body, to have due regard to the need to:
- eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by or under the Equality Act 2010
- advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it
- foster good relations between persons who share a relevant protected characteristic and persons who do not share it
The specific duties require HTA, as a public body, to:
- annually publish information to demonstrate compliance with PSED - in particular, information relating to persons who share a relevant protected characteristic who are its employees and other persons affected by its policies and procedures
- prepare and publish one or more objectives it thinks it should achieve to meet PSED every 4 years
Whistleblowing
HTA, like DHSC and all its ALBs, has whistleblowing policies and procedures in place that comply with the Public Interest Disclosure Act 1998 and best practice guidance. The Act prohibits the use of confidentiality clauses that seek to prevent staff from speaking out on issues of public interest.
Sustainability
As a major public sector body, HTA has an important role to play in driving forward the government’s commitment to sustainability in the economy, society and the environment. As a minimum, HTA should comply with the Greening Government Commitments that apply to all government departments, executive agencies and NDPBs, set out in the action plan for driving sustainable operations and procurement across government. Reporting is through DHSC (including the consolidation of relevant information in DHSC’s annual resource account) and DHSC will ensure HTA is aware of the process for this.