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DR Solicitors’ clients to access employment advice as DSW Legal expands into employment law with the arrival of Apex Employment Solicitors

DSW Legal, the legal division of business advisory group Dow Schofield Watts (DSW), has welcomed Apex Employment Solicitors as a licensee, expanding its legal offering into employment law.

DSW Apex will be providing employment advice to clients of DR Solicitors. Apex’s experience includes involvement with tribunals involving the NHS, alongside its wider work with businesses across different sectors.

Founded in 2019, Apex advises SMEs on employment matters including disciplinaries, grievances, contracts, handbooks, redundancy and negotiated exits. It also represents employers and individuals in tribunal proceedings involving discrimination, unfair dismissal and breach of contract

The firm will operate as DSW Apex, led by founder Joanna Gooden, who becomes Partner and Head of Employment at DSW Legal. Headquartered in Maidstone, DSW Apex operates remotely, serving clients across England. Its four-person team comprises Joanna, two senior associates and an HR coordinator.

Joanna Gooden, Partner and Head of Employment at DSW Legal, said: “I’ve built Apex around strong client relationships and personal service. Joining DSW gives us the opportunity to build on that foundation, retaining our independence and client focus while benefiting from the relationships, infrastructure and wider expertise of an established professional services group.
“DSW’s entrepreneurial culture was a major attraction. Its network opens the door to a broader employer client base and gives us a platform to grow our team and develop practical training alongside our legal advice.

“As the first legal licensee, we also have an opportunity to help shape how DSW’s legal offering develops. We want to become the first point of contact for employment matters across the network, working closely with colleagues to give clients joined-up advice as their businesses grow.”

James Mallender, Managing Director at DSW Legal, added: “Welcoming Joanna and the Apex team is an important step in broadening our legal offering. They bring an established practice and employment expertise that will support clients of DR Solicitors and the wider DSW network.”

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NHS Surgery Leases: Succession Planning and Risk Appetite for GP Tenants

For many GP partners, the surgery lease is one of the most significant financial and legal commitments they will undertake during their career. While attention is often focused on rent reimbursement, service charges or lease renewals, it is succession planning and risk appetite that are equally important considerations because decisions you make today can have lasting consequences for both individual partners and the wider practice. As general practice continues to evolve, with increasing workforce flexibility, partnership recruitment challenges, and changing models of care, GP tenants must carefully assess how their lease arrangements align with their long-term succession objectives and tolerance for risk.

The Succession Planning Challenge

Historically, GP partnerships operated on the assumption that retiring partners would be replaced by incoming partners who would assume a share of the lease liabilities. In parts of the country, this model has become less predictable. The recruitment of new GP partners can be difficult, particularly where younger doctors favour salaried or portfolio careers rather than traditional partnership structures. As a result, existing leasehold partners may find themselves carrying property liabilities for longer than anticipated, with fewer successors willing to assume those obligations.

This creates a fundamental succession planning question: who will take over the lease commitments when current partners retire? The answer is not always straightforward. A lease that appears manageable today may become a significant burden if future partners are unwilling to become tenants or if the practice struggles to recruit replacement partners with an appetite for lease liabilities.

Understanding Continuing Liability

Many GP tenants underestimate the extent of their ongoing obligations under a surgery lease. Depending on the lease terms, outgoing partners may remain exposed to lease liabilities through authorised guarantee agreements, partnership indemnities, or other contractual arrangements. Even where a retiring partner successfully exits the partnership, there may be circumstances in which they retain residual exposure, e.g. if they are not removed from the lease once they have left the partnership (achieved by way of a lease assignment). Effective succession planning therefore requires more than identifying future clinical and non-clinical partners. It requires a clear understanding of how lease liabilities will be transferred and whether incoming partners are willing to assume those leasehold responsibilities.

Assessing Risk Appetite

Risk appetite varies significantly between GP partners and practices. At one end of the spectrum are practices that view lease obligations as an acceptable commercial risk; supported by the DV Report (a mandatory requirement for all NHS leases under the NHS Premises Costs Directions), a stable/growing patient list, strong finances and confidence in future partner recruitment. These practices may be comfortable committing to longer lease terms and accepting a degree of uncertainty regarding future succession. At the other end are practices that place a higher value on flexibility and risk reduction. These practices may be concerned about future recruitment challenges, changing NHS estate strategies, or the potential concentration of financial risk among a shrinking number of partners. Neither approach is inherently right or wrong.

The critical issue is ensuring that the practice’s lease structure reflects its’ collective risk appetite. A practice with a low tolerance for long-term property risk should carefully consider whether lease commitments extend beyond the period over which the partners have reasonable visibility of succession arrangements. Conversely, a practice willing to accept greater risk may place more emphasis on securing long-term occupational stability.

Aligning Lease Strategy with Succession Objectives

Succession planning should form part of every major lease decision. Before entering into a new lease or lease renewal, GP partners should consider several key questions:

  • How likely is it that future partners will be willing to become leaseholders?
  • What is the age profile of the current partnership?
  • Are there identified successors within the practice?
  • How easily could lease liabilities be redistributed if a partner retires unexpectedly?
  • Would the practice remain financially resilient if partner numbers reduced?
  • Does the lease provide sufficient flexibility to accommodate future organisational change?

These considerations should be evaluated alongside traditional commercial terms such as rent, repairing obligations, and lease length.

The Importance of Planning – when to start NHS lease negotiations?

One of the most common mistakes in GP property planning is delaying succession discussions until a partner announces retirement or the lease comes to an end. Break dates and the lease termination date should be diarised and we recommend you start planning at least 12 months in advance of any break date or the lease terminating so that you maximise your negotiating leverage.

Who should be named on the NHS lease?

The answer is not ‘the partnership’ because a partnership is not a business vehicle in its’ own right, unlike a limited company!

All Partners should be individually named as tenants on the lease, unless they are serving out a mutual assessment period. But when that mutual assessment period is successfully served out, that Partner should go onto the lease. Likewise, a retiring Partner should remain on the lease until the point at which they leave the partnership. This means that all partners are liable for the lease obligations and not a ‘selected few’.

If you make a commercial decision that you don’t want all Partners as ‘named tenants’ on the lease then you should have indemnities built into your partnership deed. But if you are a ‘named tenant’ on the lease, are you happy to rely on a contractual indemnity in the partnership deed for repairs/dilapidations? If your partnership deed has lapsed, you risk other partners just walking away claiming they have no liability. As a named tenant on the lease, you are also the Partner who may be served with a section 25 eviction notice (usually as part of a lease renewal process) and does that feel comfortable?

HM Land Registry

HM Land Registry will only register up to 4 partners’ names, but this is not a reason to limit the number of partners on an NHS surgery lease to 4. To say that it costs money to change the names on the lease when there is a change in partners, is not a good reason because it ignores the risk to the partners. The 4 partners named at HM Land Registry can be selected from the names on the lease in any order you choose. Commercially, if you know a partner is about to leave the partnership very shortly then it may decide not to include them on the lease, as long as the partnership deed is up-to-date. We will be exploring this issue in more depth in an upcoming blog.

Conclusion

For GP tenants, succession planning and risk appetite are inseparable from effective lease management. The key question is not simply whether a surgery lease works today, but whether it will remain sustainable as partners retire, recruitment patterns change, and general practice continues to evolve. Practices that proactively assess their succession prospects, understand their risk exposure, and align lease commitments with their short-term and long-term objectives are likely to be better positioned to manage uncertainty as well as protect both the practice and individual partners from unforeseen property-related liabilities.

In an increasingly complex primary care environment, a surgery lease should be viewed not merely as an occupational requirement, but as a strategic commitment that must be considered through the lens of both succession and risk. If you would like to discuss anything we have covered in this piece, or anything else, please get in touch here!

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Neighbourhood Health Centres: What Practices Need to Know

Why is this a Prevalent Discussion?

NHS England published its Neighbourhood Health Centre (NHC) Design and Performance Specification in April 2026 as part of the government’s wider neighbourhood health agenda. These documents provide a clearer indication of how neighbourhood healthcare may operate in the future and raise a number of important questions for GP practices.

NHCs are intended to bring together GP practices, community health services, social care, mental health, and other services within shared facilities serving populations of around 50,000, broadly aligned with PCN footprints. General practice is expected to be a core component of the model, with centres operating extended opening hours and supporting more integrated, multidisciplinary care. Areas with the lowest healthy life expectancy will be prioritised for early investment.

The Premises Transformation: From Leases to Shared Space

One of the most significant aspects of the NHC model is its approach to premises.

The Design and Performance Specification envisages highly utilised buildings where space is shared between multiple users rather than allocated exclusively to individual providers. The emphasis is on a flexible use of clinical and non-clinical space, supported by digital booking systems and coordinated management arrangements.

For practices accustomed to occupying their own surgery premises, whether owned or leased, this represents a significant cultural and operational shift. Questions immediately arise around who controls the building, who allocates space, how occupation costs are shared, and how disputes between different users are resolved.

However, the existing Premises Cost Directions 2024 support traditional ownership and lease arrangements, raising questions about how these will apply in shared occupancy models.

What This Means for Partnership Agreements

The NHC model raises immediate questions for partnership governance.
Partnership deeds typically vest decision-making authority over premises with the partners. However, the NHC model – with its emphasis on co-location with multiple services and extended opening hours- raises questions about how practices will exercise that authority.
Practices will need to consider whether their existing partnership agreements remain fit for purpose.

For example:

  • Who will make decisions about premises matters on behalf of the practice?
  • What authority will partners have to enter into new occupancy arrangements?
  • What happens if partners disagree about participation in a neighbourhood model?
  • How will partner exits and retirements be managed where premises arrangements become more complex?

These are issues many existing partnership agreements were never designed to address.

Operational Autonomy

The NHC model seeks to promote greater collaboration and integration between providers. Whilst this may create opportunities, practices will understandably want to understand how much control they retain over their day-to-day operations.

The guidance leaves a number of practical questions unanswered, including:

  • Who controls room allocation?
  • How are competing demands for space managed?
  • Who determines opening arrangements within the building?
  • What governance structures oversee the operation of the centre?
  • What influence will individual practices have over future changes?

Practices should take care to understand how these arrangements will work in practice before committing to any new model.

Opportunities for Practices

Whilst much of the focus is naturally on the risks and uncertainties, neighbourhood health centres may also present opportunities.

For some practices, NHCs could provide access to improved premises, upgraded technology and infrastructure that would be difficult to achieve independently. The model may also support closer working with community and specialist services, potentially improving patient experience and clinical pathways.

Practices struggling with ageing premises may also see neighbourhood developments as an opportunity to address longstanding estate challenges.

The extent to which these benefits are realised is likely to depend heavily on local implementation and the arrangements put in place within individual centres.

What should you do now?

Given the pace at which the NHC programme is moving, practices should take immediate steps.

  1. Review your existing lease and premises arrangements – understand your current obligations, break clauses, and options should your practice be identified for NHC consolidation.
  2. Review your partnership deed – consider if your existing governance arrangements adequately deal with the type of decisions that will arise in shared occupancy environments.
  3. Engage with your PCN and local stakeholders – NHCs are likely to develop differently from area to area. Early engagement may help practices better understand local proposals and influence how they evolve.

A practice should always seek specialist guidance given the fundamental impact these changes will have on primary care. If you would like to discuss how this guidance applies to your practice, then get in touch here.

by Sarah Cook

Legal Director

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DR Solicitors strengthens primary care expertise with appointment of Legal Director

DR Solicitors, a specialist healthcare law firm that’s part of DSW Legal, has strengthened its primary care team with the appointment of Sarah Cook as Legal Director.

Sarah joins from Porter Dodson LLP, where she spent more than four years helping to grow the firm’s primary care offering. During her time there, she advised GP practices and dentists on a broad range of legal matters, including partnership arrangements, partnership disputes, PCN matters and employment issues, while also playing a key role in developing the team. This contribution was recognised with the team’s first Chambers ranking for medical partnerships.

Sarah’s career in healthcare law spans more than 15 years and began with her training at Bevan Brittan, before moving in-house to the British Dental Association (BDA). During more than a decade at the BDA, she progressed from legal advisor to Head of the NHS Business Advice Team, advising dental practices across England and Wales on regulatory, contractual and operational matters.

In her new role at DR Solicitors, Sarah will focus on advising GP practices and other primary care providers through a rapidly evolving healthcare landscape, while also supporting the continued development of the firm’s specialist primary care team. Sarah will play a leading role in maintaining and growing the firm’s market-leading expertise, acting as a key point of contact for clients while also focusing on business development to bring in new work for DR’s consultants.

This latest appointment comes as DSW Legal continues to bolster its presence as a disruptor in the UK’s legal market. Having recently appointed James Mallender as Managing Director for the legal division, it is focused on attracting entrepreneurial legal teams to create their own practices, while continuing to expand its existing expertise at DR Solicitors.

Sarah Cook, Legal Director at DR Solicitors, said: “Having grown up in a family of dentists, and spending time working in my Dad’s practice, I’ve always had a vested interest in primary care. This passion has guided me throughout my career to support the important work primary care provides. It’s a sector that’s constantly evolving, and practices need advisers who understand not only the legal issues but also the wider operational and strategic challenges they’re facing.

DR Solicitors has an outstanding reputation in the primary care market and is recognised for the depth of its expertise. Joining a team with such a strong specialist focus was a natural next step for me. I’m looking forward to continuing to advise clients while helping to grow the team and ensuring practices have the support they need to navigate whatever comes next.”

James Mallender, Managing Director of DSW Legal, said: “Sarah is a hugely respected primary care lawyer and brings a wealth of experience from both private practice and in-house roles. Her understanding of the challenges facing GP practices and dental providers, combined with her commercial and pragmatic approach, makes her an excellent addition to the team.

“As we continue to expand our DSW Legal offering, we’re focused on bringing in the right people, bringing with them expertise that will strengthen our proposition in the market. Sarah’s expertise will be integral to doing just that for DR Solicitors, ensuring our clients can access the high quality support they’ve come to know, while our consultants can access fulfilling work.”

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Minimising Risk in GP Partnerships: A Brief Guide to Lease Renewals

Why is this a Prevalent Discussion?

Facing a long-term lease renewal is one of the most significant decisions a GP Partnership will make. An enduring lease with an institutional landlord represents a substantial commitment, and a substantial level of liability. The risk cannot be completely removed, but with the right approach, it can be meaningfully mitigated. At DR Solicitors, we regularly advise practices navigating exactly this challenge, and we wanted to share some real-world strategies.

Understanding the Risk

When Partners sign a long-term lease (15 years, for example), they are committing to a liability that extends far beyond most Partners’ anticipated working lives. Partners in their late 50s or 60s, presumably don’t want to be agreeing to a lease that binds them into their 80s or even 90s. Understandably, taking on liability in this case would be an unwelcome prospect. Hoping that a caretaker practice will come in and take over is not a great strategy to protect you against the risk that circumstances, whether political, economic or regulatory, might change. This is why proactive risk management is essential.

Strategies for Reducing Exposure

Negotiating a shorter-term lease:

This is often the first thought for GP Partnerships, but in practice is rarely achievable with institutional landlords. These landlords require long-term returns on their investment, with most PHP lease renewals including a condition requiring renewal on the same terms as before. A 3 or 5-year term is unlikely to be accepted. As appealing as it may seem at a first glance, there are clear difficulties with this approach, suggesting that GP Partnerships ought to consider other approaches as well as this one, to avoid a potential cul-de-sac.

ICB or Foundation Trust involvement:

In certain circumstances, it is possible to negotiate for the ICB or Hospital Foundation Trust to take the head lease from the landlord, with the practice then taking a shorter underlease from the new tenant – perhaps 5 years. This depends heavily on negotiating leverage and willingness to take discussions to the wire. The ICB and Hospital Foundation Trust have their own budget constraints, risk appetites, and competing priorities, making them generally reluctant to assume additional property liabilities. Nevertheless, a practice with some negotiating leverage, perhaps in the form of a significant patient population or lack of local alternatives, may succeed in persuading these bodies to step in if they can be convinced these primary care services may be lost without intervention.

Step-in rights:

‘Step-in rights’ from the ICB or Foundation Trust are another possibility but are only triggered in specific circumstances. For example, where the ICB agrees to step in to assume the lease directly or arrange for another provider to take it over if the doctors decide to hand their contract back. This arrangement is typically documented in an agreement between the landlord, tenant (GP Partnership), and a third party (like the ICB).

Limited company structures:

This can limit partner liability but is primarily a tax-driven decision that typically takes 6 to 9 months to implement. Therefore, it is not an immediate solution, but could be worth long-term consideration for certain GP Partnerships.

The Critical Importance of the DV’s Funding Letter:

For practices remaining as Partnerships, the District Valuer’s funding letter is arguably the most important document after the lease itself. Under the Premises Costs Directions 2024, it is mandatory for the tenant to obtain this confirmation that the lease costs will be funded ‘back-to-back’ with the rent reimbursement from the NHS.

This letter should be treated as a key title document, kept alongside the lease, and reviewed carefully. Any future acquirer conducting due diligence on a potential merger or acquisition will scrutinise this document closely. Think about where the practice is now and where it could be in 3, 5, 10 and 20 years’ time—because agreeing a long-term lease means long-term liability for Partners.

What About Switching Away from a GMS Contract?

A final point worth noting is that some partners facing long lease commitments consider terminating their GMS contract and shifting to another contract, such as APMS.

A GMS contract is evergreen – it has no end date. An APMS contract, on the other hand, is time-limited – typically 10 years. After which it goes out to tender, with no guarantee of success. Every larger provider, every acquisitive neighbouring practice, every PCN and Federation in the NHS marketplace is looking to acquire GMS contracts precisely because of their permanence. Short-term contracts, conversely, discourage long term investment.

The GPC is currently negotiating with the Government to allow GPs to hold GMS contracts via an LLP, but this is not yet possible and is not a fast fix.

Get in Touch

Lease renewals require careful thought about your practice’s current position and future trajectory. The earlier you take specialist advice, the more options you have to mitigate risk and protect partners from disproportionate long-term liability. Whether you are facing an imminent renewal or simply want to review your existing arrangements, our Primary Care team is here to help. If you would like to discuss your situation, please contact us today here.

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DSW launches legal arm with appointment of new MD

Business advisory group, Dow Schofield Watts (DSW) has expanded its legal offering with the launch of a dedicated new division, DSW Legal, spearheaded by James Mallender, who has been appointed Managing Director.

As a challenger legal platform, DSW Legal is built to attract leading talent looking for an alternative to traditional partnership models. Building on the success of DR Solicitors, which DSW acquired in 2024, DSW Legal will focus on a number of key sectors, supporting DSW’s wider professional services offering to build out the group’s full business advisory platform.

Heading up the new division, James brings thirty years’ experience from across both leading City law firms and high-growth legal businesses. Having qualified as a real estate lawyer with SJBerwin, he made the move to international firm Womble Bond Dickinson, becoming a partner in 2008.

Realising the partnership model wasn’t for him, James left in 2012 left to help grow the legal start-up, The Legal Director. As one of the first platform law firms, James built and ran the firm’s recruitment function, alongside developing its go-to-market and overall strategy. By the time he left in 2025, the business had grown to around £7m in turnover and a team of over 50 lawyers, establishing itself as the UK’s largest provider of fractional general counsel services to businesses.

As Managing Director of DSW Legal, James’ experience will be instrumental in building out the new legal arm for DSW, with a focus on recruiting legal professionals with ambitions to set up their own business, with the backing of an established professional services brand.

DSW first entered the legal market with the acquisition of Guildford-headquartered DR Solicitors in 2024. The platform business provides consultants with work across the medical profession, including acting for GPs and dentists, giving them flexibility to choose how much work they take on, and when. Since the acquisition, DR Solicitors has added an additional 10 consultants, with revenues increasing by 11%.

James Mallender, Managing Director at DSW Legal, said: “Having built my career on both sides of the legal profession, I’ve seen firsthand how ambitious professionals are increasingly looking to alternative models to take control of their career. DR Solicitors has already proven itself as a model that can stand up against traditional models, providing the flexibility and control many look for, so the opportunity to expand this track record across DSW Legal provides a true challenger platform for the industry.

“I’m now focused on building out the offering, recruiting ambitious legal professionals who want the opportunity to be more entrepreneurial while still benefitting from a supportive environment with a strong brand and back office.”

Shru Morris, CEO of Dow Schofield Watts, added: “
Building on the progress we’ve made in our legal offering through the acquisition of DR Solicitors, DSW Legal provides a strong platform to continue building out that capability and better meeting client demand. It also offers an attractive home for top legal talent seeking an alternative career path, enabling them to establish their own business under a recognised brand, with the benefit of back office support, strategic input and start up funding.

“With his strength of expertise in growing challenger legal platforms, James is an excellent addition and will be integral to building this new division out further, leveraging the power of DR Solicitors to attract new talent and create a full service offering.”

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Creating a Single Neighbourhood Contract via the PCN DES

On 30 April 2026, NHS England published an updated Network Contract DES Contract Specification for 2026/27. It took effect the very next day. Interestingly, this was only a month after the original 26/27 DES had been published, so what had changed in such a short period of time? The answer is what could prove to be one of the most significant developments in primary care contracting in recent years: the DES Local Variation Arrangement, or “LVA”.

In this blog, we take a first look at what has changed, what we like about it, and what might give cause for concern.

What Is the Local Variation Arrangement?

The LVA is a new mechanism that allows a commissioner (an ICB) to submit a written request to NHS England for the establishment of a local variation to the PCN DES. In plain terms, it enables ICBs to propose changes to key parts of the PCN DES specification to suit local needs, subject to NHS England’s approval.

A Local Variation Arrangement may vary sections 7, 8 and 10.1 to 10.5 (inclusive) of the Network Contract DES Specification. To put that into context, those sections cover the Additional Roles Reimbursement Scheme (ARRS), the Service Requirements (including enhanced access, care home arrangements, collaboration obligations, and health improvement targets), and significant parts of the financial entitlements framework. The Investment and Impact Fund (IIF), however, cannot be touched.

The scope of what can be varied is striking. In principle, an ICB could propose to delete clause 7 entirely — effectively removing the ARRS — and replace it with something else altogether, such as an outcomes-based payment model or a locally defined set of KPIs. Similarly, the service requirements under section 8, including enhanced access provisions and NHS 111 obligations, could all be replaced. Even requirements introduced as recently as the 26/27 DES published the previous month could, in theory, be varied or removed.

There are no specified parameters limiting the degree to which these sections can be changed, beyond the requirement for NHS England approval. However, the LVA request must include the proposed variation wording, the rationale for the variations, and crucially, an explanation of how the proposed changes support delivery of the Network Contract DES for the PCN’s patients. So while the scope of permissible variation is wide, it is not a free-for-all — NHS England retains the final say.

What We Like About It

It builds on existing infrastructure. Perhaps the most immediately attractive feature of the LVA is that it does not require the creation of anything new. It builds on the PCN infrastructure that practices have spent years developing — whether that is through a lead practice model, a flat structure, a PCN company, or a federation. Whatever model a PCN has adopted, the LVA can sit on top of it. There is no need for new entities, new governance arrangements, or a procurement process. It is, as a consequence, a rapid way to start delivering locally defined services within a neighbourhood, assuming that neighbourhoods and PCNs are broadly aligned.

It preserves the independent contractor model. Because the PCN DES is a variation to each practice’s primary medical services contract, the LVA operates at practice level. Practices remain the prime contractors. This is a significant distinction from a potential single neighbourhood contract, which would almost certainly not be contracted at practice level and would likely involve a different entity — such as a PCN company or a federation — holding the contract. The LVA locks DES income into practices as practice-level revenue, which must be good news for those who value the independent contractor model.

It creates a “LES-DES hybrid”: national funding, local specification. In effect, the LVA creates something that has never quite existed before — a nationally funded enhanced service with locally defined content. The funding envelope remains set by NHS England, but what is delivered within that envelope can now be tailored locally. This is, in practical terms, a hybrid between the DES (national, centrally specified) and a LES (locally commissioned, locally designed) — and it is a genuinely novel construct in primary care contracting.

It offers radical devolution. The PCN DES has historically been a prescriptive, centrally driven contract. The LVA represents a significant relaxation of central control. The fact that so much of the specification is now, in principle, open to local variation is quite astonishing. It is, in essence, NHS England devolving power locally, enabling ICBs to tailor services to the specific demographic and health needs of their populations rather than persisting with a one-size-fits-all model.

It offers flexibility on geography. Interestingly, there appears to be nothing in the specification requiring a Local Variation Arrangement to apply to a geographically contiguous area. An ICB could, for example, apply the same variation to several PCNs/neighbourhoods scattered across its footprint that share similar demographic profiles — such as areas with high deprivation — without those PCNs needing to be geographically adjacent. An ICB could equally choose to have different variations for different groups of PCNs within its area, tailored to their distinct local needs. This kind of demographic-based flexibility is genuinely novel and could be a powerful tool for addressing health inequalities.

It is a credible alternative — or at least a precursor — to the single neighbourhood contract. The single neighbourhood contract remains a concept coming down the pipeline and will doubtless be implemented by many ICBs. When it does arrive, it will face significant implementation challenges: there is no entity structure for neighbourhoods, no governance framework, and a probable need for procurement. The LVA avoids all of those problems. For ICBs that are happy with their PCN footprints and want to start delivering locally defined neighbourhood-level services now, the LVA provides a credible route to do so without waiting.

What Might Be Problematic

ICB capability. ICBs are currently undergoing major cuts. The LVA requires ICBs to do a significant amount of work: drafting proposals, engaging with practices, navigating the approval process, and implementing variations. Whether ICBs have the staff and the capability to take advantage of this opportunity is a genuine question.

Lack of guidance. At the time of writing, there is no published guidance from NHS England as to what kind of changes it would or would not be likely to approve. ICBs are, to a degree, groping in the dark. Without a framework of expectations, there is a risk that ICBs either propose too little (for fear of rejection) or invest significant time and resource into proposals that are ultimately refused. This uncertainty is arguably the biggest practical barrier to uptake.

Central approval requirements. Every proposed variation requires NHS England’s approval. The more flexibility an ICB wants, the harder the approval process becomes. If a single ICB has 30 PCNs and wants multiple different variations, that is a significant volume of work flowing to the centre for sign-off. One has to hope that NHS England is adequately resourced to manage that process.

Getting practices on board. The LVA is, at its heart, still a DES — an enhanced service that operates on an opt-in basis. Before a Local Variation Arrangement can take effect, the commissioner must provide confirmation and evidence that each Core Network Practice has agreed to participate on the terms approved by NHS England. Unanimity within a PCN appears to be required. This means that a single practice within a PCN could, in principle, hold things up. If a practice refuses to sign up, the DES simply continues without modification for that PCN. Any proposed variation will therefore need to be demonstrably more attractive than the existing DES to get practices across the line.

Complexity if run alongside other models. Although no ICB would sensibly attempt to run LVAs alongside separate single neighbourhood contracts, (or indeed create a plethora of LVAs) there is nothing in the specification that precludes it. The potential for complexity and administrative burden is considerable.

What Does This Mean for Practice Finances?

One dimension that deserves particular attention is the financial impact on individual GP practices. PCN and enhanced services income typically represents around 30% of total revenue for a GP practice. A shift in how that funding is controlled, directed, or conditioned could, over time, affect both profitability and viability if not planned for. By locking this all in at practice level LVAs should be more attractive for individual practices than single neighbourhood contracts, but it does mean that the complex ‘shared cost/revenue model of PCNs will continue. Embedding control and governance of money at PCN/neighbourhood level will be more important than ever.

Are PCNs Organised for This Next Phase?

The LVA increases both opportunity and responsibility for PCNs. Networks are now expected to manage larger and more complex funding streams, employ or host multidisciplinary teams at scale, deliver locally tailored services, and act as credible partners with ICBs.

For some networks — particularly those that delayed structural decisions while waiting for clarity on neighbourhood contracts — incorporation or the use of an established federation model may now merit serious consideration. This is not about rushing into change, but about recognising that the PCN’s role is becoming increasingly central to service delivery and that governance arrangements need to be fit for purpose.

Practical Steps to Consider Now

While much will continue to evolve, there are some sensible steps practices and PCNs can take now.

First, understand your local neighbourhood model. In most parts of the country PCNs are evolving into neighbourhoods, but LVAs and single neighbourhood contracts are both aimed at neighbourhoods, not PCNs. Make sure you understand how your single and multi neighbourhood model is evolving.

Second, revisit PCN governance arrangements. Ensure decision-making, financial controls, and risk-sharing are clearly documented and understood. If you are still operating on the original Network Agreement without review, now is the time.

Third, engage early with your ICB. ICB reorganisations have created gaps — but that also means this is the moment when future direction is set by those who engage first. If your ICB is exploring LVAs, you want to be part of that conversation from the outset. This kind of engagement is probably best led at scale by your LMC.

Over time we expect to publish further, more detailed analysis of the specific provisions that can be varied and the opportunities that may arise from them. In the meantime, if you have any questions about the LVA or the updated PCN DES, please do not hesitate to contact us.

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The Neighbourhood Health Framework: Key Takeaways for Primary Care Providers

The NHS is undergoing one of its most significant structural transformations in recent years. The recently published Neighbourhood Health Framework builds on the 10 Year Plan and signals a fundamental shift in how healthcare services will be commissioned, contracted, and delivered. For GP practices, PCNs, and other primary care providers, understanding and planning for these changes is essential for survival.

At DR Solicitors, we have been working closely with primary care clients to help navigate the emerging neighbourhood landscape. This Framework brings together much of what we have observed, whilst raising important questions that providers must consider urgently.

A Paradigm Shift: The Major Changes

The end of PCNs as we know them

Perhaps most striking is the near absence of any reference to PCNs. The sole mention confirms that the government “will consult on how primary care networks might evolve into SNPs (Single Neighbourhood Providers).” This leaves a substantial question mark over services and funding currently contracted through the PCN DES.

In practical terms, PCNs will become “Neighbourhoods.” While many will operate on an identical footprint to existing PCNs, others will not. This transition from a network to neighbourhood model represents a fundamental change in the legal and contractual architecture of primary care.

A New Hierarchy of Population-Based Contracts

Until now, primary care contracts (GMS, PMS, and APMS) have been the only truly population-based contracts in the NHS. The framework introduces a new hierarchy of 3 new population based contracts: Single Neighbourhood Contracts (SNCs) for populations of 30,000-50,000; Multi Neighbourhood Contracts (MNCs) for around 250,000; and, at the apex, Integrated Health Organisation (IHO) contracts covering one to three million people. The government intends these to be “nested” within a coherent geographical hierarchy, creating organisational and legal complexity that providers must plan for.

The Implications: Risks and Opportunities

Funding Migration and Loss of Control

The most pressing concern is that PCN (and possibly also some Enhanced Service) funding will migrate into SNCs. Critically, whoever holds the SNP contract will control this funding. Currently, GP practices are the prime contractors under the PCN DES, but in a neighbourhood world they risk becoming subcontractors to the SNP. Our assessment is that GP practices & PCNs risk losing 25%+ of their combined income to the Single Neighbourhood Provider.

Practices who do not secure access to these contracts risk becoming financially unviable. Unlike the PCN DES (which is exempt from procurement rules as an Enhance Service), neighbourhood contracts may well be open to competitive tendering, and so it is critical that PCNs plan for how they will bid for and deliver these contracts – even though the details are not currently fully understood. With the notable exception of single practice PCNs, most PCNs lack legal personality and so will not be able to hold these contracts themselves. PCNs/Neighbourhoods should therefore urgently consider either setting up their own PCN/Neighbourhood company, or consider whether they are comfortable being a subcontractor to a third party, such as a federation, who controls the SNC on their behalf.

Opportunities Within the Hierarchy

There are significant opportunities within the new contract hierarchy for those willing to organise appropriately. GP Federations are generally around the population size of most MNPs, so they would be well placed if they ensure they are appropriately ‘nested’ geographically and have established effective collaborative working arrangements with other providers of primary and community care.

Even at IHO level – where contracts “will only ever be held by NHS organisations” (ie Trusts) – the Framework plans routes for “mature neighbourhood providers to lead an IHO through alliances or joint ventures with statutory NHS organisations.” The clear intent is that General Practice should take cornerstone roles at all levels of the population based contracts, but the obvious challenge is that the necessary governance and entities do not generally exist, and complex questions around staffing, data, VAT, insurance and more will all need consideration in due course. Providers who move quickly to establish governance models will be best positioned.

Local Flexibility

In a departure from NHS England’s usual centralised approach, ICBs and local communities will have significant latitude to develop their own contracting models. The immediate emphasis is on local experimentation – different geographies are developing different solutions, and those who engage proactively with their ICB will have greater influence. Again, this may be a real opportunity for local primary care leadership.

Neighbourhood Health Centres (NHCs)

NHCs represent a far more ambitious vision than the traditional GP surgery. They aim to “bring together GP services with community, local authority, civil society and VCSE sector services,” including co-location with family hubs, food banks, and employment support. As ever though, the problem is finance. Wave 1 (2026-2027) will focus on repurposing existing NHS Property Services and LIFT estates in deprived areas, but given the well-known problems with service charges in many of these buildings it Is hard to see how repurposing can work without first addressing these historic costs; future waves are supposed to include new builds funded through public-private partnerships, but we will have to wait and see how a building incorporating the voluntary sector could ever be financed in this way.

Practical Steps for Providers

Every strategic decision must now be considered through the neighbourhood lens. Providers must urgently consider how to contract for neighbourhood contracts and how their estate fits within the NHC model. Now is a good time to reconsider your PCN operating model, and practices with service charge disputes with NHS Property Services or CHP may find this an advantageous timing to negotiate.

The NHS is moving decisively towards neighbourhood-based commissioning. This creates opportunity for those who embrace change; for those who do not, the consequences may be severe. For further thoughts on the impact of these changes, please listen to our recent webinar on Preparing for Neighbourhood Contracts, and please do get in touch here to discuss your particular practice, PCN or Federation needs.

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When Partnerships Break Down: Navigating Primary Care Conflicts

Why Early Legal Advice is Your Best Investment

Partnership disputes in general practice rarely materialise overnight; they manifest over time, through various means including tensions around workload, commitment to the practice, money, differing views on the practice direction (stabilize, scale up by merger/acquisition, dispose, terminate NHS contract), patient safety concerns, poor professional practice behaviours, and so on. When left unaddressed, ‘annoying but tolerable irritations’ fester and escalate into a conflict that consumes time, causes stress and ultimately costs money because it threatens the viability of the practice itself. At DR Solicitors, we believe there is a more proactive approach which can be taken to mitigate these issues. Too often, practices reach out when relationships have already deteriorated and the only apparent option is formal litigation, when in fact resolving conflicts earlier can achieve more sustainable outcomes.

The Problem with Waiting before Taking Legal advice

There is a pervasive belief that instructing a solicitor should be a last resort. The concern, understandably, is cost. Legal fees can seem daunting so as a result, partners turn to sources of free advice including ChatGPT. While well-intentioned, these sources are unlikely to provide the specialist, healthcare advice needed to navigate a primary care partnership dispute.

When a dispute lingers on, relationships deteriorate, partner and staff morale plummets and good people leave. Before long, the practice has lost its resilience and it is unattractive to incoming partners. The good news? All of this damage can be avoided with the right, strategic legal advice at the start and sticking laser-focused to the goal.

Preparation Before the Meeting

When conflicts arise, the instinct is often to call an urgent practice meeting. This is rarely wise without preparation. Walking in without a clear agenda, defined objectives and an understanding of your legal position is a recipe for escalation.

Before any meeting, consider what outcome you actually want and take advice on your legal and commercial options at the outset. The right advice can hugely improve your negotiating leverage. Are you seeking to preserve the partnership, or is separation the best path? Do you want changes to working arrangements and profit shares? Next, understand your legal position. Review your Partnership Deed and the rights it creates. If you operate without a formal Deed, you are governed by the Partnership Act 1890, which may not reflect your intentions. Taking legal advice at this early stage is invaluable because a specialist solicitor can help you assess your position so you can approach negotiations with confidence and make informed, sensible decisions.

Every meeting should have a written agenda and clear minutes. Remember: everything you put in writing yourself is potentially disclosable; privileged communications with your solicitor remain confidential.

Choosing Your Dispute Resolution Route

If informal negotiation fails, you will need more structured processes. The three main options are mediation and, rarely, arbitration and court proceedings.

Mediation is a voluntary, confidential process where an impartial third party, known as a mediator, facilitates agreement and communication between parties, aiming to find a mutually agreeable solution for all. It is typically faster, less expensive and preserves relationships because it is collaborative rather than adversarial. Given there is no goodwill in a medical practice, if a dispute has reached this stage (most do not) the case is settled at mediation

Arbitration is more formal but the key positive (in comparison to the public courts or the Employment Tribunal) is that the arguments remain private. It is essentially a ‘private court’ where an arbitrator issues a binding decision. Most GP Partnership Deeds specify arbitration, and you can choose an arbitrator with healthcare expertise to fit the dispute. So you can appoint a healthcare surveyor to arbitrate a surgery valuation dispute or a healthcare accountant to arbitrate a financial dispute. But we work hard to settle a dispute before we get to this point because of the fact that there is no goodwill in an NHS practice so in most cases, the costs are prohibitive.

Court proceedings are heard in the High Court which is a public forum, and therefore the world can read about your dispute. It is slow because of the backlog in getting a hearing pencilled in, expensive and adversarial. It tends to destroy remaining relationships so in our view Court proceedings for a private GP partnership dispute should generally be a last resort.

Why Early Instructions to a Healthcare Lawyer can save Money

Instructing a specialist, primary care, dispute resolution solicitor early reduces your business risk and your costs. Early advice helps you avoid tactical errors: ill-advised emails and social media posts, verbal outbursts that are not thought through and most importantly, failing to follow the dispute resolution procedures set out in your Partnership Deed. You paid for a Partnership Deed so use it, and if you do not have a Partnership Deed in place then you clearly have a high risk appetite! Our team of highly skilled GP dispute resolution lawyers can quickly assess whether your GP or non-clinical partnership dispute is worth pursuing and identify the most appropriate route. Sometimes the best advice is to compromise early; sometimes it is to stand firm and hold out for a better deal.

Get in touch

Whether you are facing an emerging dispute, navigating a difficult partnership conversation, or simply want to review your Partnership Deed, our specialist team is here to help. The earlier you reach out, the more options you have and the lower your costs are likely to be. Contact our Primary Care team today here — the sooner we talk, the more we can do to help.

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Webinar: Preparing for Neighbourhood Contracts

In this webinar, Nils Christiansen from DR Solicitors and Guy Vine from MHA discuss issues surrounding the preparation for Neighbourhood Contracts. This fascinating webinar covers a variety of topics, including an overview of the neighbourhood and multi-neighbourhood models, challenges, opportunities and impacts, as well as what PCNs and Practices can do to prepare.

If you would like to get in touch about any topic covered in the webinar, please click here.

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