As stipulated in the NHS Premises Costs Directions 2013, the CCG must not agree to any funding where a contract has been entered into, or work has already commenced, but prior approval from the CCG and NHSE has not been granted.
There is an approval process which Practices must follow. This approval process is applicable for any proposed building work/project to improve GP Practice premises, and is relevant for schemes ranging from a simple reconfiguration (e.g division of a large room into two small rooms) through to a major project (e.g extension, relocation or new build).
The approval process must still be adhered to in instances whereby a project is entirely self-funded by a Practice.
Depending on the scope and cost of the scheme the approval process is either a single-stage, 2-stage or 4-stage. The attached Business Case Approval Process Flow Chart and Business Case Approval Process Guidance provide a summary of the 2 stage and 4 stage process, they can also be found in the Related Documents drop-down. The single stage process is reserved for very minor schemes and is applied at the discretion of the CCG.
There are many benefits available to GP Practices in return for following the process, and there are multiple reasons as to why the approval process is in place. Both of these are summarised below:
Benefits to GP Practices
By adhering to the Business Case Approval Process, GP Practices can benefit from the following:
Primarily there may be funding available for the project from NHSE/I or the CCG, or from Section 106 (S106) monies or Community Infrastructure Levy monies (CIL) held by the council. We are unable to retrospectively apply any such funding to schemes which have not been submitted for approval.
Increased Rent Reimbursement / Notional Rent
Any increase in GMS footprint of the Practice will have a consequence on the rent reimbursement / notional rent payments. Providing that the project is submitted to and approved by the CCG and NHSE/I, the Practice will receive the respective increase in such payments, which will be ascertained by the District Valuer.
Any Practice which does not seek approval for a project which increases their GMS footprint will not be entitled to the increased rent reimbursement or notional rent payments relative to the increase in footprint.
IT Support and financial assistance
Practices are able to receive IT support in terms of connectivity and hardware supply/installation and the costs of such are covered under the GPIT funding pot. Any Practice who does not seek approval for a project will be required to cover the IT costs relating to the project themselves.
Reimbursement of Professional Fees
Practices are entitled to seek reimbursement of professional fees (architects, surveyors, engineers, project management) which are incurred throughout the project. By implementing a scheme without approval, a Practice waives their right to this reimbursement.
Advice and Guidance
Practices are able to seek guidance from the CCG and NHSE/I in terms of all relevant guidelines and regulations. Our Infection Prevention Control (IPC) team will visit the Practice and review floor plans and room data sheets to ensure compliance from an IPC perspective. Our Premises and Estates Teams can provide assistance with identifying and securing S106 or CIL Funding and will support Practices through each stage of the approval process.
Justification for the Approval Process
The approval process is of significant importance in a strategic and financial context but, most importantly, it is in place to ensure the safety of staff, patients and other premises users. The fundamental justifications for the implementation of the approval process are detailed below:
- Despite GP Practices being independent entities with their own insurances and liabilities, the CCG and NHSE/I have a duty of care to patients, staff and other premises users, to ensure that all premises which fall under the blue and white badge of the NHS are safe and fit-for-purpose; that any related building works comply with all of the relevant guidelines and regulations; that best-Practice is applied; and that all necessary due diligence is performed.
- As referred to in the previous section, any increase in GMS footprint of a Practice has financial implications for the CCG via increased rent reimbursement / notional rent. Such implications therefore need to be quantified and approved in terms of need, affordability and value for money, and be considered against the wider premises and estates strategy.
- The approval process ensures that all approved schemes align with the CCG and STP’s estates strategies, particularly in the context of the forecasted population growth in the area in addition to the forthcoming shift of some secondary care services into primary care settings. In essence, such factors mean that the bigger picture needs to be looked at, and any premises-related solution to capacity issues needs to work at System, Place and Neighbourhood/PCN level, not just for individual Practices.
- There may be alternative solutions to costly premises improvement schemes and the CCG is duty bound to protect the public pound and utilise all available NHS space to meet ongoing demand. We work closely with Local Authorities, other system providers, and the One Public Estate Programme which allow us to identify existing premises for the potential delivery of healthcare services - there may be other NHS or non-NHS space that is available and could be utilised for provision of GMS services, rather than incur the capital and revenue implications of a Practice extension or new build.
If your Practice is considering a premises improvement scheme, in the first instance please make contact with the Premises and Estates team or you can submit an Expression of Interest Form which requires high level detail of the proposal, estimated costs and a summary of the main strategic drivers.