Response to the Covid Inquiry Module 1 Report on ‘Preparedness and Resilience’

On July 18th, The Right Honourable Baroness Hallett published Module 1 of the UK COVID-19 Inquiry, focusing on the Resilience and Preparedness of the United Kingdom. The publication began by lending its voice to those of the bereaved, giving salience to the work which the UK Government must do to create a more resilient Britain. The state’s existing civil contingency structures failed in their primary duty – to help protect citizens from harm, and the Inquiry sounded an ominous warning that ‘there will be a next time’. 

It’s worth reviewing which of the Inquiry’s recommendations have already been actioned (Section A), which are yet to be implemented (Section B), and where we think it might go further to improve the UK’s resilience and preparedness (Section C).

Section A – Action Taken

In the four years following the start of the COVID-19 pandemic, we have been pleased to see the following actions taken by the government to improve UK resilience. Several of these have been re-emphasised by the Inquiry, and it is encouraging that they echo our recommendations:

Section B – To Be Actioned

The Inquiry made several additional recommendations that largely align with our own but which are yet to be implemented. These include:

1. Stronger central leadership on resilience and preparedness

The Inquiry called for the formation of a cabinet-level committee, and a cross-departmental group of senior officials in each government to oversee and implement policy, rightfully criticising the historical absence of a dedicated ministerial committee and highlighting the need for stronger leadership under a simplified structure. Whilst we support the overarching aim, we feel that this could also be an opportunity to enact our recommendation to recruit a specialist risk management capability in the shape of a government Chief Resilience Officer, appointed as a Deputy National Security Adviser. This role would provide a point person to spearhead resilience enhancement and assume responsibility for leading the Resilience Directorate and national security teams working on risk. This new role would bring balance and challenge to entrenched assumptions reflective of groupthink across government, cross-cutting oversight, as well as simpler and clearer accountability of the sort encouraged by the Inquiry. 

2. Regular Independent Scrutiny by External Experts

The Inquiry echoed our recommendation that independent scrutiny of preparedness is needed. The Inquiry envisages this taking the form of red team exercises (where resilience would be assessed by applying an adversarial lens) to challenge prevailing assumptions. The Inquiry also suggests the use of external independent scrutiny in addition to red teams. We agree and suggest this forum of external experts could perhaps be initially coordinated by the National Preparedness Commission ahead of the implementation of the independent statutory body recommended by the Inquiry. This would effectively implement a ‘three lines’ model to government risk management by providing ‘third line’ independent scrutiny of the risk management process. 

3. Revamping the National Risk Register

We were pleased to see the Inquiry directly address the shortcomings of the current risk assessment approach, acknowledging that “too much reliance was placed on a single scenario – pandemic influenza – and on the likelihood of the scenario occurring”. This resulted in a damagingly narrow assessment of pandemic risk. We have previously suggested that the National Risk Register (NRR) be revamped. It should include a section covering chronic risks with longer time horizons, and (in line with recommendations made by the Royal Academy of Engineering) a generally improved risk assessment methodology which moves away from likelihood towards vulnerability (see our response to the NRR publication). The Inquiry reflects these ideas, calling for a broader range of scenarios with far-reaching consequences to be considered and planned for, and future decision-making to be driven by consideration of both preparedness and impact. Ultimately, the Inquiry suggests, successful resilience requires plans to be made for unlikely events too.

4. Centralised and Coordinated Risk Ownership 

The Inquiry recognised the historically fragmented and siloed approach to pandemic preparedness. We agree with its conclusion that “the number of organisations across the UK with responsibility for pandemic preparedness has multiplied over time to become unnecessarily numerous and complex” (p.45). Its recommendations align with our own in proposing more centralised and coordinated risk ownership for cross-cutting risks such as those in the AI and biosecurity spheres, to allow for effective oversight. The Inquiry is hesitant to recommend further structural change, acknowledging that frequent movements within institutions can undermine planning and preparedness. However, it calls for the creation of a core structure of leadership that leads to permanent improvements. It recommends Cabinet Office leadership on complex risks, instead of the current Lead Government Department (LGD), and appointing a “senior cross-department group” of officials within six months of publication. We go further and recommend the establishment of specialist central ownership coordination units for complex risks creating a more direct and integrated approach. 

Section C – Further Suggestions

The following section highlights areas where we think the Inquiry might have gone further with recommendations to improve the UK’s resilience and preparedness:

1. Make resilience a national priority, reflected in titling the next Integrated Review ‘Resilient Britain’ 

This would boost resilience, support the Inquiry’s recommendation to build public understanding and acceptance of emergency preparedness measures and provide the UK with an opportunity to take an international lead in this field.

2. Encourage National Security to lead on UK Resilience

We suggest National Security takes the lead on resilience, and that the National Security Adviser be retitled to National Resilience and Security Adviser, simplifying the current reporting structure of the Resilience Directorate.

3. Apply the private sector ‘three lines’ best practice model for risk governance

An overarching government risk management framework based on the ‘three lines’ model should be implemented to separate risk ownership, oversight and audit. It should include the introduction of risk ownership coordination units, a government Chief Resilience Officer (to oversee the risk management process) and the independent statutory body recommended by the Inquiry to provide third-line scrutiny. This will enhance risk management practices further by providing clear ownership and oversight. 

4. Include a chronic risks section in the National Risk Register

In 2023, the National Risk Register (NRR) refocused on acute risk, assigning the responsibility for chronic risk to ongoing policy and operational work. Whilst the Inquiry has referenced the inadequacy of the NRR, it has not explicitly addressed this change. We advise adding a section on chronic risk to the NRR over a longer timeframe. Adding a chronic risk section to the NSRA/NRR would ensure that long-term risks are adequately considered, aligning with the Inquiry’s call for a broader and more comprehensive risk assessment approach.

5. Ringfence budget for the Biological Security Strategy

The Biological Security Strategy (BSS) released in 2023 was welcomed by the Inquiry as it contains various crucial commitments that, if implemented in full, will improve the UK’s resilience and preparedness against biological threats. However, the resources necessary for delivering these commitments have not been guaranteed. Given its importance, BSS funding needs to be prioritised in the next treasury budget with ringfencing for biological security in departments across the government. 

6. Publish a detailed implementation plan for the Biological Security Strategy

While the BSS contains a high-level summary of a non-public implementation plan, the Inquiry notes it “lacks deadlines by which actions should occur and by which the government’s progress could be measured”. The public cannot know if the government has failed “if the government itself, is unwilling or unable to describe and set objective tests by which its actions can be measured, nor can the officials whose job it is to implement such a strategy.” (p. 94) Therefore, we recommend tasking the lead departments for each pillar in the BSS by providing additional, specific commitments for each outcome that encompass the full scope of what must be delivered to achieve the stated objectives. While some may have national security concerns, the Government should evaluate which of these commitments can be shared publicly and publish these in full in an updated implementation plan by the end of 2024. BSS funding, including for NBN commitments, should be prioritised in the next treasury budget. As the NBN is needed to detect new pathogen outbreaks and prevent future pandemics, its resourcing should be prioritised.

7. Appoint a Senior Responsible Owner to coordinate cross-government engagement for the successful delivery of the National Biosurveillance Network

The National Biosurveillance Network (NBN) announced in the BSS presents the best way for the UK to detect outbreaks early and prevent pandemics, but it is not mentioned in the Inquiry’s report. The Inquiry acknowledges that the “best defence against the spread of pathogens was and remains strong national surveillance and detection mechanisms.” (p. 17) However, it fails to make explicit recommendations about how this could be achieved. The NBN is ambitious and requires adequate resourcing, and the UK Health Security Agency (UKHSA) tasked with its delivery has already identified several project risks including issues with cross-government coordination. We therefore recommend the appointment of a Senior Responsible Owner (SRO) to coordinate cross-government engagement for the successful delivery of the NBN. This SRO, likely based outside of UKHSA, and perhaps a member of the relevant risk ownership coordination unit we have suggested, should have links with all departments involved to ensure NBN integration is feasible and achieved.

8. Task the National Exercising Programme with conducting a Tier 1 pandemic exercise by mid-2025

Given the shortcomings identified by the Inquiry regarding the underutilisation of historical exercises, we suggest that the Government follow through with the previous government’s announced plans for 2025 exercises. National-level and smaller-scale exercises are valuable tools for informing effective response plans against different biological threats and their expansion will help identify lessons and gaps to inform future response plans, strengthening the UK’s preparedness for future biological events.

9. Provide a clear roadmap towards improved resilience 

The Cabinet Office should provide an update on the roadmap towards resilience improvement. The Inquiry has outlined many failures and made recommendations to resolve these. However, we would like to see a clear roadmap clarifying how the government intends to learn from the COVID-19 pandemic, and other historical and future exercises, and at what rate changes will be introduced. The Inquiry sets a concrete timeline for introducing a streamlined approach to preparedness and governance, with a restructuring to be made within six months, and a wholesale review to be carried out by July 2026. We welcome this metric for tracking improvement but suggest that transparency should be offered throughout the process via published updates. 

In suggesting these additional improvements, we acknowledge that the topics of the remaining seven modules of the Covid Inquiry are promising. We look forward to engaging with their content and seeing some of our ideas reflected in future recommendations.

Meanwhile, we welcome the considered and reflective tone of the first module of the Inquiry and recognise the impact it has made in just a few short weeks, with Chancellor of the Duchy of Lancaster Pat McFadden confirming that there will now be a review of national resilience. The Inquiry makes it clear that the UK was not as well-prepared for a pandemic as was previously thought. CLTR looks forward to supporting the national resilience review and playing our part in enhancing national preparedness.