Healthwatch Brighton and Hoves response to the consultation on the new NHS Online NHS trust

This document sets out Healthwatch Brighton and Hove’s formal response to the Department of Health and Social Care and NHS England consultation on the proposed new NHS Online Trust, a national digital‑first provider of elective NHS care. The Trust is intended to be established in June 2026, tested with patients from January 2027, and launched later in 2027 as part of the government’s ambition to expand virtual care and reduce waiting times.

Healthwatch Brighton and Hove welcomes the potential benefits of digitally delivered care, particularly improved convenience, reduced travel, faster access to appointments, and greater patient control over managing health conditions. Evidence from local and national research shows that the use of digital and remote consultations has increased steadily since the Covid‑19 pandemic, with around one‑third of NHS appointments now conducted remotely. Younger people in particular are more comfortable with phone and video consultations, especially for less complex issues.

However, the organisation stresses that significant sections of the population remain digitally excluded or digitally disadvantaged. Older people, people with disabilities, people from Black, Asian and minoritised ethnic backgrounds, people whose first language is not English, and those with complex physical or mental health needs are less likely to benefit from digital‑only services. Many people prefer face‑to‑face appointments for physical examinations, mental health issues, and sensitive or complex conditions. Healthwatch emphasises that digital services must complement, not replace, in‑person care.

Polling carried out locally in February 2026 shows mixed public opinion about the new Trust. Awareness of NHS Online is low, and people are divided over whether they would choose to be referred. Those who support the idea value speed, convenience, reduced travel, and having records in one place. Those who are opposed express concerns about quality of care, digital exclusion, data security, and the use of artificial intelligence. Many people want reassurance that transferring to NHS Online would not mean losing their place on a waiting list and that they could switch back to face‑to‑face care if needed.

Healthwatch identifies four types of digital users—non‑users, competent users who struggle with healthcare systems, potential users who need support, and recent users—and argues that these differences must inform the design of the new Trust. The organisation highlights widespread problems with the NHS App and other digital systems, including complex language, poor accessibility, confusing navigation, difficulty understanding test results, and lack of integration across services.

The response makes a series of recommendations. These include stronger promotion of the Trust and clearer explanation of its benefits, transparency and reassurance about data sharing and artificial intelligence, and giving patients meaningful control over their data and consent. It calls for substantial investment in digital skills training and community support, as well as improvements to the usability and accessibility of the NHS App. Communications must meet the Accessible Information Standard and be available in plain language and multiple formats.

Healthwatch also argues that patient feedback must be central to the Trust’s development and operation. It recommends ongoing engagement with local Healthwatch organisations, the use of deliberative engagement methods, and the creation of a senior leadership role focused on patient experience. Feedback should go beyond simple satisfaction surveys and include qualitative methods such as interviews and focus groups.

Concerns are raised about equity of access across regions, the clarity of referral processes, the role and support of GPs, data security, staffing capacity, and how carers will be able to access information and appointments on behalf of others. The organisation stresses the importance of clear communication about referrals, waiting lists, patient responsibilities, and how care will transfer between local services and the national Trust.

Finally, Healthwatch highlights weaknesses in current complaints systems and urges the new Trust to adopt a simpler, more consistent, and better‑resourced approach to feedback and complaints handling. Overall, the response supports the ambition of NHS Online but warns that without careful design, sustained engagement, and investment in inclusion and transparency, the new Trust risks widening inequalities rather than improving access to care.