How Serious Does NHS Maladministration Have to Be Before Chair Dr Priya Singh Investigates Chief Executive Dr Nick Broughton?
After the Parliamentary and Health Service Ombudsman found serious failures in the development of NHS Buckinghamshire, Oxfordshire and Berkshire West ICB's female sterilisation policy and in the way my complaint had been handled, I wanted to know what happened at leadership level.
In particular, I wanted to know whether Dr Nick Broughton, Chief Executive of NHS Thames Valley ICB, had faced any Board-level scrutiny or Fit and Proper Person Test consideration after giving me formal assurances about governance and evidence that, in my opinion, were fundamentally contradicted by what the Ombudsman later found.
I therefore wrote directly to Dr Priya Singh, Chair of NHS Thames Valley ICB, whose role includes overall accountability for the organisation's Fit and Proper Person Test framework.
Her answer was remarkably clear: the Board and its committees had not considered leadership accountability following the Ombudsman's findings, and Dr Nick Broughton's FPPT status had not been reviewed, reassessed or discussed because of them.
I independently tested that answer through Freedom of Information. The ICB confirmed that it held no recorded information showing any FPPT review or consideration of Dr Broughton's suitability, fitness for role, leadership accountability, honesty, integrity or governance responsibility arising from the Ombudsman findings.
So the question for me became bigger than one NHS policy: what does accountability actually mean if serious maladministration can be independently established, senior leadership can have given assurances that do not survive external scrutiny, and nobody at Board level even formally considers whether there are leadership consequences?
The full correspondence and evidence are available in my Evidence Folder.
A note on language: I have previously explained why I personally regard some of the assurances I received from Dr Nick Broughton as in my own language - lies. That is my interpretation of the documentary discrepancies between what I was told by him and what the Ombudsman subsequently established.
Why did I ask Dr Priya Singh, Chair of NHS Thames Valley ICB, about Dr Nick Broughton's accountability?
By April 2026, the question I was asking had changed.
I was no longer only asking whether the female sterilisation policy was wrong.
The Parliamentary and Health Service Ombudsman had already investigated how the policy had been developed and how my complaint had been handled. Its findings included failures to properly weigh and balance evidence, failures to explore relevant evidence, failures to document and explain decisions, unexplained departure from relevant clinical guidance, unfair and inconsistent consideration of female and male sterilisation, and a failure to consult appropriately.
Those findings mattered to me for another reason.
During my original complaint, Dr Nick Broughton, then Chief Executive of BOB ICB and now Chief Executive of NHS Thames Valley ICB, had sent me a formal final response assuring me that the policy had gone through a "robust governance process" and a "full assessment" of relevant evidence, guidance, cost-effectiveness, legal and ethical considerations.
I have already examined that contradiction in detail in:
and:
The Gaps between NHS CEO Dr Nick Broughton's Claims & The Health Ombudsman's Findings
What is the NHS Fit and Proper Person Test — and why did I raise it with Dr Priya Singh, Chair of NHS Thames Valley ICB?
The NHS Fit and Proper Person Test, usually shortened to FPPT, exists because people holding Board-level power in healthcare are expected to meet standards that go considerably beyond simply having the right CV.
The NHS England FPPT Framework applies to executive and non-executive Board members of Integrated Care Boards, NHS trusts and foundation trusts, as well as NHS England and the Care Quality Commission.
Its stated purpose is to strengthen individual accountability and transparency and improve the quality of NHS leadership.
The framework considers whether Board members are of good character, possess the necessary competence, skills and experience, and remain suitable to exercise substantial authority within the health service.
Importantly, this is not merely an appointment check performed once and then forgotten.
A full FPPT assessment is also expected annually.
That distinction is important to what followed.
What does NHS England say Dr Priya Singh, Chair of NHS Thames Valley ICB, is responsible for?
The NHS England framework is unusually clear about this.
Ultimate accountability for adherence to the FPPT framework resides with the Chair of the NHS organisation.
The Chair must take reasonable steps to ensure the FPPT system is effective, ensure Board members continue to be suitable for their roles, oversee the relevant records and assessments, and ultimately conclude whether a Board member is fit and proper.
If concerns exist about a Board member who nevertheless remains in post, the framework says the reason for the concern and the measures taken should be documented and retained.
The framework also states that Chairs themselves are subject to FPPT oversight. In the case of ICB Chairs, accountability for ensuring the Chair meets the FPPT requirements sits with the relevant NHS England Regional Director.
This matters because my question to Dr Singh was not really an HR question.
It was a governance question directed to the person NHS England places at the centre of that governance system.
What kind of conduct can become relevant to a Fit and Proper Person assessment?
Not every organisational error makes a Chief Executive unfit for office. Nor should it.
NHS England's framework is supposed to be proportionate.
But it specifically recognises that serious misconduct or serious mismanagement may be relevant. Its examples include:
- dishonest conduct;
- discrimination under the Equality Act 2010;
- disregard for appropriate standards of governance;
- resistance to accountability or undermining due process;
- failure to report significant issues properly;
- repeated or ongoing tolerance of poor practice;
- and conduct that causes departure from recognised standards or accepted practice.
The framework also says organisations should consider whether conduct was deliberate or reckless, whether dishonesty was involved, whether problems were repeated or continued over time, and whether the individual demonstrates insight and self-reflection when concerns are identified.
None of that means the Ombudsman's report automatically proved that Dr Broughton was unfit.
It does explain why I considered it entirely reasonable to ask whether somebody had at least examined the question.
28 April 2026: what did I ask Dr Priya Singh, Chair of NHS Thames Valley ICB?
On 28 April 2026, I wrote directly to Dr Priya Singh in her capacity as Chair.
I explained that the Ombudsman's findings had transformed the matter from a patient complaint into a question of Board-level governance, leadership accountability and public confidence.
I asked five straightforward questions.
- Had the Board, Chair or any relevant committee considered leadership accountability after the Ombudsman findings?
- Had Dr Nick Broughton's Fit and Proper Person status been reviewed, reassessed or discussed?
- If so, through what governance route?
- If not, why did the Board consider that appropriate?
- Had NHS England, the Care Quality Commission or another external oversight organisation been informed?
I made clear that I was not asking for private personnel information.
I was asking whether the people responsible for governing the organisation had considered whether findings of this seriousness had any implications for its senior leadership.
5 May to 19 May 2026: why was my governance question initially redirected into a meeting?
My email was acknowledged on 5 May 2026.
Then, on 19 May, rather than receiving the Board-level written answers I had requested, I was offered a meeting with the ICB's Chief Medical Officer and Clinical Lead.
I declined.
Not because clinical input was irrelevant to the wider sterilisation issue, but because this particular question was not clinical- it was about governance, and that's the Chair's responsibility.
I had asked the Chair:
What did the Board do about leadership accountability after the Ombudsman's findings?
A meeting with executives or clinicians reporting within the same organisational structure could not substitute for the Chair answering that question.
I therefore wrote back on 19 May 2026 and explicitly reminded the ICB that NHS England's FPPT governance framework places overall accountability with the Chair.
29 May 2026: what did Dr Priya Singh, Chair of NHS Thames Valley ICB, finally confirm about Dr Nick Broughton?
On 29 May 2026, Dr Singh finally answered the questions directly.
And this is where the accountability story becomes extraordinary.
She confirmed:
The Board, its committees and associated groups had not considered leadership accountability following the Ombudsman's findings.
Dr Nick Broughton's FPPT status had not been reviewed, reassessed or discussed in light of the Ombudsman's findings.
When I asked what governance route had been used to assess his continued suitability, the answer was simply:
"Not applicable."
Dr Singh explained instead that the Ombudsman findings had been considered by the Quality Oversight Group, where actions were identified and undertaken.
She also made an important point: an FPPT review is not an automatic consequence of Ombudsman findings.
That is correct.
But it did not answer the question that concerned me.
If an FPPT review was not automatic, did Dr Priya Singh, Chair of NHS Thames Valley ICB, nevertheless consider whether one was warranted?
This is the distinction I think matters most.
I was not arguing that an Ombudsman report automatically equals "CEO fails FPPT".
That would be simplistic and would not reflect NHS England's framework.
I was asking how the Chair reached the conclusion that no leadership consideration at all was necessary.
Because the framework does not say fitness is considered only when a special investigation is automatically triggered.
Quite the opposite.
It says consideration of fitness is continuous and ongoing.
It says Boards need robust systems for assessing competence and character.
It says governance concerns, accountability, honesty, serious mismanagement and repeated poor practice can all become relevant.
And it places responsibility for ensuring Board members remain fit and proper with the Chair.
So after Dr Singh confirmed that:
- the Board had not considered leadership accountability;
- no relevant committee had considered it;
- Dr Broughton's FPPT status had not been reviewed;
- it had not been reassessed;
- and it had not even been discussed because of the Ombudsman findings;
I wanted to know what evidence supported the conclusion that no further leadership scrutiny was appropriate.
What did my Freedom of Information request reveal about Dr Nick Broughton's FPPT?
I trust you can see why I had already decided not to rely only on assurances.
So I submitted a Freedom of Information request seeking the recorded evidence.
The resulting response — FOI-TV-2604-039 — was authorised by NHS Thames Valley ICB and stated that the information was accurate as of 28 May 2026.
I asked whether any FPPT review, reassessment, discussion or recorded consideration had taken place in relation to Dr Nick Broughton following the Ombudsman findings.
The answer:
I also asked for any records in which the Ombudsman findings had been considered in relation to Dr Broughton's:
- FPPT status;
- suitability;
- fitness for role;
- leadership accountability;
- honesty or integrity;
- governance responsibility;
- or continued appointment.
The response stated:
That gave me something considerably more concrete than an institutional reassurance.
It gave me a recorded absence.
Why did the Ombudsman's referral to NHS England and the Care Quality Commission matter?
The Ombudsman had recommended that its final report and the information supplied to me should also be sent to NHS England and the Care Quality Commission (CQC).
Dr Singh confirmed on 29 May that this had been done.
That does not mean the Ombudsman had ordered NHS England or the CQC to discipline Dr Broughton. It had not.
But both organisations are directly relevant to senior NHS governance.
NHS England oversees the FPPT framework and receives annual FPPT submissions through its regional structure.
The CQC's role is different: it does not normally decide whether an individual director is personally fit and proper. Instead, it assesses whether an organisation has proper systems for making those assessments and can intervene where those processes are not robust.
CQC guidance says that where it receives information raising concerns about a director's fitness, it can pass that information to the organisation and require it to explain what steps it has taken to assure itself that the individual remains fit.
That made my question even more straightforward:
1 June 2026: Why did I challenge Dr Priya Singh, Chair of NHS Thames Valley ICB, again?
On 1 June, I wrote back.
I summarised what her own response and the FOI evidence now showed:
- no Chair or Board consideration of leadership accountability;
- no committee consideration;
- no FPPT review or reassessment;
- no recorded consideration connecting the Ombudsman findings to Dr Nick Broughton's continued fitness for role.
I told her I found that extremely difficult to reconcile with her simultaneous assertion that governance assurance had been sufficient.
And I put it bluntly:
if this level of maladministration did not trigger internal consideration of leadership accountability, what would?
That is still my question.
Why do I personally believe Dr Nick Broughton's assurances should at least have raised an FPPT question?
This is where my previous investigation matters.
My original complaint had challenged the evidence, equality implications, clinical rationale, consultation and governance underpinning the sterilisation policy.
Dr Broughton's final response reassured me that appropriate governance and assessment had taken place.
The Ombudsman subsequently established substantial failings in exactly those areas.
As I have said elsewhere, in my opinion the gap between those statements is so substantial that I regard some of the assurances as false.
The NHS England FPPT framework itself says honesty, openness, trustworthiness, governance, accountability and competence matter when assessing senior Board members.
It even lists conduct characterised by dishonesty, disregard for appropriate governance and resistance to accountability among matters capable of becoming relevant to serious misconduct or mismanagement.
So I was not asking Dr Singh to prejudge him.
I was asking her to investigate, consider and document.
Her answer was that this had not happened.
Did Dr Priya Singh, Chair of NHS Thames Valley ICB, then answer my questions about the new female sterilisation policy?
At the same time, a second accountability problem was unfolding.
The ICB had introduced another female sterilisation policy in February 2026.
I challenged Dr Singh directly on whether that policy complied with the Equality Act, Public Sector Equality Duty, NHS Constitution, Montgomery, relevant NICE and WHO guidance, the Ombudsman's findings and principles of informed consent and bodily autonomy.
I repeatedly asked for a direct answer.
That becomes a separate chapter of this story because the policy itself deserves a detailed analysis.
But the correspondence about that issue also revealed something important about accountability culture.
3 June to 27 June 2026: what happened when I kept pressing Dr Priya Singh, Chair of NHS Thames Valley ICB, for direct answers?
On 3 June, my email was acknowledged.
On 6 June, I chased again.
On 8 June, I wrote again because my questions remained unanswered.
On 9 June, Dr Singh said there would be further discussion at the regional Priorities Committee and promised a detailed response by 15 June.
On 16 June, she explained that the Committee had now recommended removing the requirement for women to undergo a trial of LARC before sterilisation, and said another policy would move through Board and Quality Committee approval.
But once again, that did not answer the question I had been asking: was the February policy actually compliant when it was approved and imposed on women?
On 19 June, I asked again.
On 23 June, I received an acknowledgment promising a response that week.
I challenged the absence of an answer again the same day.
On 26 June, I chased the missed deadline.
Finally, on 27 June 2026, Dr Singh replied.
She refused to answer the question in the yes-or-no terms I had requested, saying it was not appropriate to reduce complex healthcare policy to a binary answer.
She gave a series of general assurances about patient-centred care, clinical judgement, resources and the policy-development process.
And then she did something I had begun to recognise very well.
Why did Dr Priya Singh, Chair of NHS Thames Valley ICB, close correspondence while my questions remained unresolved?
At the end of her 27 June 2026 response, Dr Singh wrote that the ICB did not consider there to be any further substantive issues to address.
She stated that the email would be the final response, apart from sending me a link to the future policy.
And she said the ICB would not enter into further correspondence on the same issues unless I raised new or materially different information.
In other words:
This concerned me not only because of that email, but because by then it felt familiar.
Why does closing correspondence look like a wider pattern inside NHS Thames Valley ICB?
Across this case I have repeatedly experienced a similar sequence.
I raise a specific question.
The ICB provides a broader answer to something adjacent to it.
I point out that the question remains unanswered.
I chase.
I challenge the reasoning.
Eventually, the organisation declares its position final and stops engaging.
I saw versions of this during:
- my original complaint about the female sterilisation policy, where the responses repeatedly returned to the policy and Individual Funding Request process instead of addressing the evidence and decision-making problems I had identified;
- the later Freedom of Information Internal Review process, where after I challenged continuing delay and the adequacy of the review I was told that no further responses would be provided;
- my correspondence with the Chair, where Dr Singh eventually closed correspondence despite my continuing contention that the substantive compliance questions had not been answered;
- and subsequently in other attempts to obtain documentary evidence of how policies and governance decisions had actually been made.
I am not arguing that a public body is required to correspond indefinitely with someone who merely repeats the same point.
Public organisations need reasonable boundaries.
But there is an enormous difference between:
"We have answered your question and you dislike the answer"
and:
"We have not answered the question you asked, but we have decided the correspondence is over."
That distinction is central to my experience of this ICB.
How does this pattern sit with the accountability standards NHS Board members are supposed to follow?
The irony is difficult to ignore.
The NHS FPPT framework itself incorporates the Nolan Principles of Public Life.
Those principles include:
- Accountability — public office holders must submit themselves to the scrutiny necessary to ensure accountability;
- Openness — decisions should be made transparently and information should not be withheld without clear and lawful reason;
- Honesty — holders of public office should be truthful;
- Leadership — leaders should model these principles themselves and challenge poor behaviour when it occurs.
The NHS Constitution likewise says the NHS is accountable to the public, communities and patients it serves.
That is why I find the repeated closure of scrutiny so troubling.
Accountability cannot mean that a public body gets to decide unilaterally that it has adequately answered questions about its own accountability.
Does the absence of an FPPT review prove Dr Nick Broughton, Chief Executive of NHS Thames Valley ICB, is unfit?
No, but its presence and review might prove he is unfit.
And I think that distinction is important.
The evidence I have does not establish that Dr Broughton fails the Fit and Proper Person Test.
Nor does an Ombudsman finding automatically require a Chief Executive to be disciplined or removed.
What the evidence establishes is narrower — but still significant:
Serious independent findings were made about the organisation's decision-making and complaint handling.
Those findings contradicted important assurances I had previously received from its Chief Executive.
The Chair and Board did not consider leadership accountability in response.
Dr Broughton's FPPT status was not reviewed, reassessed or discussed because of those findings.
The ICB confirmed it held no recorded FPPT material connecting the Ombudsman findings to his fitness, integrity, governance responsibility or continued appointment.
My challenge is therefore about the absence of examination.
You cannot meaningfully say, "We examined this and concluded there was no leadership problem", if the recorded evidence says the leadership question was never actually examined through that route.
So:
How Serious Does NHS Maladministration Have to Be Before Chair Dr Priya Singh Investigates Chief Executive Dr Nick Broughton?
Who, then, holds Dr Priya Singh, Chair of NHS Thames Valley ICB, accountable?
The framework has an answer to that too.
Dr Singh is herself subject to the Fit and Proper Person requirements.
For ICB Chairs, the responsibility for ensuring the Chair meets the FPPT criteria resides with the relevant NHS England Regional Director.
That matters because accountability cannot stop with the person who decides whether somebody below them requires scrutiny.
There must also be a route to examine whether the Chair has properly discharged her own governance responsibilities.
That is one reason this case has progressively moved beyond NHS Thames Valley ICB itself and into external oversight routes.
What does accountability mean if nobody is ever personally accountable?
This is now one of the central questions of this entire project.
The NHS can apologise.
It can rewrite a policy.
It can say lessons have been learned.
It can create an action plan.
It can send a report to another organisation.
But somewhere in the chain, human beings made the decisions.
Human beings reviewed the evidence.
Human beings approved the policies.
Human beings answered the complaints.
Human beings signed the assurances.
And human beings decided whether anyone should be held accountable when an independent investigation later found that substantial things had gone wrong.
For me, organisational learning without any examination of individual leadership accountability risks becoming a very convenient form of institutional absolution.
Where can I read the correspondence between Dr Priya Singh, Chair of NHS Thames Valley ICB, and me?
I publish the underlying evidence because I do not want this website to depend on readers simply accepting my interpretation.
You can find my correspondence with Dr Singh, the FPPT Freedom of Information response, the Ombudsman material and the wider documentary history in the Evidence Folder.
Read the emails.
Read what I asked.
Read what she answered.
Read what the FOI subsequently confirmed.
Then decide for yourself whether this looks like meaningful NHS leadership accountability.
Sources and further reading on Dr Priya Singh's responsibilities as Chair and NHS Board accountability
- NHS England — Fit and Proper Person Test Framework for Board Members. The current NHS framework covering Board-member fitness, Chair accountability, annual assessment, good character, competence and serious misconduct or mismanagement.
- NHS England — Guidance for Chairs on Implementation of the Fit and Proper Person Test. Guidance specifically addressing the Chair's role in overseeing FPPT governance.
- NHS England — Leadership Competency Framework for Board Members. Includes Board-level expectations around equality, governance, assurance, culture and trusted relationships with communities.
- Care Quality Commission — Regulation 5: Fit and Proper Persons: Directors. Explains the regulatory basis for Board-member fitness and the requirement to address information raising questions about fitness or serious mismanagement.
- Care Quality Commission — Fit and Proper Persons: Directors. Explains CQC's role in assessing whether organisations operate proper processes for evaluating Board-member fitness.
- The NHS Constitution for England. Sets out NHS principles including accountability to patients, the public and communities.
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