ICB complaint: how to complain to your NHS Integrated Care Board

What is an ICB — and what replaced CCGs?

An Integrated Care Board (ICB) is the statutory NHS body responsible for commissioning most NHS services within a defined geographic area of England. On 1 July 2022, 42 ICBs replaced the 106 Clinical Commissioning Groups (CCGs) under the Health and Care Act 2022. Each ICB covers a population of between roughly 500,000 and 3.5 million people and sits within an Integrated Care System (ICS) alongside local authorities and NHS trusts.

ICBs hold NHS contracts with GP practices, dental practices, community pharmacies, and opticians in their area. This contractual relationship is the key to understanding their complaints function: because ICBs commission GP practices, they have both the power and the legal obligation to handle complaints about primary care services when a patient chooses to complain to the commissioner rather than the provider.

You can find which ICB covers your area using the NHS England ICB directory. Each ICB has a dedicated complaints team, typically reachable by email and post.

When to complain to the ICB

The ICB route is usually more appropriate than a practice-level complaint in the following circumstances:

• The decision originates with the ICB, not the clinician. If your GP refused to fund a treatment, medication, or referral because of an ICB commissioning policy — for example a blanket restriction on prescribing a drug, or an Individual Funding Request refusal — the ICB made the decision. The GP is following instructions. Complaining to the practice achieves little; complaining to the ICB challenges the policy.
• Your Right to Choose referral has been blocked or ignored. Right to Choose is a nationally mandated entitlement. If your GP practice has refused to make a Right to Choose referral, or the ICB has created a local policy restricting it, the ICB is the commissioner responsible for ensuring the entitlement is honoured.
• There is a conflict of interest at practice level. At a small or rural practice where you are one of a handful of patients, complaining in-house carries a real risk of relationship damage. The ICB provides a step removed from the treating clinician.
• You want to complain about how the practice handled your practice-level complaint. Meta-complaints about complaint handling can go to the ICB, which oversees primary care complaints management.
• Your complaint involves multiple providers. ICBs can coordinate cross-provider complaints where the problem spans, for example, a GP and a community pharmacy both commissioned by the same ICB.

When to complain to the GP practice first

For the majority of individual clinical care complaints — a GP who dismissed your symptoms, a delayed referral, a prescription error, or a rude consultation — complaining directly to the GP practice under the NHS Complaints (England) Regulations 2009 is usually faster and more productive. The practice manager or the designated complaints handler must acknowledge your complaint within three working days, investigate it, and provide a substantive written response.

Complaints to the practice also produce a formal written response on the practice letterhead, which can be quoted in any subsequent ICB or PHSO escalation. A written GP response acknowledging a failure — even a partial one — is valuable evidence.

Remember: you cannot complain to both the practice and the ICB simultaneously about the same matter. Once you choose a route, you are committed to it until you reach the PHSO escalation stage.

NHS Complaints (England) Regulations 2009: the legal timetable

The NHS Complaints (England) Regulations 2009 set legally binding obligations on every NHS body, including ICBs. The key deadlines are:

• 3 working days: written acknowledgement of your complaint, confirming receipt, the name of the person handling it, and whether any third party needs to be involved.
• 25 working days (NHS target): substantive written response completing local resolution. This target is not a statutory deadline but is the NHS standard; if the ICB cannot meet it, they must write explaining why and give a revised date.
• 12 months time limit: complaints must be made within 12 months of the event, or within 12 months of the date you became aware of the cause for complaint. The ICB has discretion to extend this limit if there are good reasons for delay.
• Consent: if you are complaining on behalf of someone else, the ICB may require written consent from the patient unless the patient lacks capacity or is deceased.

Note that some ICBs now operate under local arrangements offering shorter response targets. Check your specific ICB's complaints policy on their website, as several have pledged 20 working days.

How to make your ICB complaint

ICB complaints can be made by letter, email, or telephone, though a written complaint (letter or email) is strongly recommended because it creates a paper trail and starts the formal clock.

Your complaint should include:

• Your full name, date of birth, NHS number (if known), and contact details.
• The name and address of the GP practice or service you are complaining about.
• A clear chronological account of what happened, including dates.
• The specific failures you are identifying — be precise about what was done or not done.
• What outcome you are seeking: an explanation, an apology, a service change, a review of a funding decision, or a combination.
• Any relevant supporting documents (appointment letters, test results, previous correspondence).

Free NHS Complaints Advocacy is available in every area, funded by your ICB. Advocates can help you draft the letter, attend meetings, and navigate the process at no cost to you. Search "NHS Complaints Advocacy [your area]" or ask the ICB for a referral.

Sample ICB complaint letter wording

The following structure works for most ICB complaints. Adapt the bracketed sections to your circumstances:

After the ICB responds

When the ICB sends its final response letter, read it carefully. The final response should:

• Address every point you raised in your complaint.
• Explain the findings of any investigation conducted.
• State clearly what, if anything, will be done differently as a result.
• Inform you of your right to escalate to the PHSO if you remain dissatisfied.

If the response does not address all your points, or contains factual errors, write back pointing out the gaps and asking for a supplementary response before escalating. Keeping the local process open, where possible, strengthens any subsequent PHSO referral — it demonstrates you gave the ICB every reasonable opportunity to resolve the matter.

Escalating to the Parliamentary and Health Service Ombudsman

If you have received a final response from the ICB and remain dissatisfied, you can refer your complaint to the Parliamentary and Health Service Ombudsman (PHSO). The PHSO investigates complaints about NHS bodies in England and is entirely free.

Key PHSO rules:

• You must have completed local resolution first — that is, received the ICB's final response letter.
• You normally have 12 months from the date of the final response to contact the PHSO, though this can be extended.
• The PHSO can require the NHS to provide remedies including financial compensation, apologies, changes to services, and clinical reviews.
• The PHSO does not take all complaints — it exercises discretion and prioritises cases where there is evidence of injustice and where local resolution has genuinely failed.
• Preparing a clear evidence pack — your complaint letter, the ICB's response, any clinical records, and a summary of the injustice suffered — significantly increases your chances of the PHSO accepting the case.

For complaints about clinical care decisions (as opposed to commissioning decisions), the ICB route and PHSO route both sit alongside your right to raise a concern with the General Medical Council (GMC) about individual doctors, or to seek legal advice about clinical negligence claims. These are separate processes and can run in parallel.

Frequently asked questions