Part 3 of The State of DHCW. The leadership criticism is institutional and behavioural, made by the Welsh Government, Audit Wales, DHCW's own internal auditors and its own staff. The Cabinet Secretary's February 2026 letter records DHCW's concession that 'optimism bias, insufficient early discovery, supplier constraints and legacy system complexities have all contributed to late emergent issues.' DHCW's own minutes record three whistleblowing investigations, a Limited Assurance recruitment audit, and a 15-recommendation culture review — and its 2025–26 accounts record staff confidence that concerns would be addressed falling from 84.8% to 59.2%.
Part 3 of The State of DHCW. Numbered citations resolve at the sources page.
Precision matters here, because the leadership criticism of DHCW is institutional and behavioural, not allegations of misconduct. Extensive searching found no employment tribunal judgment, no named trade union dispute, no substantiated bullying finding and no whistleblowing-retaliation case involving DHCW. The case against DHCW’s leadership rests on documented delivery behaviour and internal-control findings, and it is made by the Welsh Government, Audit Wales, its own internal auditors and its own staff — not by anonymous briefing.
That said, there is a documented internal thread on culture, speaking up and recruitment controls running from late 2024 to 2026, recorded in DHCW’s own committee minutes. It is set out below, and it materially strengthens the Welsh Government’s April 2026 finding that culture requires external intervention.
The Cabinet Secretary’s own assessment
The clearest single document is Jeremy Miles’s letter of 12 February 2026 to Interim Chair Ruth Glazzard and Chief Executive Helen Thomas, following DHCW’s Public Accountability Meeting of 29 January 2026. It is worth reading as a sustained critique:[3]
“I welcomed your honesty about both progress and challenges. However, what emerged clearly was the need for stronger forward-planning, earlier escalation of risk, and a much clearer articulation of benefits and system value. These are issues the Welsh Government expects to see addressed quickly.”
On the App: “The public need a more integrated, seamless, and universally reliable product before this can be described as the primary digital front door for Wales. Concerns were raised about fragmentation, differential availability across Wales, and the lack of a defined critical path that would move the app from useful to essential for citizens.”[3]
On causes, the letter records DHCW’s own concession: “You acknowledged that optimism bias, insufficient early discovery, supplier constraints and legacy system complexities have all contributed to late emergent issues.”[3]
On the pace of correction, the sharpest passage: “I welcome the shift you described towards more agile programme structures, clearer milestones, more frequent testing cycles … These are positive steps, but they have been a long time in development, and you must shift to this approach immediately. My clear expectation is DHCW must alert Welsh Government significantly earlier when risks threaten delivery, avoiding the pattern of late notification that undermines system confidence and disrupts operational planning across Wales.”[3]
And on value for money: “It is clear the organisation remains some distance from being able to consistently quantify return on investment, articulate realised benefits across Wales or demonstrate the scale of digital investment is matched by measurable improvements for citizens and clinicians.”[3] The letter closes by requiring that “the governance and cultural changes planned are accelerated.” Two months later, DHCW was escalated to Level 4.
Senedd committee criticism
The joint scrutiny of DHCW by the Health and Social Care Committee and the Public Accounts and Public Administration Committee, reported in July 2023, is the most important parliamentary assessment. Its warning has aged remarkably well:
“We applaud ambition and positivity … but we caution against over-optimism and a focus on celebrating successes at the expense of realistically assessing both what needs to be achieved and how the work agenda needs to be prioritised.”[22]
The Committees also found: “It is not yet clear to us who is deciding on the priorities for DHCW, or how the multiple projects it has responsibility for are being ordered in terms of importance or urgency. We are also not yet assured … about the adequacy of information about timelines, milestones and progress on DHCW’s major projects.”[22] On WCCIS specifically they were “concerned about the lack of clarity about where responsibility lies for leadership,” noting that DHCW’s answer — that uptake was “a collective responsibility” — “does not provide us sufficient assurance that responsibility for leading on this flagship system is being adequately prioritised.”[22] Russell George MS summarised: “We understand the complexity and scale of the programme, but during our scrutiny of DHCW we were not assured about several issues central to the roll out of WCCIS.”[23]
In plenary on 4 March 2025 — a week before the first escalation — Rhys ab Owen MS told the First Minister: “it’s fair to say that Digital Health and Care Wales has faced its share of problems across the years, from governance issues to cyber risk issues,” linking this to coroners’ alerts about information-sharing failures.[30] Gareth Davies MS said in the same exchange: “The digital divide between the NHS in Wales and England is growing ever bigger, First Minister. The vast majority of patient records in Wales are still physical, a bit like the 1970s.”[30]
What Audit Wales says — and does not say
Audit Wales is markedly more positive on corporate governance than the Welsh Government is on delivery governance, and this divergence is itself informative. Its September 2025 structured assessment found “an effective Board supported by good governance arrangements … strong financial management processes and a clear long-term plan,” a stable board with all executive roles filled, livestreamed meetings, live Welsh translation and papers published a week in advance.[12] On no reading is DHCW an opaque or badly run corporate entity. How far that verdict actually reaches is examined in Part 5.
But the same report identifies precise weaknesses that map onto the Level 4 concerns:
- “While DHCW is responding positively to its recent escalation by Welsh Government, stronger performance reporting and better tracking of organisational strategies would help it to assess and demonstrate its impact and value to partners.”[12]
- “we found that reports to the [Programmes Delivery] committee often focus too much on problems outside of DHCW’s control. Instead, DHCW should focus more on the issues it can control.”[12]
- “DHCW should make its Integrated Organisational Performance Report clearer. It should explain why key targets are being missed, what actions are being taken to address this, and how well those actions are working.”[12]
- “The actions that need to be taken in response to issues escalated to the Board could be clearer.”[12]
- The May 2025 performance report “highlights worrying trends in some areas … staffing levels, turnover, and availability, and how major incidents are resolved. These issues are not clearly explained.”[12]
- Eight structured-assessment recommendations remained in progress and “some recommendations from past structured assessment reports are still beyond their completion date.”[12]
- DHCW’s Duty of Quality “Always On” reports for 2024–25 were drafted but “remain unapproved and unpublished.”[12]
Earlier assessments add two structural points. In 2024 Audit Wales recorded that “a recent skills review identified that the Board has limited clinical experience”[13] — a notable gap for a body whose products carry clinical safety risk. And in 2023 it found that “a significant number of priorities in the IMTP have not been resourced, and DHCW often commits to work outside its agreed IMTP which places a further strain on organisational resources. This creates deliverability risks.”[14]
Leadership continuity, churn and interim cover
| Post | Position as evidenced |
|---|---|
| Chief Executive | Helen Thomas, in post continuously since April 2021 (initially interim), previously interim director and Director of Information at NWIS.[7] Signed the 2025–26 accounts as Chief Executive and Accountable Officer on 30 June 2026.[65] No evidence of resignation or departure was found. |
| Chair | Bob Hudson (interim, from Nov 2020) → Simon Jones (substantive, from 1 Oct 2021)[8] → stepped down at end of term September 2025, with Audit Wales noting DHCW "will need to put plans in place to support leadership continuity."[12] Ruth Glazzard was Interim Chair from at least October 2025 through May 2026.[61][38][3] The 2025–26 Staff Report lists the post itself as "Chair – Vacancy" at 31 March 2026, with an interim chair and an interim vice chair.[65] DHCW therefore entered Level 4 intervention with a vacant chairmanship. |
| Executive Director of Finance | The remuneration report resolves this: Claire Osmundsen-Little "was seconded to Swansea Bay UHB from 9th March 2026," and Chris Moreton "became Acting Executive Director of Finance from 9th March 2026."[84] A secondment out rather than a departure — but it leaves DHCW carrying the finance portfolio on an acting basis through its Level 4 intervention.[38] |
| Earlier churn | DHCW's first annual report records a director stepping down in November 2021 and an Interim Executive Director of Operations appointed April 2022.[50] The Director of People and OD changed in late 2024.[46] WCCIS saw "two changes in previous temporary appointments to the role of WCCIS programme director" before the post was made permanent in early 2022.[16] |
One further governance data point belongs here: a 2024 internal audit follow-up found that “recommendations from reports are not always recorded accurately on the tracker,” with discrepancies in 16 of 26 reports tested.[41]
Workforce and the “unsustainable model”
The Level 4 framework’s charge of an “unsustainable workforce model (temporary and external roles)” is corroborated by DHCW’s own disclosures. Its 2024–25 accounts record £1.628m spent on “temporary staff, including agency workers, interim managers, and specialist contractors” plus £0.325m on external consultancy; the equivalent 2025–26 figures fell to £1.286m and £0.227m.[46][65] DHCW states that “some digital skills are in short supply and posts are difficult to fill.”[48] Staff engagement in the 2024 NHS all-Wales survey fell from 80% to 76%, with board minutes recording that “challenges remain, particularly around burnout and the need for stronger leadership, visibility and development opportunities.”[37] Sickness absence was 2.9% in 2024–25, rising to a 3.21% average in 2025–26, and in both years “the highest number of lost working days were related to stress and anxiety.”[46][65] Headcount fell slightly, from an average of 1,235 to 1,225.[65]
This closes a loop with 2018. The Public Accounts Committee then reported concern “about gaps in NWIS’ capacity and capabilities to deliver” and recommended that additional funding “be tied to reorganisation.”[21] DHCW grew about 30% in employed staff to April 2025[4] — and the Welsh Government’s 2026 finding is that “growth [is] not matched by delivery maturity.”[1]
The whistleblowing, recruitment and culture thread
This is the one strand of the DHCW record where the organisation’s internal evidence, rather than external audit or ministerial criticism, does most of the work. The chronology is the argument.
January 2025 — three whistleblowing investigations, and a culture review. The Audit and Assurance Committee’s private abridged minutes record the Head of Governance / Deputy Board Secretary advising that:
“members were aware of the three raising concerns (whistleblowing) investigations that specifically related to values and behaviours and processes being adhered to. As a result of these concerns, DHCW commissioned a culture review, this work was undertaken by an Independent Senior Leadership Consultant and concluded in December 2024.”[60]
The Committee was told findings “had been put into an action plan and reviewed with the team to ensure the required progress was being made,” and “recognised that it was positive that staff felt able to provide feedback and raise concerns.”[60] The published record does not say what the three concerns alleged, who they concerned, or how they were resolved.
April 2025 — Limited Assurance on recruitment. At the next meeting, item 5.1:
“Stephen Chaney, Head of Internal Audit (StC), presented the review into the DHCW Recruitment Processes which had received a Limited Assurance. The Committee confirmed that this review had been requested following a Whistle Blowing concern and welcomed the findings which provided a good learning opportunity. Samantha Morgan, Director of People and OD responded to points raised and provided assurance that the organisation was committed to ensuring improvements were made. The Committee requested an immediate report on progress on actions resulting from the audit, in addition members requested that the audit be shared with the Executive team … and to review and agree an action plan for further support and improvement.”[40]
Three points stand out. First, the audit was reactive — commissioned in response to a concern, not scheduled. Second, “Limited Assurance” is the second-lowest rating in the NHS Wales internal audit scale (above only “No Assurance”), and it was the only Limited Assurance report in DHCW’s cycle: the Head of Internal Audit’s 2024–25 opinion was Reasonable Assurance overall, comprising “2 reviews had Substantial Assurance, 9 had Reasonable Assurance, 1 advisory report, and 5 reports (including 1 ‘Limited Assurance’) were issued before year-end for reporting in 2025/2026.”[66] Third, the recruitment audit and the culture-review action plan were handled at the same meeting — item 5.1 and item 5.3 — by the same director.[40]
What the documents do not say. No published DHCW, Welsh Government or Audit Wales document states what the whistleblowing concern was about, whether it concerned a specific appointment, or what the audit's individual findings and recommendation priorities were. The underlying internal audit report has not been published — unlike DHCW's other internal audit reports, several of which are on its website in full. Nor is it established that the April 2025 concern was one of the three reported in January. Anything beyond the quoted minutes is inference, and this record does not draw it.
And what the public record cannot show. The absence of any employment tribunal judgment involving DHCW is not evidence that no proceedings exist. Two features of the system make this so: the gov.uk register publishes employment tribunal judgments only on hand-down, so a claim issued, case-managed and heard leaves no entry until it is decided; and tribunal daily hearing lists — the one contemporaneous public record that a hearing took place — are not retained retrospectively, so they are unretrievable after the day. A contested claim can therefore run for two years, be heard in public, and leave no trace a researcher can cite. This section's silence on litigation is a gap in the available record, not a finding — the register itself is the thing to watch (see Part 7).
October 2025 — re-audited, not closed. The Committee’s private session received a “Spot Checks for Recruitment Processes Report … which provided progress on the action requested by the Committee following the recent Limited Assurance review into Recruitment Processes.”[63] More significantly, the public 2025/26 internal audit plan shows that recruitment was put back through a full second audit — “5. Recruitment Process — Work in Progress” — still unrated at that date.[62] The same plan records a separate advisory review, “Staff Culture / Wellbeing,” which had reached Final Report with 15 recommendations.[62] Presenting it, the Head of Culture and People Strategy described the need to move “from reactive to proactive, evidence-based well-being strategies,” and a “culture road map” covering the next 12 months; the Executive Director of Finance “raised concerns about confidentiality and stress management.”[61]
December 2025 — declared resolved, on the wrong measure. DHCW’s performance report to the February 2026 Board lists “Recruitment Processes” among areas of strong performance, and under “Resolved Areas of Concern” states:
“The current position with DHCW Recruitment processes continue to improve, with the targets of all KPIs, met. The average time from Vacancy Creation to Unconditional Offer has remained steady at 47.4 days. Hiring Manager training continues to be offered to all DHCW hiring managers … This will become mandatory for all recruitment after March 2026.”[63]
This is a precise illustration of the behaviour Audit Wales and the Welsh Government criticise elsewhere in this record. The KPI that was met measures time-to-hire — 47.4 days — which is not what a Limited Assurance opinion on recruitment controls was about. Recruitment was booked as a “Resolved Area of Concern” while a second internal audit of the same area was still running, and while the single most concrete remedy, mandatory hiring-manager training, remained voluntary until eleven months after the Limited Assurance finding. Audit Wales’s recommendation that DHCW’s performance reports should “explain why key targets are being missed, what actions are being taken … and how well those actions are working”[12] applies with equal force to targets reported as met.
June 2026 — the speaking-up figures collapse. The strongest evidence in this thread is DHCW’s own. Comparing the two Annual Governance Statements:
| NHS Wales Staff Survey — DHCW | 2024–25 | 2025–26 | Change |
|---|---|---|---|
| Would feel secure raising concerns about unethical behaviour | 91.3% | 79.5% | −11.8 pts |
| Confident that DHCW would address concerns | 84.8% | 59.2% | −25.6 pts |
| Feel safe to speak up about anything that concerns them | 84.8% | 62.8% | −22.0 pts |
| Raising Concerns cases reported in year | 4 | 2 | −2 |
Sources: refs. [47] (2024–25) and [64] (2025–26).
Two of the three indicators fell by more than twenty percentage points in a single year. Barely three in five DHCW staff now believe the organisation would act on a concern, or feel safe raising one. The fall in reported cases from four to two should be read against that, not as improvement: falling confidence that concerns will be addressed is the standard mechanism by which case volumes drop. Corroborating workforce data in the same accounts points the same way — working days lost to stress and anxiety rose to 5,209, average sickness absence rose from 2.9% to 3.21%, long-term absence accounted for 8,358 of 14,649 days lost, and exit packages doubled from one to two.[65]
Why this thread matters. DHCW identified a culture problem itself, in late 2024, through its own whistleblowers. It commissioned an independent culture review, produced an action plan, and told its Audit and Assurance Committee that "the required progress was being made."[60] It commissioned a 15-recommendation culture and wellbeing review and a "culture road map."[62] It declared recruitment a resolved concern.[63]
Then, in April 2026, the Welsh Government concluded that "cultural factors appear to inhibit early, open reporting of delivery risk," escalated DHCW to Level 4 on grounds expressly including leadership and culture, and commissioned external reviewers specifically "to support understanding of the underlying cultural dynamics within the organisation."[1] Two months later DHCW published staff-survey figures showing confidence in its handling of concerns down more than 25 points.[64]
The pattern is not that DHCW ignored the warning. It is that DHCW's internal remedies were reported as working while the underlying measures moved the other way — which is, precisely, the "optimism bias" and "insufficient delivery grip and realism in leadership behaviours" that the Welsh Government identified in delivery.[1] The same reporting behaviour appears in programmes and in culture.