Shelley Lewis’ recent commentary struck a powerful chord, and not just for those within the NHS. Her assertion that removing clinical leadership from Integrated Care Board (ICB) executive teams risks derailing safe, effective healthcare delivery couldn’t be more timely, particularly as we accelerate the adoption of digital health technologies and artificial intelligence (AI) across the system.
This is not a theoretical debate. It’s a practical, real-world issue playing out in meeting rooms, procurement cycles, and development sprints across the country, where too often, clinicians are absent from the conversation.
As someone who works with digital health innovators and NHS organisations to support regulatory compliance, clinical safety, and assurance, I’ve lost count of the times I’ve encountered digital health solutions built with no clinical engagement. Products are scoped, designed, and even deployed without consulting the very people accountable for patient safety. It’s a practice that is not just unwise, it’s unsafe.
When clinical input is missing at the design table, the outcomes are predictable:
- Workflows that don’t reflect real-world practice
- Risk assessments that miss critical clinical consequences
- AI systems trained on data with no clinical validation
- Safety standards (such as DCB0129/0160) treated as a tick-box exercise, rather than embedded principles of harm prevention
This lack of clinical oversight creates a dangerous blind spot, particularly when these tools are designed to guide, support, or automate clinical decision-making.
The ICB Parallel: Clinical Oversight Must Start at the Top
The proposed removal of mandated clinical leadership on ICB executive boards reflects a worrying trend, one that devalues clinical expertise in strategic decision-making. ICBs are responsible for system-level commissioning and digital transformation agendas, including decisions that directly impact patient care pathways, data architecture, AI deployment, and risk-sharing arrangements.
This disconnect isn’t confined to ICBs, it’s also evident within NHS Trusts and health organisations delivering digital health technologies. Clinical engagement is often missing where it’s most needed, at the point where clinician insight is critical to the safe and successful adoption of platforms and applications across our healthcare system.
To delegate these decisions to boards without clinical accountability is akin to running a digital health company with no clinicians involved and we’ve already seen how that story ends.
These aren’t just policy decisions. They are decisions about safety, trust, transparency, and outcomes. And when something goes wrong, such as a system-generated clinical error or a failed escalation in digital triage, who will make sense of the clinical context? Who will respond with insight grounded in patient care? Who will recognise when the system is veering off course?
Clinicians Are Not Optional in Digital Health
It is imperative that the NHS and its partners recognise that digital health is still health. The tools may be digital, but the risks, responsibilities, and repercussions are very human. In regulatory terms, both UK MDR and DCB0129/0160 make clear that clinical safety is not an afterthought. It is a foundational requirement and that means meaningful clinical involvement throughout.
As we embed AI into clinical workflows, standards like ISO 42001 (AI Management Systems) and ISO 30440 (AI Impact Assessment) reinforce this further, calling for accountable leadership, stakeholder engagement, bias monitoring, and impact validation. These cannot be fulfilled by data scientists or executives alone. They require clinicians to shape the algorithms, interrogate the outputs, and champion ethical use.
Putting Clinical Expertise at the Heart of Decision-Making
This isn’t about pitting clinical and non-clinical leaders against one another. It’s about recognising that the most resilient systems are those where technical, clinical, operational, and financial leadership co-exist, not in competition, but in collaboration.
The NHS Long Term Plan sets a clear direction of travel: a system that’s proactive, digitally enabled, and centred on patient outcomes. Achieving that vision depends on technology that is safe, effective, and trusted, and trust starts with clinicians being at the heart of decision-making, not on the periphery.
What Needs to Change?
We must embed clinical leadership into every stage of digital health, from governance to procurement, from boardroom to backend. This includes:
- Mandating clinical roles on ICB executive boards
- Regulation of the NHS safety standards – DCB0129/0160
- Embedding Clinical Safety Officers (CSOs) and frontline clinicians in digital health project teams
- Ensuring all digital health manufacturers engage clinical expertise from scope to deployment to decommissioning
- Supporting clinical digital leadership development across NHS organisations that have experience within the sector
Because you wouldn’t launch a plane without a pilot.
So why are we willing to risk launching a healthcare system, and its digital future, without clinical leadership at the controls?
