It is almost certainly unrealistic, although even that i am not entirely sure of. Things may suddenly start changing. I am assuming that it is unrealistic to think that policy will shift directly to what is suggested but the current DHSC proposal is actually extremely vague - so vague that in fact it could probably allow the suggested format to be set up by a commissioning group. I think there is at least a chance that the DHSC will shift to a position where it is more explicitly allowed.
If not, the goal is to try to get everyone involved to have some appreciation of the absurdity of the current DHSC wording of a rehab-ish service for mild/moderate and forget the others. And moreover, to appreciate the absurdity of the rehab model. I think that provides a chance for getting a better result from any local negotiations that follow. In one sense the whole thing is a juggernaut. But, as Suffolkres has established, it is also a fabric of individuals, some of whom can make sensible decisions.
There is a lever, in that if, as the DHSC say, they will look again at severe services, they may realise that you cannot really do that without a different format.
At the moment we have very few physician-run services, but there are just a few. There might be more soon. Getting physicians with a hospital base rather than community trusts may be the biggest sticking point but I don't think that should be allowed to slide without making it clear that it is not the best answer.
This suggested proposal is not a demand, or even an ask, so much as a suggestion of what seems to make sense. This is only a 'consultation' process. I see no point in watering anything down. That is what has happened up until now and it has been a disaster.