Attempts to 'subvert' workforce rules to be investigated as 'fraud'

Under the agreement published by the British Medical Association and NHS England earlier this year, PCNs are entitled to funds to cover the costs of expanding their workforce, provided their new team members are hired in addition to their existing clinical staff.

In their latest guidance, NHSE and BMA said this principle of “additionality” is intended to protect existing investment in the primary care workforce.

The new network contract provides for increasing levels of funding for PCNs to pay for additional staff members in five roles: physiotherapists, clinical pharmacists, social prescribing link workers, physician associates, and paramedics.

In year one, each PCN will be reimbursed for the total salary of new social prescriber link workers. They will also be able to claim reimbursement for 70 per cent of new clinical pharmacists’ salaries. The rest will be staged through the subsequent years of the contract, with 70 per cent of salary costs for each role available from the centre.

The latest guidance said: “Any suspicion that deliberate attempts have been made to subvert the additionality principles will result in a referral for investigation as a potential fraud.”

This “additionality rule” – essentially meaning new staff must be taken on in addition to existing staff – is intended to “protect existing commissioner investment into primary care as well as expand capacity”.

In a bid to identify attempts to get around the rule, NHS England’s regional teams will survey clinical commissioning groups later this month “to determine the number of staff employed in these five roles as at 31 March 2019”.

This survey “will be used to inform the workforce baseline for each PCN”, which will be used to assess PCN claims to the Additional Roles Reimbursement Scheme, set up to enable commissioners to distribute funding to networks to pay for their expanded workforce.

The guidance also said: “It will not be possible for commissioners to stop funding staff identified in the baseline exercise on the grounds that these could instead be funded through PCN reimbursement. CCGs will be required to maintain existing funding for the baseline staff levels.”

Failing to submit information or providing inaccurate information “is a breach of the network contract [Direct Enhanced Services] specification and may result in commissioners withholding reimbursement pending further enquiries”.

The only exception to the additionality principle will be clinical pharmacists employed under two pre-existing employee salary reimbursement schemes.

Pharmacists employed using the Clinical Pharmacists in General Practice Scheme or the Medicines Optimisation in Care Homes Scheme can be transferred across the additional roles reimbursement scheme, provided they have been in post since before 31 March, they will be working across the PCN to defined specifications, and the transfer takes place before 30 September this year.