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Published 3 September 2019
We updated clients last month about NHS England and NHS Improvement’s Digital-First Primary Care Policy: consultation on patient registration, funding and contracting rules. The consultation sets out proposals to reform primary care contracting to enable digital-first providers to work better within the system, leading to fairer funding, ensuring patient choice and reducing health inequalities.
Read our response to this consultation below:
Proposal: If a practice exceeds a threshold number (suggested 1,000-2,000) of out-of-area patients from another CCG’s area, then its main contract will be disaggregated. The CCG in which those patients live will instead award a separate APMS contract to that practice (a “Satellite Contract”). The aim of this is to enable those patients to be better connected with local primary care networks (“PCNs”) and for the relevant CCG to pay directly and immediately for its patients’ care.
Our response: We agree that it’s important that practices with out-of-area patients are connected to those patients’ local health economies including primary care networks. We also accept that, under the current system where each CCG is responsible for its own budget, CCGs should be responsible for paying for services for patients who live in their area.
Where a practice has large numbers of patients from different CCGs, it would hold several Satellite Contracts and with this there are a number of issues that need further consideration:
Proposal: Before the above threshold is triggered, it is proposed that there is a more timely (quarterly is suggested) recalculation of CCG funding to reflect patient movements. The consultation also seeks views on postponing the payment of the new patient registration premium.
Our response: We agree that resources should follow the patient in a timely way. However, there is a lot of detail to work through to ascertain the cost of out-of-area patients which may be a significant burden on already-overstretched CCGs. Presumably the threshold for recalculation would be significantly lower than the threshold for awarding a Satellite Contract; but it would need to be high enough to avoid additional unnecessary administration. Presumably for this mechanism to work, this would need to be aligned with reviews of registered patient list numbers.
In terms of postponing the new patient registration premium until the patient has been with a practice for a defined term – safeguards need to be put in place to ensure that practices with new patients requiring additional resource in the first year are not financially disadvantaged.
Proposal: The proposal considers ways in which to award new APMS contracts to digital-first providers in deprived and under-doctored areas. These providers would be required to establish new physical premises from which to provide face-to-face services.
Our response: While the focus on under-doctored and deprived areas is welcome, this needs to reconcile with the NHS Long Term Plan’s objective to offer digital-first services to all patients. There is a danger that offering these contracts only in certain areas creates a mixed-economy of service provision across the country and is restrictive on the market. Any proposed national solutions should not be at the expense of local innovation around primary care service delivery.
In terms of the detail of the proposals:
It is important to balance the opportunity for local service provision with the opportunity for innovation. The proposal considers looking to PCNs as the default provider of primary care services in the locality. While this may help to support local service provision, it risks excluding providers from outside the area who could offer better value and different ways to provide services, perhaps powered by more advanced technology than a PCN has access to.
If you would like to discuss the issues we have raised in our consultation response, please contact:
London - Walbrook
+44 (0)20 7894 6411
+44 (0)113 251 4785
+44 (0)191 404 4119
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