The Lincolnshire LMC have been contacted by many practices over the past few days who have received an email from NHS England regarding their core hours.
In November 2017, NHS England issued guidance to commissioners regarding the definition of how practices meet the 'reasonable needs of patients' in providing or arranging access to essential and additional services delivered under the GMS contract. The guidance goes beyond the requirements on practices, as set out in the GMS contract, the PMS agreement and Regulations. Based on the guidance for commissioners, some practices have been approached by their CCG via NHS England to question their arrangements.
The GMS Regulations allow individual practices to decide which services to provide when, to meet the needs of their patients. Practices should be able to show that they have engaged with their Patient Participation Group (PPG) to check the arrangements are meeting their reasonable needs and take measures to address any areas of concern (recognising the requirements within the regulations regarding PPGs).
GMS Regulations defines:
core hours as 08:00 – 18:30, Monday to Friday (excluding Bank Holidays)
the essential and additional services which practices are required to deliver
GMS Regulations do not require practices to:
- be open at all times during core hours
- deliver all services at all times when they are open
GMS Regulations do require practices to (either themselves or through sub-contracting arrangements):
- provide services at times that are appropriate to meet the needs of patients
- ensure arrangements are in place for patients to access services throughout core hours in case of emergency (this allows practices to close for example to undertake training etc.)
The NHS England guidance asks commissioners to review the hours of service delivery and subcontracting arrangements for all practices. If the commissioner believes your hours of service provision are not meeting the reasonable needs of your patients, they will contact your practice. You should provide reasonable information to the commissioner, upon request, showing that the times of delivering services are appropriate to meet the reasonable needs of patients, and that at other times within core hours, there are arrangements in place so that patients can access services in an emergency. You should also show engagement with your patients (usually via the PPG) around hours and service delivery.
An information sheet detailing the sections of the contract referred to above is attached for reference.
Please be assured that we have also written to NHS England & the four CCGs regarding this matter.