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The following briefing has been created in partnership with our expert legal partner Mills & Reeve.

Primary Care Networks: What you need to know

GP contractors across England have been holding their breath awaiting the launch of the Primary Care Network Directed Enhanced Service contract (DES) following the announcement of the 2019/20 GP contract changes in January.

With the launch of the DES, the required Network Agreement and supporting guidance on 29 March 2019, many will be asking “what now?”  We provide some answers to various questions to try and demystify some core queries and concerns you may have.

What are the registration requirements for practices wanting to participate?

Practices wishing to establish a PCN must (by the 15th May 2019):

  • Give their ODS codes and identify their collective network patient list size. Note: For this purpose, the network considers its collective patient size as at the 1st January 2019.
  • Enter into the “core parts” of the pro forma Network Agreement.
  • Map clearly the network area.
  • Nominate a Clinical Director.
  • Nominate a practice (called the “Nominate Payee”) from within the PCN which will receive all DES funding that is payable to the network.

Commissioners will confirm that:

  1. the PCN registration requirements are met; and
  2. there is full network coverage in their locality no later than the 31st May 2019.

If these are not achieved, then a process of local discussion between commissioners, practices and the LMC will take place.

These timescales are tight, is there any leeway?

Yes. Despite initial concerns, the BMA and NHS England have reached a sensible position on the pre-requisites. While most should be achievable by the 15th May deadline, the necessity to enter into a Network Agreement was causing concern as any network is going to need to consider its objectives and operating model before moulding the Network Agreement to suit. Indeed, all PCNs should consider “function before form”.

With this in mind, it has now been agreed that practices need only sign up to the core elements of the Network Agreement by the 15th May 2019. They will then have up to the 30th June 2019 to finalise the full agreement. Even then, if agreement has not been reached the commencement of the DES will be delayed until agreement is reached.

How is the Network Area mapped?

The underlying principle behind a network area is set out in the PCN DES. This reiterates a point made in the five-year framework for reforming the GP contract to implement the NHS Long Term Plan.

It states that:

“Each Primary Care Network must have a boundary that makes sense to: (a) its constituent practices; (b) to other community based providers who configure their teams accordingly; and (c) to its community.”

While logical, there is clearly the possibility of conflict between these three limbs. As it stands, it is unclear which of these three limbs prevails, but it is likely to be the case that practices will seek to determine the network area that they believe works best for them. Commissioners will then need to consider the same and in doing so, and pursuant to the DES, they will be under an obligation not to unreasonably withhold or delay their consent.

We expect further guidance on the issues will ultimately be released.


How can we help?

Fixed price expert support for practices:

·         Choosing the right operating model

·         Considering potential pros and cons

·         Drawing up the Network Agreement

·         Considering and drawing up appropriate employment or sub-contracting arrangements

·         Understanding data-handling obligations and requirements within a PCN

Delivered by primary care experts Mills & Reeve and specialist accountants, our support is priced on a pence per patient rate and is designed to assist you and your fellow network practices.


Get in touch to discuss how we can help you >




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This information is provided by our expert partners Mills & Reeve who handle all of our family law matters. Find out more >