Open Letter Responses : What Every ICB Said Back

A collation and first analysis of the 42-ICB open letter campaign on NHS Talking Therapies              

Mental Health Action  ·  August 2026

Summary

We wrote to all 42 Integrated Care Boards (ICBs) in England about the failings of NHS Talking Therapies. One area — Shropshire, Telford and Wrekin — was never sent an open letter, because the underlying NHS data for that area was acknowledged to be internally inconsistent and no reliable analysis could be made. It is excluded in this report. So effectively this is a report on 41 ICBs.

17substantive replies (39%)

19no response at all (46%)

5 acknowledgment / notice only (15%)

Of the 41 ICBs contacted, 17 ICBs sent a substantive reply of some kind. 19 never responded at all, to either the original letter or a follow-up prompt. The remaining 5 sit in a grey zone — an acknowledgment with no answers, an administrative notice about a merger, a reply from a provider rather than the ICB itself, or a reply obtained only through an MP’s separate correspondence. 

The headline finding is not simply that most ICBs stayed silent, though that is true. It is that among the minority who did reply, a strikingly consistent set of moves recurs across organisations — near-identical opening lines rejecting the letter’s premise, the same national rather than local statistics quoted in the same order, and a repeated substitution of favourable, recent, or differently-defined figures for the specific 2023/24 entry-based analysis the letters were built on. Two replies — Somerset and North East London — stand out as genuine exceptions, engaging with the letter’s questions in real detail. A handful of others engage partially. The rest range from thin to empty.

Below I set out those patterns with the evidence behind them, work through what happened ICB by ICB, and flag points that still need clarification before writing this up as becomes a finished report.

How to Read This Draft

Every ICB below is classified into one of four categories, used consistently throughout:

• Substantive reply — the ICB itself sent a response addressing some or all of the ten questions, whatever its quality.
• Confirmed non-responder — no reply to either the original letter or the follow-up prompt email, as of the date logged.
• Acknowledgment or notice only — contact was made, but with no answers: a holding message, an administrative notice about a merger, or similar.
• Provider- or third-party-sourced only — a reply exists, but not from the ICB itself: a commissioned provider trust answering on the ICB’s behalf, or a reply obtained only through an MP’s separate correspondence.

Seven ICBs in the original 42 were affected by organisational restructuring during the campaign — mergers, dissolutions, or commissioning transfers that happened after the original letters went out. Where this affects how a letter’s outcome should be read, it is noted against that ICB individually and summarised in its own section below. Letters caught up in a merger are kept as separate entries rather than folded into a single row for the successor body, so that (for example) one ICB’s substantive engagement is not diluted by another’s silence just because they now share a successor organisation.

Responses from MPs and Healthwatch bodies is included as context throughout, but is not counted in the 41-ICB response tally — it supplements the picture without changing the arithmetic of who did and didn’t answer Mental Health Action directly. The one open exception is Devon, whose only substantive content came via an MP’s separate correspondence.

Part One: The Patterns Across Replies

Read individually, most ICB replies look like isolated pieces of correspondence, each with its own tone and gaps. Read together, several moves recur consistently — sometimes in near-identical wording — and they look far more like a shared playbook than forty-one organisations independently deciding how to answer the same ten questions.

1. The shared denial script

Five ICBs open their reply by rejecting Mental Health Action’s premise, using very similar language:

“Your assertion… is not recognised within this system. — Suffolk and North East Essex (SNEE), 8 Sept 2025”

“We do not recognise Mental Health Action’s interpretation of NHS Talking Therapies data. — Kent and Medway, FOI response, 8 July 2026”

“We do not share your assessment that the NHS Talking Therapies service is a failing service, and we believe there has been some incorrect interpretation of the data. — Coventry and Warwickshire / Herefordshire and Worcestershire joint reply, 22 June 2026”

“Nottingham and Nottinghamshire ICB does not recognise Mental Health Action’s interpretation of the NHS Talking Therapies data. — Nottingham and Nottinghamshire, 17 June 2026”

“We do not recognise a number of the interpretations and conclusions presented. — North Central London (replying as West and North London ICB), 18 Aug 2026”

The Kent and Medway and Nottingham lines are close to word-for-word matches. Five organisationally unconnected ICBs opening with structurally identical denial language, two of them almost verbatim, is not easily explained as coincidence. Bedfordshire, Luton and Milton Keynes uses its own wording to the same effect (“this statement does not reflect the position or experience of BLMK ICB residents”) — a sixth instance of the same underlying move, even if not the same script. Norfolk and Suffolk ICB (the successor to SNEE) went a step further on 27 August 2026, reusing the SNEE denial line and stats block near word-for-word to answer chase emails sent to two different original letters almost a year after the first reply — the clearest case yet of a template being reused rather than a fresh answer being drafted.

2. The shared national statistics block

At least three replies — SNEE, Kent and Medway, and North Central London/West and North London — quote the same four national 2023/24 figures, in the same order, with the same rounding:

“~670,000 people received well-governed, evidence-based psychological therapy for anxiety and depression through NHS Talking Therapies. 90% of referrals had an initial assessment within six weeks. Half of those who received a course of treatment recovered, and two-thirds showed significant improvement.”

Bedfordshire, Luton and Milton Keynes reproduces the same block. In every case, these are national aggregates substituted for the local data the original letters were built on — not once does an ICB using this block cite a single local dropout, access, cost, or recovery figure alongside it. The consistency of phrasing across otherwise unconnected organisations is the strongest evidence in the whole correspondence set that ICBs are working from a shared NHS England-issued line to take, rather than independently drafting their own responses.

3. Switching the year, or switching the metric

The single most repeated evasion in the whole set. Mental Health Action’s letters are built on 2023/24, entry-based figures — what happened to everyone who was referred, not just the minority who finished treatment. Reply after reply answers with a different year, a different starting point, or both, without acknowledging the substitution:

• Bristol, North Somerset and South Gloucestershire’s first reply cited July and August 2025 monthly snapshots instead of the 2023/24 annual figures the letter was built from.
• Lancashire and South Cumbria’s provider reply (LSCFT) answered the “targets met” question with 2025/26 and 2024/25 figures, sitting a few paragraphs away from its own quotation of Mental Health Action’s 2023/24 data showing an 8,800-person, 50-day-average waiting-time failure.
• Lincolnshire’s entire reply — the shortest and thinnest in the whole set — consists of nothing but favourable 2025/26 headline numbers, with no reference to 2023/24 or to any of the ten questions.
• Bedfordshire, Luton and Milton Keynes cites the shared national stats block, then adds its own 2024/25 claim (“all providers reported recovery rates above 50%”) rather than engaging with 2023/24.
• Derby and Derbyshire stays within the correct year, 2023/24, but only cites the flattering metrics within it — completer-based recovery (50%) and initial-assessment wait (85% within six weeks) — while silently omitting the ~50% dropout rate, the 17%-vs-25% access gap, the 38% entry-based recovery rate, and the £72-per-session estimate that sit in the same year’s data.

Derby and Derbyshire’s reply matters because it shows the evasion is not just about which year gets cited — it is about which figures within a year get quoted. 

4. Redirect to NHS England

In a distinct move from outright denial, rather than disputing the letter’s claims several replies decline to engage at all and push the question upward. Dorset’s reply does this three times in succession, on the three most pointed accountability questions:

“NHS England sets the performance metrics, targets and the associated definitions… It is recommended that this query is redirected to NHS England. — Dorset ICB, on why TT claims to meet its targets, why recovery is measured against completion rather than entry, and why there is no independent audit”

Somerset and North East London use the same move on some of the same questions, but with more context attached — naming the specific national manual or commissioning structure responsible, rather than simply pointing elsewhere. North East London is unusual in stating upfront, in its cover paragraph, exactly which questions (three, four, six and eight) it intends to redirect, rather than burying the deflection inside a wandering non-answer.

Mental Health Action’s own follow-up to Dorset makes the underlying point directly.  Repeatedly redirecting to NHS England is itself evidence of the centralised control this campaign is concerned about, since it leaves no local body answerable for whether the targets it has been set are being met, or whether they are even realistic.

5. Reframing the number itself

Bedfordshire, Luton and Milton Keynes produces a genuinely distinct move on the dropout question — not disputing the figure, and not switching the year, but arguing the number does not mean what it appears to mean. It describes Talking Therapies as an intentionally “open access… no wrong door” service, so that outreach sessions and initial assessments count as people being served even when they never receive any treatment.  It suggests some of the 23,800 people counted as having “dropped out” are in fact recovering through “waiting well” strategies or getting help privately – reframing drop-out as a form of engagement rather than treating it as a failure to be explained.

6. The empty complete reply

Kent and Medway’s FOI response is procedurally faultless — it answers all ten numbered questions, as an FOI request legally requires — and says almost nothing. No local figures, no named programmes, no local specifics anywhere across all ten answers. It is worth distinguishing this from the denial-script replies and the thin one-paragraph replies (Lincolnshire, Derby, Nottingham): this is a different failure mode, where the form of a complete answer is used to avoid supplying its substance.

West Yorkshire’s reply is the inverse failure mode: no numbered question structure, and the most data-free reply in the whole set — not even a favourable current-year snapshot, just a claim to “tend to meet” recovery and improvement targets while conspicuously not mentioning access or waiting-time targets, which is exactly where the ICB’s own underlying figures are worst (17.5% access against a 25% target; a 48-day average second-session wait).

7. Who signs the letter

Signatories range from Chief Executives writing in their own name — David Jarrett at BNSSG, Ed Garratt OBE at SNEE, Zina Etheridge at North East London, Dean Spencer at Dorset — down to entirely anonymous replies. Derby and Derbyshire is signed only “Enquiry Officer, Enquiries Team.” Nottingham and Nottinghamshire’s reply carries no individual name at all, only the organisation’s. There is a rough, though not perfect, correlation between seniority of signatory and substance of reply: the two most substantive replies in the set (Somerset and North East London) both carry named, senior signatories, while several of the thinnest (Derby, Nottingham, Lincolnshire) are anonymous or junior. Worth testing this pattern more rigorously if the final report wants to make the point explicitly.

8. Only escalation gets an answer

At least four ICBs produced no response whatsoever to the original open letter, and only answered after we escalated — a follow-up prompt, or a formal Freedom of Information request: Kent and Medway (silent until an FOI request), Somerset (an FOI response from the start), Lincolnshire, and Frimley (whose only response was from a provider, not the ICB, after a second letter). BNSSG answered the original letter but only with a content-free holding response, and redirected to NHS England, after being chased. Taken together with the 19 ICBs who never responded even to a prompt, this suggests the open letter alone, unescalated, is the “weakest lever” the campaign has had for extracting any answer at all — worth stating in the report’s conclusions, and worth considering as a practical point for any future phase of the campaign.

9. The exceptions: replies that actually engaged

Two replies stand out from everything above. Somerset’s FOI response answers all ten questions, roughly six of them with genuine local specificity — named services (a commissioned LGBTQ+ service, “2BU”), named frameworks (PCREF), and a real, falsifiable explanation for why it cannot give a cost-per-session figure (a block contract, not commissioned per case). North East London’s reply, signed personally by its Chief Executive, is similarly detailed — the most extensive named list of therapy modalities in the whole set, concrete and specific answers on inequalities work, and an unusual candour about which questions it intends not to engage with, stated upfront rather than buried.

Lancashire and South Cumbria’s provider reply (LSCFT, not necessarily the ICB itself — see the open question below) sits in between: genuinely detailed and self-critical on several questions — it is the only reply anywhere in the set to concede outright that no independent audit exists, and the only one to supply an official, sourced cost-per-session figure — but undermines that credibility with one glaringly evasive answer on waiting times, sitting a few lines from the very figures it contradicts.

Sussex’s FOI response, though it answers only three of the ten questions, is comparably strong on the ground it does cover: the most detailed answer on community-tailoring of any reply in the set, and no denial-script language anywhere. Its cost figures turned out to need unpicking — see the Sussex entry below — but the underlying substance of its inequalities and community-engagement answers stands on its own.

Devon’s content, obtained only via an MP’s separate correspondence rather than sent to Mental Health Action directly, is also worth naming here: it is one of the few pieces of correspondence in the whole campaign to openly disclose an unfavourable figure (a first-treatment wait above the national average) rather than omit it.

Part Two: ICB Reorganisation During the Campaign

The campaign’s structure assumed one letter, one ICB, one reply. Reality has been messier: seven of the original 42 letters have been affected by mergers, dissolutions, or commissioning transfers that took place after the letters went out, some of them mid-correspondence. (Claude speak here! “This matters for how the final report should present the results — a merged or dissolved ICB’s silence, or its successor’s silence, should not read as a contradiction or an error”).

1. Frimley → Hampshire and Isle of Wight ICB. TalkPlus, the provider delivering Talking Therapies for the North East Hampshire and Farnham population, says commissioning responsibility for that population transferred from Frimley ICB to Hampshire and Isle of Wight ICB. Unverified against NHS England’s own record of the change — see the open question below. Frimley ICB itself has not substantively responded, and neither has Hampshire and Isle of Wight.
2. Coventry and Warwickshire + Herefordshire and Worcestershire, now branded “Happy Healthy Lives.” The two ICBs describe themselves as having “recently clustered” and answered jointly in one letter.
3. North West London + North Central London merger, confirmed by North Central London’s reply arriving under the letterhead of a new combined body.
4. Suffolk and North East Essex (SNEE) dissolved 1 April 2026, splitting into a new NHS Norfolk and Suffolk ICB (which absorbed Suffolk) and a new NHS Essex ICB (which absorbed the north-east Essex portion).
5. North Central London’s successor is now named NHS West and North London ICB — confirmed by the signatory on its reply, which came under that letterhead while the subject line still referred to the old “North Central London” area.
6. Cambridgeshire and Peterborough, Bedfordshire/Luton/Milton Keynes, and Hertfordshire and West Essex merged, as of 1 April 2026, into a single new Central East ICB. This is the most complicated of the seven: it folds three of the original 41 letters into one successor body, with three very different outcomes attached — Bedfordshire, Luton and Milton Keynes gave a full reply before the merger; Hertfordshire and West Essex never responded, and its follow-up prompt (sent after the merger) may have reached an address that no longer functioned in its original form; Cambridgeshire and Peterborough produced nothing but an automated notice about the merger itself.
7. Norfolk and Waveney ICB, confirmed to have operated July 2022 to April 2026 before merging into the same new Norfolk and Suffolk ICB that absorbed Suffolk and North East Essex. Two of the original 42 letters — Suffolk and North East Essex, and Norfolk and Waveney — now run through the same successor body, which has so far sent only a holding response.

Letters caught up in a merger are kept as separate entries in the detailed breakdown below, grouped under a note naming the successor body, rather than collapsed into a single row. This keeps each original letter’s own outcome visible rather than letting one ICB’s engagement (or silence) be diluted by another’s.

 

Part Three: Region-by-Region Detail

Full detail on every one of the 41 ICB responses/non-responses, grouped by region as the original campaign was organised. Shropshire, Telford and Wrekin — excluded from all counts — is noted at the end of this section for completeness.

East

Bedfordshire, Luton and Milton Keynes

SUBSTANTIVE REPLY  —  29 Oct 2025

Signed by Maureen Walton, Enquiries and Experience Manager. All ten questions addressed, but most answers are thin. Uses the shared national statistics block and switches to 2024/25 figures on the targets question rather than engaging with 2023/24. Flatly declines to give a cost figure (“does not hold this information”). Names no actual therapy modalities, pointing only to the national manual.

The one distinctive move: rather than disputing the 23,800-person dropout figure, argues the figure itself is misleading, since the service’s open-access, self-referral design means outreach contacts and assessments count as people being served even without structured treatment — see the reframing pattern above.

Now part of the new Central East ICB merger — see Part Two.

Cambridgeshire and Peterborough

PARTIAL / NON-SUBSTANTIVE CONTACT  —  automated notice, undated

No answer to any question. The only response received is an automated notice that the ICB merged into the new Central East ICB on 1 April 2026, directing all enquiries to the successor body’s website.

Now part of the new Central East ICB merger — see Part Two.

Hertfordshire and West Essex

NO RESPONSE  —  chased 30 May 2026

No reply to the original letter or the follow-up prompt. The prompt postdates the 1 April 2026 Central East ICB merger, so it may not have reached a functioning address. Now part of the new Central East ICB merger — see Part Two.

Mid and South Essex — chased (exact date not yet supplied), no reply to the original letter or the follow-up prompt.

Norfolk and Waveney

SUBSTANTIVE REPLY  —  no reply before merger; successor substantive reply 27 Aug 2026

Confirmed to have merged into the new Norfolk and Suffolk ICB in April 2026 — the same successor body Suffolk and North East Essex merged into. No substantive reply was received before the merger. The successor’s 27 Aug 2026 reply (see Suffolk and North East Essex, below) explicitly answers the chase emails sent to both former Norfolk and Waveney and former Suffolk and North East Essex at once.

Suffolk and North East Essex (SNEE)

SUBSTANTIVE REPLY  —  8 Sept 2025; successor substantive reply 27 Aug 2026

Signed Ed Garratt OBE, Chief Executive. Answers for SNEE ICB and two provider trusts (EPUT and NSFT) in one letter. Opens with the denial-script line (“is not recognised within this system”), then substitutes the shared national statistics block for any local figures — no local dropout, access, recovery, or cost data anywhere, despite the original letter being built entirely from SNEE-specific figures. None of the ten questions answered.

SNEE was dissolved 1 April 2026; Suffolk transferred into the new Norfolk and Suffolk ICB (see Norfolk and Waveney, above), the north-east Essex portion into a new NHS Essex ICB.

The successor Norfolk and Suffolk ICB sent a holding response on 18 Aug 2026 (signed Hayley Collins, Patient Experience Officer), then a substantive reply on 27 Aug 2026, signed again by Ed Garratt OBE, explicitly covering the chase emails sent to both former SNEE and former Norfolk and Waveney at once. That reply is, in substance, the same text as the original 8 Sept 2025 SNEE reply — same denial-script opening, same national statistics block, word for word — still none of the ten questions answered. A striking example of an ICB reusing near-identical boilerplate across two separate original letters and chase emails nearly a year apart.

London

North Central London (replying as West and North London ICB)

SUBSTANTIVE REPLY  —  18 Aug 2026

Confirms the North West/North Central London merger — the combined body now trades as West and North London ICB. Uses the denial script (“we do not recognise a number of the interpretations and conclusions presented”) and reproduces the shared national statistics block near-verbatim — the third close repetition of that exact figure set logged in this campaign. No local London figures of any kind, and none of the ten questions answered.

An earlier holding message was received on 18 June 2026, two months before this substantive reply.

North East London

SUBSTANTIVE REPLY  —  10 Sept 2025

Signed personally by Zina Etheridge, Chief Executive — one of the two most substantive replies in the whole campaign, alongside Somerset. Unusually transparent: states upfront, in its cover paragraph, exactly which questions (three, four, six and eight) it intends to redirect to NHS England, rather than burying the deflection.

Names nine distinct therapy modalities — the most extensive list of any reply — though most remain manualised, time-limited interventions within the same behavioural framing as the therapies named elsewhere, rather than the longer-term relational work the letters are asking about.

Strong, specific answers on inequalities and community tailoring: named community engagement workers, mosque-based delivery, co-produced interventions for named communities, and a rare claim of measurable improvement in deprived-area outcomes.

North West London — chased 7 June 2026 (reportedly merging into the same successor body as North Central London — see Part Two), no reply to the original letter or the follow-up prompt.

South East London

PARTIAL / NON-SUBSTANTIVE CONTACT  —  acknowledgment only, 8 June 2026

Not a substantive reply. The Patient Experience Team states the request has been “escalated to Commissioners… to arrange a direct response.” No data, no answers, no timeline.

South West London — chased 28 May 2026, no reply to the original letter or the follow-up prompt.

Midlands

Birmingham and Solihull — chased 14 June 2026, no reply to the original letter or the follow-up prompt.

Black Country — chased (exact date not yet supplied), no reply to the original letter or the follow-up prompt.

Coventry and Warwickshire / Herefordshire and Worcestershire

SUBSTANTIVE REPLY  —  22 June 2026, joint reply

Signed Simon Trickett, Chief Executive, on behalf of both ICBs, which describe themselves as having “recently clustered” and now trade as “Happy Healthy Lives.” Uses the denial script (“we do not share your assessment that the NHS Talking Therapies service is a failing service”) — the third instance of that framing logged.

More polished and specific than the other denial-family replies: the fullest named list of therapy modalities of any reply (six named types), and a genuine, specific concession — the clearest of any ICB — that there are “challenges in some areas relating to waiting times between first and subsequent appointments,” exactly the hidden second-session-wait problem that runs through the original letters.

On the therapy list itself: though the six modalities carry different names, they can reasonably be argued to share a fundamentally behavioural framing — short-term, manualised, protocol-driven interventions within the same stepped-care model — rather than the genuinely diverse, longer-term, relational therapy the original letters are asking about.

Still gives no local dropout, access, or cost figures, and does not engage with the entry-based recovery methodology.

Derby and Derbyshire

SUBSTANTIVE REPLY  —  no reply to original; 2 July 2026 after prompt

Signed only “Enquiry Officer, Enquiries Team” — no named individual. Thin, generic, none of the ten questions addressed even implicitly.

Uses the correct year, 2023/24, but only cites the flattering metrics within it (85% assessed within six weeks; 50% of completers recovered; 69% improved) while silently omitting the same year’s dropout rate, access gap, entry-based recovery rate, and cost estimate. A clear instance of cherry-picking within the right year, distinct from switching years altogether.

Herefordshire and Worcestershire

SUBSTANTIVE REPLY  —  22 June 2026

See Coventry and Warwickshire, above — the two ICBs replied jointly in one letter as the “Happy Healthy Lives” cluster.

Leicester, Leicestershire and Rutland — chased 14 June 2026, no reply to the original letter or the follow-up prompt.

Lincolnshire

SUBSTANTIVE REPLY  —  no reply to original; 15 July 2026 after prompt

Signed Heather Drabble, Complaints Administrator. The shortest and thinnest reply in the whole campaign — four short paragraphs, no numbered structure, not one of the ten questions engaged with even implicitly.

Cites only current in-year (2025/26) figures — none of MHA’s 2023/24 dropout, cost, audit, or inequality analysis is acknowledged or disputed, simply superseded by different-year headline numbers.

Northamptonshire — chased 14 June 2026, no reply to the original letter or the follow-up prompt.

Nottingham and Nottinghamshire

SUBSTANTIVE REPLY  —  17 June 2026

Signed only “Nottingham and Nottinghamshire ICB” — no individual named at all. Opens with the clearest, closest-to-verbatim instance of the shared denial script in the whole set (“does not recognise Mental Health Action’s interpretation of the NHS Talking Therapies data”), then the shared national statistics block plus a local-figure version of the same “additional X people by 2028/29” expansion claim used nationally elsewhere.

None of the ten questions addressed. The 12,935-people figure quoted is very likely a completed-courses-only count presented without that context, roughly a third of the 37,370 people originally referred per the original open letter — a framing-through-omission rather than a factual error, but worth describing precisely as that.

Healthwatch Nottingham and Nottinghamshire later wrote to Mental Health Action independently, and reached the same conclusion unprompted: that this reply “largely restates headline service figures rather than addressing the ten specific questions raised.” See Part Four.

Shropshire, Telford and Wrekin

PARTIAL / NON-SUBSTANTIVE CONTACT  —  excluded from this report

No substantive open letter was sent to Shropshire, Telford and Wrekin — the underlying NHS data for the area was internally inconsistent, and no reliable analysis could be built. Excluded from every count and calculation in this report by design, not because of any failure to respond.

Staffordshire and Stoke-on-Trent — chased 1 June 2026, no reply to the original letter or the follow-up prompt.

North East and Yorkshire

Humber and North Yorkshire — chased 7 June 2026, no reply to the original letter or the follow-up prompt.

North East and North Cumbria — chased 7 June 2026, no reply to the original letter or the follow-up prompt.

South Yorkshire — chased 15 June 2026, no reply to the original letter or the follow-up prompt.

West Yorkshire

SUBSTANTIVE REPLY  —  9 June 2026

Signed Mary Jo Pearson, Senior Communications Lead. The most data-free reply in the whole campaign — no percentages, no headcounts, no figures of any kind, not even a favourable current-year snapshot.

Claims only to “tend to meet” the reliable recovery and reliable improvement targets — conspicuously not mentioning the access target or the waiting-time target, which are exactly where the ICB’s own underlying figures are worst. One genuine, if vague, concession: acknowledges the targets “do not tell the whole story of access and outcomes for people,” without ever stating the entry-based figure directly.

North West

Cheshire and Merseyside — chased 15 June 2026, no reply to the original letter or the follow-up prompt.

Greater Manchester — chased 15 June 2026, no reply to the original letter or the follow-up prompt.

Lancashire and South Cumbria

SUBSTANTIVE REPLY  —  18 Sept 2025

Reply from Lancashire and South Cumbria NHS Foundation Trust (LSCFT), the provider delivering Talking Therapies — signed Tracy Cook-Scowen, Director of Operations — rather than confirmed to be from the ICB itself. The letter notes Mental Health Action wrote separately to the ICB; whether a distinct ICB reply exists is an open question, flagged below.

By far the most detailed reply in the campaign on several individual questions: the only reply anywhere to concede outright that no independent audit exists, the only one to supply an official, sourced cost-per-session figure (£199, closely matching Mental Health Action’s own £216 estimate), and the first to name real alternative modalities (EMDR, Interpersonal Therapy, Person-Centred Experiential Counselling, Couples Therapy) rather than assert compliance in the abstract.

Undermines that credibility on the targets question: claims to “consistently meet” waiting-time standards immediately after quoting Mental Health Action’s own figures, drawn from the same letter, showing an 8,800-person, 50-day-average second-session wait — reconciled only by switching to 2025/26 and 2024/25 figures rather than engaging with the 2023/24 entry-based analysis actually being asked about.

Questions nine and ten (inequalities and community tailoring) are missing from the letter as supplied — worth checking whether a further page exists.

South East

Buckinghamshire, Oxfordshire and Berkshire West — chased 30 May 2026, no reply to the original letter or the follow-up prompt.

Frimley

PARTIAL / NON-SUBSTANTIVE CONTACT  —  provider reply only, 2 June 2026

The only response received is from TalkPlus (North Hampshire Urgent Care), the commissioned provider — not Frimley ICB itself. TalkPlus states it believes it was included in error, that it never received the original letter, and that commissioning responsibility for its area transferred to Hampshire and Isle of Wight ICB. It declines to answer substantively and defers to “the intended recipient, Frimley ICB.”

Frimley ICB itself has not responded. The claimed commissioning transfer is unverified against NHS England’s own boundary records — see the open question below.

Hampshire and Isle of Wight — chased (exact date not yet supplied), no reply to the original letter or the follow-up prompt.

Note: Hampshire and Isle of Wight is the body TalkPlus named as the correct recipient for Frimley’s North East Hampshire and Farnham population (see above) — it has itself not responded to either its own original letter or the follow-up prompt.

Kent and Medway

SUBSTANTIVE REPLY  —  FOI response, 8 July 2026

No response at all to the original open letter; this reply followed a formal Freedom of Information request Mental Health Action filed after the letter went unanswered. Opens with a near-verbatim match to SNEE’s denial-script line, then the same shared national statistics block, word for word in the same order.

Procedurally complete — all ten questions technically answered, as an FOI request legally requires — but with essentially no local content anywhere: no local figures, no named programmes, no local specifics in any of the ten answers. The least forthcoming answer of any reply on cost, declining to give any figure at all.

Surrey Heartlands — chased 7 June 2026, no reply to the original letter or the follow-up prompt.

Sussex

SUBSTANTIVE REPLY  —  FOI response to prompt, 27 Oct 2025

Handled as a Freedom of Information request (ref FOI 51522 SX QNX), answering only three of the ten questions — cost of a completed course, work on inequalities, and plans to attune services to different communities. Whether the remaining seven were answered elsewhere is not yet confirmed.

Does not use the denial script anywhere, and does not contest Mental Health Action’s premise. The document also reproduces Mental Health Action’s own question text verbatim in places — both the cost comparison and the inequality statistics that appear early in the document are Mental Health Action’s own figures being quoted back as context, not ICB admissions, confirmed with Paul.

The ICB’s own cost answer — £39.1M spent in 2024/25 against 17,955 “completed treatments,” giving £2,177 per completed treatment — swaps in a different NHS Digital metric from the one Mental Health Action’s £212-per-session figure uses, not just a different year. Reworked on a basis consistent with Mental Health Action’s own methodology, the ICB’s own numbers come out above £300 per session — meaning Sussex’s own data, taken on its own terms, suggests the original £212 estimate was if anything too low.

The genuine substance of Sussex’s answers on inequalities and community-tailoring is strong — the most detailed answer on community-tailoring of any reply in the whole campaign: interpreters, translated assessment tools, leaflets in the ten most common local languages, a dedicated refugee and asylum-seeker referral line, and named outreach work targeting access for men and older adults.

South West

Bath and North East Somerset, Swindon and Wiltshire — chased 2 June 2026, no reply to the original letter or the follow-up prompt.

Bristolcs, North Somerset and South Gloucestershire (BNSSG)

SUBSTANTIVE REPLY  —  14 Oct 2025, second reply 7 July 2026

Signed David Jarrett, first as Chief Delivery Officer, later as Chief Strategic Commissioning Officer (worth checking whether that is a real title change). Treated throughout as a formal complaint response.

The first reply engaged, if selectively, with current data — July and August 2025 monthly snapshots and demographic breakdowns — rather than the 2023/24 annual, entry-based figures the letter was built on. None of the ten questions were addressed.

After Mental Health Action’s chase email (28 May 2026, rejecting the first reply as a non-response), the second reply was markedly worse, not better: zero data of any kind, pure boilerplate, and an explicit redirect of several questions to NHS England on the grounds that they concern “national policy and programme design” BNSSG “cannot amend or redefine locally.” Quality of engagement declined after being chased, rather than improving.

The wide cc list on this thread produced real political engagement: Carla Denyer MP’s office called the first reply “unsatisfactory” and offered to follow up, and Kerry McCarthy MP wrote personally and in detail — see Part Four.

Cornwall and The Isles Of Scilly — chased (exact date not yet supplied), no reply to the original letter or the follow-up prompt.

Devon

PARTIAL / NON-SUBSTANTIVE CONTACT  —  no direct reply — content via Steve Race MP

Devon ICB has not responded to Mental Health Action directly. The only content available is Devon ICB’s reply to a separate letter from Steve Race MP, forwarded on by his office.

Notably candid by comparison with most direct ICB replies: gives the correct 2023/24, entry-based figures Mental Health Action’s own analysis uses, and openly discloses a worse-than-average first-treatment wait (29.2 days against an 18-day national average) rather than omitting it. Only afterwards adds more favourable 2024/25 figures as a supplement, not a substitute — a materially more honest use of the year-switch than most other ICBs. No denial-script language.

OPEN QUESTION, still awaiting your decision: does a reply obtained only via an MP’s separate correspondence, never sent to Mental Health Action, count as an ICB “reply” for the response-rate arithmetic, or should Devon remain classified as a non-responder to Mental Health Action specifically, with this content used only as supporting material? Currently held as flagged pending your steer.

Dorset

SUBSTANTIVE REPLY  —  23 Dec 2025; follow-up reply 22 Jul 2026

Signed Dean Spencer, Chief Operating Officer. All ten questions addressed. No denial script and no shared statistics block — instead redirects the three most pointed accountability questions (targets met, completion- vs entry-based recovery, no independent audit) straight to NHS England, three times in succession.

One of the only replies anywhere to directly dispute Mental Health Action’s own numbers rather than sidestep them: recalculates a 37.0% non-engagement rate against the roughly 50% dropout figure in the original letter. Mental Health Action has since confirmed this was a genuine error in its own letter template, not corrected for Dorset’s actual figures — Dorset’s 37.0% stands.

Mental Health Action wrote back to Dorset directly, introducing a new Dorset-specific figure (roughly 13% of local prevalence reached, against an implied 25% target) and challenging Dorset’s “service user choice” explanation for dropout as itself evidence of a structural gap in the service, rather than a neutral choice.

Dorset’s follow-up reply (22 Jul 2026) does not confirm or dispute the 13% figure — instead it says the prevalence-coverage access measure “is from a few years ago” and has been replaced by “a new access metric related to the number of patients discharged having been treated,” on which Dorset claims to have “exceeded the fair share allocation access figure in 25-26.” A clean instance of switching the metric rather than engaging with the figure asked about. On dropout, it does not address the longer-term-therapy-shortage point; instead it attributes much dropout to factors “outside the service’s control” and adds an unsupported, uncited claim that “many do come back to the service in future, going on to complete a course of therapy.”

Gloucestershire

PARTIAL / NON-SUBSTANTIVE CONTACT  —  acknowledgment only, 2 June 2026

Not a substantive reply. Sophie Hopkins, Communications Manager, states the ICB could not find any record of the original letter, sent 29 October 2025 — it appears to have been lost internally rather than reviewed and set aside. Now passed to the lead commissioner for adult mental health. A different kind of administrative failure from the deflection patterns seen elsewhere, though the practical effect is the same: over seven months with no engagement until chased.

Somerset

SUBSTANTIVE REPLY  —  FOI response, 18 Nov 2025

The most substantive reply of the whole campaign, alongside North East London — the only ICB reply, together with North East London, to answer all ten questions with a genuine mix of real local content and honestly-explained deflection.

Names specific initiatives no other reply matches: implementation of the Patient and Carer Race Equality Framework, a commissioned LGBTQ+ service (“2BU”), outreach built into the maternal mental health service, and a named alternative pathway for longer-term therapy (the Specialist Psychological Interventions Service) — the first reply anywhere to point to where longer-term therapy is actually meant to sit.

On cost, gives the first substantive, falsifiable explanation for why no clean figure exists: Talking Therapies in Somerset is commissioned on a block contract, not cost-per-case, with the funding envelope covering non-intervention costs too. Where it does redirect to NHS England (on targets and recovery methodology), it explains why, rather than simply pointing elsewhere with no context.

Signed Jade Renville, Director of Corporate Services and Affairs — a working-level signatory, consistent with this being an FOI response rather than an executive complaint reply.

Part Four: External Corroboration — MPs and Healthwatch

Alongside the ICB replies, a number of MPs and one Healthwatch body have written in independently. None of this counts against the 41-ICB response tally, but it is useful supporting material for the report, and one piece of it is significant enough to stand on its own.

Healthwatch Nottingham and Nottinghamshire — 18 June 2026

The single most significant piece of external corroboration gathered so far. Commenting on the Nottingham and Nottinghamshire ICB reply, Healthwatch reached, independently and unprompted, the same conclusion this analysis has been reaching throughout:

“[The ICB’s response] largely restates headline service figures rather than addressing the ten specific questions raised in your letter.”

This is a statutory patient-champion body, not a campaigning organisation, reaching the same critical assessment of reply quality. Healthwatch also asked whether Mental Health Action had considered a Freedom of Information request on the harder factual questions (cost per completed course, absence of independent audit, outcomes for people who don’t complete treatment), asked whether Mental Health Action had heard from service users directly, and offered a call with their Chief Executive and their Lead for Data and Intelligence. Paul has accepted that offer; a call is pending for early September 2026.

MP correspondence

Four MPs have written in, ranging from brief supportive acknowledgment to substantive engagement with the underlying policy questions.

• Stella Creasy MP (Walthamstow, within North East London ICB’s area), 31 July 2025 — a supportive acknowledgment, forwarding Mental Health Action’s letter to the ICB directly and asking to be kept posted if nothing came of it.
• Manuela Perteghella MP (Stratford-on-Avon), 31 Aug 2025 — asked to be sent Coventry and Warwickshire’s response once received.
• Ellie Chowns MP (North Herefordshire), 19 Aug 2025 — went further than a simple acknowledgment, offering to table written parliamentary questions to government on these issues if Mental Health Action wanted, and asking for suggested question text. A live, unactioned opportunity worth revisiting.
• Carla Denyer MP (Bristol Central), 24 Sept 2025 — the most substantive of the four. Pointed to an existing written parliamentary question already on the record about NHS mental health delays, a Parliamentary debate on the Darzi report where a Green colleague raised funding directly, and a Green-backed amendment calling for increased health and social care investment. Offered to raise follow-up queries with local NHS services or directly with the Minister for Health.
• Kerry McCarthy MP (Bristol East), 8 December 2025 — engaged personally and in detail with BNSSG’s case, though not uncritically: pushed back on framing services as “failing” given they help many people, while independently raising real points the ICB replies hadn’t touched, including a specific hypothesis that CBT can fail neurodivergent people, and a concrete theory that high drop-out is partly driven by people being routed into group therapy as a gateway to one-to-one help when they wanted the latter from the start.

Read together, the MP correspondence and Healthwatch’s intervention suggest the wide cc list used throughout the campaign — MPs, Healthwatch branches, scrutiny committees — has generated real engagement beyond the ICBs themselves, even where the ICBs’ own replies have not.

Part Five: Open Questions Before This Becomes a Finished Report

A short list of points still needing input or verification.

1. Devon: does the reply obtained only via Steve Race MP count as an ICB “reply” for the response-rate arithmetic, or should Devon stay classified as a non-responder to Mental Health Action, with the content used only as supporting material?
2. Lancashire and South Cumbria: is the LSCFT reply the ICB’s own answer, or only the provider trust’s? The letter itself implies a separate ICB reply may exist — has one arrived? Also worth checking whether a further page exists covering questions nine and ten, which are missing from the copy on file.
3. Frimley / Hampshire and Isle of Wight: TalkPlus’s claim that Talking Therapies commissioning for its area transferred from Frimley ICB to Hampshire and Isle of Wight ICB is unverified against NHS England’s own boundary-change records. Worth confirming before the report states it as fact, especially since Hampshire and Isle of Wight has itself not responded to either the original letter or the prompt.
4. Gloucestershire: is there a substantive reply since the 2 June 2026 acknowledgment (which said the original letter had been lost internally and passed to the lead commissioner), or is that still the most recent contact?
5. David Jarrett’s title at BNSSG changed between the first reply (“Chief Delivery Officer”) and the second (“Chief Strategic Commissioning Officer”) — worth checking whether that reflects a real role change or just inconsistent letterhead, in case it’s relevant to how the report describes continuity of engagement.
6. Bedfordshire, Luton and Milton Keynes, Kent and Medway, and others were logged from pasted text without every process detail Paul may hold elsewhere (e.g. whether BLMK’s reply followed the original letter or a prompt) — worth a final pass to confirm nothing is missing before publication.

Appendix: Full Response Status Table

All 41 ICBs counted in this report, plus Shropshire, Telford and Wrekin for completeness. Sorted by region, matching the order used in Part Three.

Region	ICB	Status	Date / note
East	Bedfordshire, Luton and Milton Keynes	Replied	29 Oct 2025
East	Cambridgeshire and Peterborough	Partial / notice only	merger notice only
East	Hertfordshire and West Essex	No response	chased 30 May 2026
East	Mid and South Essex	No response	chased, date tbc
East	Norfolk and Waveney	Replied	merged into Norfolk and Suffolk ICB; successor reply 27 Aug 2026
East	Suffolk and North East Essex	Replied	8 Sept 2025 (SNEE); successor reply 27 Aug 2026
London	North Central London	Replied	18 Aug 2026 (as West and North London ICB)
London	North East London	Replied	10 Sept 2025
London	North West London	No response	chased 7 June 2026
London	South East London	Partial / notice only	acknowledgment only, 8 June 2026
London	South West London	No response	chased 28 May 2026
Midlands	Birmingham and Solihull	No response	chased 14 June 2026
Midlands	Black Country	No response	chased, date tbc
Midlands	Coventry and Warwickshire	Replied	22 June 2026 (joint reply)
Midlands	Derby and Derbyshire	Replied	2 July 2026
Midlands	Herefordshire and Worcestershire	Replied	22 June 2026 (joint reply)
Midlands	Leicester, Leicestershire and Rutland	No response	chased 14 June 2026
Midlands	Lincolnshire	Replied	15 July 2026
Midlands	Northamptonshire	No response	chased 14 June 2026
Midlands	Nottingham and Nottinghamshire	Replied	17 June 2026
Midlands	Shropshire, Telford and Wrekin	Partial / notice only	excluded — no substantive letter sent
Midlands	Staffordshire and Stoke-on-Trent	No response	chased 1 June 2026
North East and Yorkshire	Humber and North Yorkshire	No response	chased 7 June 2026
North East and Yorkshire	North East and North Cumbria	No response	chased 7 June 2026
North East and Yorkshire	South Yorkshire	No response	chased 15 June 2026
North East and Yorkshire	West Yorkshire	Replied	9 June 2026
North West	Cheshire and Merseyside	No response	chased 15 June 2026
North West	Greater Manchester	No response	chased 15 June 2026
North West	Lancashire and South Cumbria	Replied	18 Sept 2025 (provider reply — ICB status TBC)
South East	Buckinghamshire, Oxfordshire and Berkshire West	No response	chased 30 May 2026
South East	Frimley	Partial / notice only	provider-only reply, 2 June 2026
South East	Hampshire and Isle of Wight	No response	chased, date tbc
South East	Kent and Medway	Replied	FOI response, 8 July 2026
South East	Surrey Heartlands	No response	chased 7 June 2026
South East	Sussex	Replied	FOI response, 27 Oct 2025
South West	Bath and North East Somerset, Swindon and Wiltshire	No response	chased 2 June 2026
South West	Bristol, North Somerset and South Gloucestershire	Replied	14 Oct 2025; 2nd reply 7 July 2026
South West	Cornwall and The Isles Of Scilly	No response	chased, date tbc
South West	Devon	Partial / notice only	MP-sourced only, not sent to MHA
South West	Dorset	Replied	23 Dec 2025; follow-up 22 Jul 2026
South West	Gloucestershire	Partial / notice only	acknowledgment only, 2 June 2026
South West	Somerset	Replied	FOI response, 18 Nov 2025