NHS 10 Year Plan: Time for Primary Care to take the lead?
Why PCNs and GP Federations must act now
The NHS 10 year plan is 168 pages long and looks to address all the many problems of the NHS. As such, it can be difficult to identify what is relevant to primary care and, most importantly, what should primary care be doing now to prepare for the changes? The plan is clear that money will be shifted out of secondary care into ‘neighbourhoods’ and that primary care is expected to be at the heart of neighbourhoods. However, it is also clear that if GPs do not step up to lead the new ‘neighbourhood health service’ created through two new contracts, then others, such as Foundation Trusts, will be offered the chance to lead.
A new three–tier structure for primary and community care
The plan envisages three ‘tiers’ of primary and community healthcare provision.
Tier 1
Tier 1 is still the individual GP practice with its patient list and practice area. Unsurprisingly, the plan refers to improving access and to increasing use of the NHS app as a portal to GP practices, but otherwise it has very little to say about the way practices operate. The plan’s view is that the “status quo of small, independent practices is struggling”, and where appropriate, an alternative is needed. That alternative is two-tier neighbourhood working to be facilitated through 2 new contracts covering larger populations, and we consider these below. From an individual practice perspective, the most impactful changes will come from the ongoing GMS contract negotiations, which we anticipate will facilitate changes to the contractor model which have been well signposted by the Minister for Health.
Tier 2
Tier 2 in the new structure will be individual neighbourhoods. These will be areas of approximately 50,000 patients, and unsurprisingly, the plan states that “the existing primary care network (PCN) footprint is well set up as a springboard for this type of working”. The first of the new ‘single neighbourhood contracts’ will be offered in 2026 and will relate to ‘enhanced services for groups with similar needs’. However, the obvious problem is that many PCNs are not currently in a position to bid for these new services. PCNs were deliberately established through the PCN DES, which is contracted as a practice level enhanced service, so as a starting point, the PCN has no legal status and is not able to contract for anything. PCNs have often worked around this issue through ‘lead practice’ and ‘flat practice’ operating models, but these are unlikely to work well for the new single neighbourhood contract.
Therefore, as a matter of urgency, every PCN should now be reviewing its structure and considering whether to either set up a PCN shared company (a.k.a PCN incorporation) or whether to work closely with an existing GP Federation. Those who already have PCN companies should be considering how the company can be modified to move from being a PCN costs sharing arrangement to also becoming a neighbourhood contract holder and potentially an independent provider. Reviewing governance will be key here.
Tier 3
Tier 3 will be ‘multi-neighbourhood providers’ (‘MNPs’) covering a population of 250k+. The plan acknowledges that this may often be similar to the footprint of existing GP Federations, and the new contracts have the potential to breathe new life into organisations which have sometimes struggled since the extended access contracts were incorporated into the PCN DES. The vision for MNPs is both as at scale providers of complex service provision, such as end of life care, drawing on multiple service providers, and as a provider of back office, service transformation and estate strategy services. They are also expected to step in and take over struggling practices and will presumably have a significant role to play in planning the proposed new Neighbourhood Health Centres. These organisations are clearly expected to go far beyond traditional primary care, but if GPs are not at the heart of them, then they may quickly become a threat to independent primary care in their area. The alternative model is stated in the 10 year plan: “we will create a new opportunity for the very best NHS FTs to hold the whole health budget for a defined local population as an integrated health organisation (IHO).”
An immediate action is therefore to assess what GP-led multi-neighbourhood providers already exist in your area/Place, and to assess their fitness for purpose. The new multi-neighbourhood providers will have to ensure that they are able to both represent and support primary care practices and be inclusive of other community based providers. We would expect that this will require significant changes in governance even for the best run GP Federations, and in many locations entirely new provider entities will be required. Given the complexity of the task ahead this process should be started urgently, or ICBs will have little alternative but to offer these contracts to existing at scale providers who will often be community trusts or large private providers.
Our NHS 10 Year Plan Conclusion
Despite the size of the NHS 10 year plan, much is still very unclear about the near future. However, given that most of any additional primary and community funding is likely to come through the two new neighbourhood contracts, it is critical to start preparing for them now. Not doing so risks leaving primary care unviable as it is unlikely that significant funding shifts will happen into GMS.
How can we help?
At DR Solicitors we have a great deal of experience of supporting primary care at scale. We have acted for over 250 PCNs and are already in the process of constructing a number of multi-neighbourhood providers. Please contact us for a no-obligation conversation about how we can help you to better prepare for the future.
