NHS Improvement and NHS England have launched a consultation on its proposals for reform to patient registration, funding and contracting rules as part of its digital-first primary care (DFPC) policy to ensure patients have both choice as well as access to integrated care.
Proposals include changes to primary care contracting rules to enable DFPC to work better and to harness the potential of digital providers to help improve GP capacity issues and improve patient access to services.
NHSI/E’s consultation proposals form part of the commitments made in the NHS Long Term Plan that every patient will have the right to be offered DFPC by 2023/24.
Specific patient commitments, include:
- By April 2020: online access to medical records.
- By April 2021: access to online and video consultations.
Appetite for the new digital GP providers
We have seen a growth in digital GP providers offering a model which allows patients to register with them directly and contact the practice through an app. These providers are proving convenient and popular with patients but under current arrangements, the expansion of these models has taken place by registering patients across wide geographies from a single GP practice. The widely cited example, is the expansion of a practice in Hammersmith and Fulham to register patients in Birmingham, as it is permitted to do under the current General Medical Services regulations.
But these new and emerging arrangements create a number of new challenges:
- Delivering integrated local care services becomes more complex.
- NHS funding currently flows following a patient’s registration with a GP – this means that CCGs with high numbers of out-of-area registrations become responsible for the healthcare costs of patients registering with a digital provider in their area, in advance of the adjustment, which is then made to funding allocations. And many argue that this is unfair.
Why consult?
The consultation sets out proposals and options to:
- Ensure the money follows the patient.
- Make it easier for existing GP surgeries to expand and improve their own digital services.
- Ensure that DFPC providers can register new patients in areas where people cannot currently access digital GP services.
So, what needs to change
The consultation document is divided into four chapters, each setting out options and proposals for reform.
Chapter 1: Current out-of-area placement registration rules need to change – in a way that maintains patient choice
Proposals cover amending the out-of-area registration rules so that where a practice exceeds a threshold number of out-of-area patients in any CCG, then their main contract will be disaggregated to create new, local practice contracts, linked to local CCGs and PCNs.
Chapter 2: Proposal to change the CCG allocations system
The proposal should be timely and quarterly to reflect patient movements “of the sort which have been stimulated by registration with digital-first practices in London”.
Chapter 3: Changes to the GP payment formula
The expansion of DFPC models over the past two years has driven the need to review the new patient registration premium – with three options open for discussion from abolishing the new PRP, retaining it to keeping it but setting stricter criteria for its payment. Given that new patients generate extra work for practices, it is proposed to maintain the premium but only pay it if a patient remains registered with a practice for a defined period. Views are invited on that period, but proposals include six to twelve months.
Chapter 4: Review allowing other digital providers to set up and start registering patients in any part of England
The options here could help increase overall GP capacity as well as increase the choices available to patients.
In addition, NHSI/E suggest removing “the need for most local APMS procurements by looking to PCNs as the default mechanism for maintaining primary care provisions.” Views on this are set out in chapter four.
Have your say – don’t delay the consultation closes on 23 August
You can share your views by completing the survey here – chapter five details how to get involved. NHSI/E are keen to hear from GPs, primary care clinicians, charities, the technology industry, CCGs and others on the proposals for reform.
Some of you may have attended TechUK’s event yesterday which it hosted with NHSX, NHSI/E to look at the proposals set out in the digital-first consultation document.
Our content explained
Every piece of content we create is correct on the date it’s published but please don’t rely on it as legal advice. If you’d like to speak to us about your own legal requirements, please contact one of our expert lawyers.