Leah Brown examines whether the £67m Wales spends reviewing its public bodies is repairing institutions or merely creating compliant ones.
A note: this piece is not about the Cabinet Office programme that reviews whether an arm’s-length body should exist, merge, or close; it is about the standing machinery of audit and inspection that examines how public bodies in Wales perform, and what it cannot measure.
The media is quick to tell the public when a public body is being reviewed. There are Audit Wales reports, Healthcare Inspectorate Wales (HIW) and Care Inspectorate Wales (CIW) inspections, as well as independent governance reviews commissioned by and for named bodies. Separately, the Welsh Government runs review programmes for its arm’s-length and government-sponsored bodies.
I note that a body may have satisfied every recommendation on paper and still be unable to serve the public better than before the review began.
Wales spends an eye-watering sum funding public bodies every year, and a great deal more funding the machinery that reviews them. Audit Wales costs £28.4m a year, Estyn £17.1m, CIW £16.05m, and HIW £5.48m; roughly £67m across those four bodies alone. That machinery sits above public bodies commanding some £23bn: NHS Wales received £11.57bn in revenue funding in 2024-25, and Welsh local government budgeted £11.6bn for 2025-26. The Institute for Fiscal Studies puts it in proportion: the Welsh Government and Welsh councils are responsible for around 61 per cent of all identifiable expenditure in Wales, £30bn out of £50bn. The bodies subject to review account for the bulk of what Wales spends on itself.
Audit Wales assesses each of the ten health boards and NHS trusts, as well as the special health authorities. Healthcare Inspectorate Wales conducted 163 inspections in 2024-25. The NHS escalation framework was exercised at least five times in 2025, and at least three independent reviews were commissioned into bodies under pressure in that year alone.
My concern is narrower, and it comes from the work I do. I repair the internal damage that stops organisations adhering to their commitments. By the time I am called in, the review has usually been done, the report published, the recommendations accepted. I note that a body may have satisfied every recommendation on paper and still be unable to serve the public better than before the review began.
The public, in whose name every review is commissioned and who are funding the machinery, should have confidence in its investment.
Throughout the years, I have sat with boards in the months after a review concluded, and the pattern is consistent: boards accept every recommendation as a matter of course to move beyond being examined and found wanting, followed by a lengthy implementation phase where progress is tracked, ministers are briefed, and hard data is assembled for select committees and parliamentary questions. Whether or not recommendations were delivered, the body itself is likely changing in ways no one is monitoring. Responsibilities are redrawn, so that a director who owned three of the recommendations in the autumn owns none of them by the spring, while two colleagues find themselves covering ground they are unfamiliar with. Board papers are rewritten repeatedly because each version must show the recommendations being delivered, and the accuracy of the picture will fluctuate over time. By the end, the record will show that each recommendation was implemented.
However, there are two crucial factors the machinery has no way of examining: the impact of the review process on the governing group, and what the recommendations have not accounted for. The machinery can resolve that the board emerged still able to work together but is unable to distinguish whether that cohesion is performative or actual. I believe that reviews succeed when they result in changes that improve what a public body does for the people it serves, not when findings and recommendation have been accepted, implemented, and closed.
Syniadau uchelgeisiol, awdurdodol a mentrus.
Ymunwch â ni i gyfrannu at wneud Cymru gwell.
The public, in whose name every review is commissioned and who are funding the machinery, should have confidence in its investment. That confidence should come from knowing that the public body has a means of measuring the necessary components to avert further governance failures.
This is not a Welsh problem, and it is not new. In our white paper on rebuilding trust in Britain’s publicly funded institutions, I set out how often acknowledgement is mistaken for repair. The British Medical Association is the clearest example. In 2019, it commissioned an independent review into sexism within its structures, issued a public apology, and accepted the recommendations in full. On the surface, this was accountability. Yet five years later a second independent report was published. The first review identified what was wrong but could not repair the conditions that produced it, and so those conditions re-produced the same issues.
As highlighted in the above cited white paper, health institutions need fundamental cultural change, not another acknowledgement.
The pattern recurs wherever you look. South Wales Fire and Rescue Service was the subject of an independent culture review published in January 2024; within weeks the authority’s members were removed and commissioners took their place. The Ministerial Advisory Group on NHS Wales performance reported in March 2025 with twenty-nine recommendations, all of which the Welsh Government accepted. Swansea Bay University Health Board’s maternity and neonatal services were examined in an independent review published in July 2025, which made ten priority recommendations to the board and eleven to the Welsh Government. Betsi Cadwaladr University Health Board has been reviewed more often, and by more instruments, than any other body in Wales; each review has been received, its recommendations recorded, and its escalation status has stood at the highest level since February 2023. There is no question that the reviews are thorough. But I would wager that a critical question goes unasked: once the recommendations are closed, is the body actually working for the people it serves?
As highlighted in the above cited white paper, health institutions need fundamental cultural change, not another acknowledgement. The Countess of Chester is a reminder that saying the right things and actually doing them are not the same. That is precisely what the machinery does not measure. It examines governance, structures, even culture, and records the recommendations as delivered. It is not built to measure whether the people inside can still work together; and without that, there is no reliable way to know whether anything has improved for the public at all.
The issue is that the machinery cannot tell us whether a completed review left behind a repaired institution or merely a compliant one.
There is a further cost the machinery does not see. Each successive review asks the same people to examine themselves again, and the effect on them accumulates. Staff at every grade come to treat reviewing as something done for its own sake rather than for any live problem, particularly when the recommendations are poorly drafted, or shaped by political pressure rather than the difficulty they are meant to address. Cynicism sets in, and cynicism is corrosive to precisely the working relationships a review is supposed to restore. It is rare for the necessary candour to exist, and rarer still for such disclosures to appear in any progress report.
Thus, the issue is not that Wales spends £67m reviewing its public bodies; accountability costs money and it should. The issue is that the machinery cannot tell us whether a completed review left behind a repaired institution or merely a compliant one. There is next to no recourse for the public, in whose name every review is commissioned and from whose purse the machinery is funded, to ask which of the two they have paid for.
The true cost is not the £67m Wales spends reviewing; it is that the spending tells us nothing about whether the body can now do what it exists to do. Until the machinery can measure that, the public is entitled to ask one question of every review conducted in its name and at its expense: does the body work for us now?
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