Governance Reform

DHCW's governance has failed at every level. The board did not detect — or did not act on — programme failures that the Welsh Government would later describe as warranting its highest tier of intervention. Directors received late, incomplete, and misleading information from the executive team. Interim Chair Ruth Galzzard herself admitted publicly that the board shares the frustration of being "informed in what we perceive to be late in the day." A board that cannot get timely information from its own executives is not governing — it is being managed.

Reform must address four structural failures: the absence of independent technical oversight, the lack of relevant competence on the board, the near-total opacity of DHCW's operations, and the absence of any meaningful accountability for directors who preside over failure.

1. Independent Technical Advisory Panel

The problem: DHCW currently marks its own homework. Programme status, risk assessments, and delivery timelines are self-reported by the same executives responsible for delivery. There is no independent technical challenge function. When the Welsh Government finally intervened, it appointed an independent digital expert — but that person's identity has never been disclosed, their findings have not been published, and there is no standing mechanism for ongoing independent scrutiny.

The proposal: Establish a standing Independent Technical Advisory Panel (ITAP) for DHCW, modelled on the Cabinet Office's Central Digital and Data Office (CDDO) spend controls process.

Under the CDDO model, any UK Government digital programme above a defined spending threshold must pass an independent technical assessment before it can proceed through phase gates (Discovery, Alpha, Beta, Live). Assessors are drawn from a pool of experienced digital practitioners across government — they are independent of the programme team and report their findings transparently.

How it would work for DHCW:

• Composition: 5-7 members drawn from senior digital leaders outside Wales — former GDS assessors, NHS England digital directors, experienced CTOs from UK public sector digital. At least two members must have direct experience of healthcare digital transformation. No current or former DHCW staff. No DHCW suppliers.
• Remit: Mandatory assessment of all programmes above £2 million total lifetime cost. Assessment at each phase gate (Discovery exit, Alpha exit, Beta exit, Live assessment). Power to recommend programme pause, restructure, or termination.
• Reporting: Panel findings published in full within 30 days of each assessment. Recommendations are "comply or explain" — the DHCW board must either accept them or publish a written explanation of why it disagrees, available to the Senedd.
• Independence: Panel members appointed by the Welsh Government on the recommendation of an independent appointments panel. Fixed three-year terms. Funded directly by Welsh Government, not from DHCW's budget.

Comparator: CDDO spend controls have prevented billions in wasted UK Government digital spending since 2012. The model is proven, battle-tested, and well-documented. There is no reason Wales cannot adopt it.

2. Board Competence Requirements

The problem: DHCW's board has overseen the failure of every major programme without intervening effectively. This is not solely a character failing — it is a structural one. If board members lack the technical and commercial expertise to evaluate digital programme delivery, they cannot challenge executive assertions, detect warning signs, or hold leaders accountable. They become dependent on whatever the executive team chooses to tell them.

The proposal: Mandate minimum competence requirements for DHCW board members, drawing on the NHS England Board Development Framework and the Government Digital Service's DDaT (Digital, Data and Technology) Capability Framework.

Specific requirements:

• Minimum two board members must have demonstrable senior experience (5+ years) in digital programme delivery at scale — not digital strategy, not digital transformation consulting, but hands-on accountability for delivering working digital services used by real users.
• Minimum one board member with senior commercial/procurement experience in technology contracts above £10 million.
• All board members must complete the NHS Digital Academy's digital leadership programme (or equivalent) within 12 months of appointment.
• Chair must have direct experience of either digital service delivery or oversight of a technical organisation employing more than 500 staff.

Comparator: NHS England's Board Development Framework sets explicit expectations for digital literacy at board level. The Government's Technology Code of Practice requires departments to have appropriate digital expertise at senior leadership and board level. DHCW meets neither standard.

3. Mandatory Transparency Regime

The problem: DHCW operates in near-total opacity. Programme costs are fragmented across multiple funding streams and never consolidated publicly. Off-payroll workers who make operational decisions and spend public money are not named. Whistleblowing data is not published. Board papers are not routinely published. Contract values for major procurements are hidden. Even salary disclosures for named directors have vanished from published accounts while those directors remained in post.

This is not a data management problem. It is an architecture of unaccountability.

The proposal: Impose a mandatory transparency regime requiring DHCW to publish the following, quarterly, in machine-readable format:

Financial transparency

• Programme-level spending: Total cost to date, forecast cost to completion, and variance against original business case — for every programme above £1 million. Published as structured data (not buried in narrative annual reports).
• Contract register: All contracts above £25,000 — supplier name, contract value, duration, whether competitively tendered, and named DHCW contract owner. This is already a legal requirement under Welsh Government procurement policy; DHCW must be held to it.
• Off-payroll workers: Names (or unique identifiers), day rates, contract durations, and roles of all individuals engaged at £245/day or above. Published quarterly. If DHCW argues that naming individuals breaches privacy, unique identifiers with role descriptions are an acceptable minimum — but the total cost and number must be published.

Operational transparency

• Programme status dashboard: RAG status, key milestones, delivery dates (original and revised), and named Senior Responsible Owner for every active programme. Updated monthly. Published on DHCW's website, not locked inside board papers.
• Whistleblowing data: Number of disclosures received, categories, outcomes, and whether any discloser faced adverse consequences within 12 months of disclosure. Published annually as a standalone report. This is standard practice in well-governed NHS organisations.
• Staff data: Annual publication of overall turnover rate, voluntary turnover rate, exit interview themes, disciplinary actions by category, and grievance outcomes by category.
• Board papers: Full board papers published within 14 days of each meeting, with redactions only for legally privileged or genuinely commercially sensitive material — not for material that is merely embarrassing.

Performance transparency

• User satisfaction: Measured using a standardised instrument (NHS Friends and Family Test or equivalent), not a self-designed survey. Results published quarterly with methodology.
• System uptime: Published monthly for all national systems (WPAS, WCCG, WCP, eMPI, GP systems). Include planned and unplanned downtime, incident severity, and mean time to resolution.

Comparator: NHS England publishes detailed spending data through the Digital Data and Technology Spend Transparency framework. GDS publishes service performance dashboards for all live services. DHCW publishes almost nothing.

4. Director Accountability

The problem: No DHCW director has faced any consequence for the failure of any programme, at any point. CEO Helen Thomas presides over nine programmes under the highest tier of government intervention — simultaneously — and remains in post. Directors whose portfolios fail are reshuffled or given new titles. Salary disclosures vanish. The message to every future DHCW leader is clear: failure carries no penalty.

The proposal: Introduce Personal Accountability Statements for all DHCW executive directors, modelled on the Senior Managers and Certification Regime (SM&CR) used in UK financial services.

How it would work:

• Every executive director signs a published statement setting out their specific areas of responsibility, the outcomes they are accountable for, and the standards against which their performance will be judged.
• The Independent Technical Advisory Panel assesses delivery against these commitments annually.
• Where a director's portfolio fails to meet agreed standards for two consecutive assessment periods, a formal capability review is triggered — conducted independently, not by DHCW's own HR function.
• Directors who are removed or who resign following performance failures cannot be re-employed by any NHS Wales organisation within three years without the approval of an independent panel.

Comparator: The SM&CR regime was introduced in financial services after the 2008 crisis specifically because senior executives were able to claim ignorance of failures in their areas. The regime works by making it impossible to hide behind collective responsibility. The same principle should apply to leaders responsible for critical public healthcare infrastructure.

These four reforms — independent oversight, board competence, mandatory transparency, and personal accountability — form the governance foundation on which all other reforms depend. Without them, any other changes will be absorbed and neutralised by the same leadership culture that created the current crisis.