Primary Care Networks, has your PCN considered all the issues?

The new DES has all the good intentions for practices to work together to structure clinical care across their local population. The requirement is for practices to form a network of 30000 – 50000 plus patient populations, with funding available over a 5-year period. This typically will amount to around £1.47 million for a 50k patient population.

There is however a short time scale for practices to make the decisions required to establish an effective sustainable model of working together as a group.

The early stages will be to:

  • Confirm which practices will work together and establish the best model for your network
  • Agree the initial governance and appoint a clinical lead
  • Sign up to a network agreement and establish terms and accountability
  • Establish a transparent funding arrangement

Key considerations:

  • Think about which structure will work best including consideration of the legal and accounting matters

The BMA have recommended 5 potential structures

  • The flat alliance model – No one practice taking the lead
    • The lead practice model – One practice takes the lead role for all in the PCN
    • Federation model- The Federation /Provider organisation is used as a provider vehicle
    • Subcontracting model- to a non-GP provider organisation e.g. Hospital Trust
    • Super-practice model-The whole PCN sits within the one practice
  • Clinical Lead – How will they be appointed? For how long? Consideration as to employment or self-employment or reimbursed to practice for back fill. NHS Pension position needs to be understood.
  • The network agreement – Legal advice on the content and governance arrangements within the agreement should be addressed including dispute resolutions, risks and liabilities.
  • Employment – Consideration to potential VAT implications, employer obligations, auto enrolment and the NHS pension scheme
  • Governance and funding – Who will hold the funds and how will they be accountable to the other practices. The DES is an individual practice contract even though it is joint funding, therefore each practice’s annual accounts will need to reflect their share of the DES income and expenditure for tax and superannuation purposes. The fundholder will need to keep a transparent record of the transactions through the PCN bank account which summarises practice by practice the income received, and payments made

We recommend:

  • Take legal advice in respect of the PCN agreement and other legal aspects such as employment contracts.
  • Take legal and financial advice on the best model under which the network should work, this will require consideration of limited liability, if not immediately possibly in the future as the network establishes and grows.
  • We recommend that advice is taken from a specialist medical accountant to assess the nature of any proposed transactions to mitigate exposure to VAT 
  • We recommend that the accounting summary for the PCN DES transactions is prepared by a specialist medical accountant and their report attached to provide to each practice for their own accounting year end
  • Advice is sought from a specialist medical accountant who understands the NHS Pension Scheme Employing Authority rules

It is fair to say that as in many NHS initiatives they will develop and more advice will be issued over time, however if thought is given at the early stages the network can plan for a sustainable future.

MHA Moore and Smalley specialist healthcare team would be happy to have conversations with practices and their networks to offer our services. Please email Susan Charnock or call us on 01253 404404 if you would like to discuss this in further detail.