Fourth, and perhaps most difficult to tackle, it would seem to be time to question whether we need 209 CCGs and their associated costly infrastructure. If local health and care systems are to act as accountable care organisations, we need a fresh approach to where we locate those critical functions currently described as ‘commissioning’, namely analysis of needs, activity and costs, review of service performance and patient experience, and support for planning and making service change. The NHS is understandably cautious about further structural change, still bruised by the Lansley reforms of 2010, but at a time of austerity when major and urgent service change is needed, the system itself has to be properly efficient and fit for the purpose ahead.