healthcare update - issue 16


GP commissioning consortia


Does the law require them to comply with procurement rules when commissioning for the NHS?


By April 2013, the role of PCTs as commissioners of NHS-funded services is likely to have been replaced by new powers given to local consortia of GP practices to commission services for their patient populations. The aim is to bring decision-making as close as possible to patients themselves.

It is a truism that PCTs, as public bodies as well as NHS commissioners, need to have regard to the EU public procurement rules and apply them in each commissioning undertaken. Most contracts relevant to commissioning by PCTs are for partially-regulated “Part B” services, although some contracts let by them – catering and cleaning, for example - are inevitably subject to the entirety of EU procurement law and, accordingly, require full advertisement in the OJEU when their value falls above threshold.

But will GP commissioning consortia actually be required to do the same? As a matter of policy, they may well be. But will they legally be required to comply with EU procurement law in the way PCTs are? In other words, will they be public bodies in the eyes of the EU law?

The Procurement guide for commissioners of NHS-funded services[1] (which the Department of Health may amend as the coalition’s NHS White Paper[2] is implemented) appears to advocate due procurement process as a requirement upon all NHS commissioners, without offering any view on whether GP consortia will actually be “contracting authorities” for the purpose of the EU rules. If they are not, then such consortia will be under no legal requirement to comply with the EU rules, no matter what the policy may dictate.

The key will be whether such consortia are “bodies governed by public law”, for which the EU rules set out a three-stage test. Each element of the test has to be satisfied before an organisation can be required to comply with the EU rules as a “contracting authority”:

  • The incorporation test - As groupings of GPs working together for a common aim, then (even if not “incorporated” in the legal sense) this test will be satisfied. If the following two tests are also satisfied, then GP consortia will be subject to the EU rules.
  • The specific-purpose test - This test requires that the bodies concerned are “established for the purposes of meeting needs in the general interest, not having an industrial or commercial character” – in other words, established purely for the purpose of healthcare commissioning, with no commercial element to their operations. If there is any commercial element, then these consortia will not be subject to the EU rules.
  • The control test - This looks at the extent to which the financing, management supervision and boardroom control of the undertaking concerned lies with a public body as opposed to the private sector. Assuming that (in the case of a GP consortium) the first two tests are satisfied – the second being satisfied by reason of the fact that the agendas of these consortia will be purely NHS-mandated, then it only remains necessary to determine whether (a) over half of their financing is public, (b) they are to be subject to management supervision by the NHS or a particular part of it, and (c) their activities are to be subject to boardroom control by the NHS or a particular part of it.

It is the control test which, in the case of GP consortia, it may be trickiest to answer, at least until the “bones” of the White Paper are fleshed out. On the basis that the handing of the ability to commission services to GPs represents a devolution of power from the NHS, one expects that the way in which GPs will be able to go about that activity will be fairly tightly regulated. Secondly, the fact that GP commissioning is likely to be anchored on a largely statutory footing will mean that total freedom on the part of the consortia to control their own activities is unlikely. Budgets will be allocated directly to consortia and there will undoubtedly be strict controls on the way those budgets will have to be applied.

On this basis, the likelihood is that, in relation both to financing and management control, GP consortia will satisfy the third limb of the test. Which is good news – since, by being required to apply the procurement rules, where necessary, in furtherance of their commissioning activities as well as operating within their own statutory framework, they are more likely to commission services which are genuinely in the best interests of patients and taxpayers: the power and budgets afforded to them will not be able to be applied in setting up contracts which have been procured in anything less than a totally fair and transparent way. Furthermore as there is an expectation within the White Paper that there will be a shift to commissioning for outcomes with an emphasis on health and well being, it is likely that some commissioning will either be integrated with that to be commissioned by Local Authorities or, such as the current example of learning disability services, transferred en bloc to Local Authorities.

There would be a definite slope in the level playing field if some services are the subject to the full rigour of EU law - learning disability, public health and health promotion i.e. those that sit with and may transfer to Local Authorities; whilst others were not i.e. those that may sit with the new GP Consortia.

We anticipate that both the regional arms of the National Commissioning Board and the extended remit of Monitor, as an economic regulator, will have a role in levelling out the playing field, so that all publicly funded health services are the subject of EU law. It would certainly maintain contestability in those services that fall to be commissioned by the GP consortia.

It would also give providers certainty as to the marketplace and rules of engagement in that playing field so that the scope of current provision is extended, whether by reference to private-public / third sector partnerships in whatever form, or by reference to the emerging social enterprises “umbrella’d” under primary and community care service provision.

[1] Gateway reference 14611, published 30 July 2010 and superseding the PCT Procurement Guide (March 2010). See also the Principles and Rules for Co-operation and Competition.
[2] Equity and excellence: Liberating the NHS – July 2010 (Cm 7881)

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The content of this bulletin is provided for the purposes of general interest and information. It contains only brief summaries of aspects of the subject matter and does not provide comprehensive statements of the law. It does not constitute legal advice and does not provide a substitute for it.

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