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Practices 'could miss out on enhanced services' as CCGs begin putting them out to AQP

Exclusive The first CCGs have begun putting local enhanced services out to tender through the ‘any qualified provider’ route, with GP leaders warning this could mean that practices will be ‘unable to compete for services they have always provided’.

CCGs in Essex said they are putting the local enhanced services – which are to be renamed ‘community service contracts’ from April 2014 – through the AQP route to avoid accusations of conflicts of interest that would arise were they to award contracts directly to practices.

Commissioners in other areas have also begun asking practices to complete onerous forms in order to be considered for LESs, despite local leaders pointing out that GPs have already provided the same information to different authorities, including the CCGs themselves.

GP leaders said that CCGs did not need to go down the AQP route and warned that the bureaucracy involved in tendering for services was ‘unnecessary’, yet the level of paperwork required could lead to practices missing out on services they currently provide.

From April, under new competition regulations, services will have to be put out to tender unless commissioners can prove that they can only be provided by a single provider.

The controversial AQP route requires providers to prove they meet NHS service quality requirements, prices and normal contractual obligations in order to be added to the list of qualified providers, from which patients can choose when they are referred to the service.

The professional bodies have warned that the AQP route would actually reduce choice, as the bureaucracy involved and the uncertain income would lead to practices shunning the services.

Until now, no CCG has said they are going to put enhanced services through AQP. But a statement sent to Pulse on behalf of Basildon and Brentwood, Thurrock, and Castle Point and Rochford CCGs revealed: ‘Given the potential conflict of interests  - CCGs with boards that are primarily made of GPs awarding contracts to primary care – it was considered that the AQP process was a fair and transparent way for commissioning these services long term. We are aware of the LMC’s position and we are in discussion with them.’

However, Dr Brian Balmer, chair of Essex LMC, said: ‘There is a real danger in this climate that some practices will not be able to compete for services they have always provided. We think this policy is complete rubbish. It looks like ambitious managers trying to make a name for themselves – but they don’t need to go down this route.’

Guidance from NHS England (then the NHS Commissioning Board) on local enhanced services issued in July 2012 stated that many services could be awarded without the need for tendering.

It said: ‘As now, for services for which there are no other possible providers, for instance because they require list-based primary medical care, or for services of a minimal value, CCGs will be able to commission services through single tender from GP practices.’

GPC deputy chair Dr Richard Vautrey said CCGs were concerned about legal challenges.

He said: ‘CCGs are doing this because they are fearful of legal challenges by private providers if they are not seen to be putting GPs under heavy scrutiny. If CCGs don’t go down this route they worry that other provider companies will threaten them with legal action.’

‘This is something that people have been fearful of. We have been thinking that more CCGs would go down the AQP route. But this involves a whole lot of bureaucracy, which has already been done as part of CCG processes. It’s simply unnecessary. Monitor has found that CCGs can use local commissioning arrangements to get the information they need.’

Pulse has also received a copy of a document sent by the Lancashire Commissioning Support Unit, which requires GPs and other potential providers to fill in what are known as ‘initial contract information’, covering safeguarding policy, serious untoward incidents, and insurance documentation. GPs in Lancashire also have to fill out ‘organisation crime profile’ forms which focus on violent incidents in the practice, bribery and fraud.

Mr Peter Higgins, chief executive of Lancashire and Cumbria consortium of LMCs said commissioners ‘are trying to be helpful’.

However, he added: ‘There is a fundamental issue here that needs to be taken up nationally. How many times do practices have to assure the same people that they fulfil their GMS/PMS contract, are CQC compliant, have a safeguarding policy and have a business continuity plan? It’s endless duplication.’

This follows Pulse’s report that practices are being burdened by extra paperwork to win certain local authority contracts for the provision of services including sexual health and long acting reversible contraception.

Readers' comments (11)

  • Will it be possible under this system to provide joint injections for ones patients if it's done for free ?

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  • This is a storm in a tea cup as completing the forms for an AQP bid is not onerous at all. If practices work together in federations its even easier.
    Most potential competitors will not be interested in bidding as practices generally control the patient flows.

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  • gp is the best to care for his patients 24 hours but when it comes des and les aqp will be cheaper so patient need to go elsewhere in 10 to 20 miles radius. what a hypocrisy of government...

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  • Absolutely correct. The AQP form, also known as the PQQ in H&SC tendering should not be onerous. The Procurement Regulations require that thi stage in tendering asks about the "personality"(sorry EU translation!) of the tenderer i.e company, partnership etc. "economy" details of accouonts, financial sustainabillity and "technical capacity" this means providing evidence of qualifications, previous contracts held and capacity to deliver the service, including experience. A well managed practice should have this information to hand
    There is considerable confusion over this first "selection" stage in tendering and AQP selection and the second "award" stage which is used in other full tendering processes. It is true that CCGs appear to be going overboard where they are not using AQP, but a full tendering process. 31 questions requiring answers of 500 words is questionalbe as to both validity and the cost of appraisal. But THIS DOES NOT apply to AQP.
    Just one word of warning - tendering documents are the property of the purcasher, protected by copyright and provided for the tenderer and their advisers only in strictest confidence. It is not a good idea to share tendering document with any other body as by doing so the tenderer risks being excluded from the process arising from potential collusion.

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  • I think its about time that we should all call on our colleagues on CCG Boards to resign. AQP leads to fragmentation and to a worse service for our patients and until we all make a stand together no one will understand the havoc that section 75 is causing.

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  • Re the point made by Dr Higgins: the isue for the purchaer is tha t"stuff happens" which can affect their assessment of risk. One of our customers had an H&S enforcement notice issued. Usually this leads to exclusion from the process. But by dealing with the matter they finished up providing a better service for patients and gave comfort to their pruchaers as a result were awarded conracts. These types of events are occurring all of the time across the areas covered by the Questionnairre. This is why purchasers require uptodate information. Ultimately the process pushes up the overall quality of the services being provided.

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  • The AQP form is onerous . Just try and fill one out . It is not complicated just time consuming and laborious . It boils down to two questions . Can you provide the service within the regulations ? How much ?

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  • If you think the AQP form is not onerous, then you have never seen one.

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  • I have filled in about four AQPs and they don't take long once you have done one (you just copy and paste). The price is set by the commissioner so this is not an issue

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  • Roger Tweedale

    GPs are certainly best placed to provide LES/DES services; they have the clinical expertise and a delivery network that cannot be matched in delivering care closer to home; and it is a nonsense that Commissioners find themselves in a position where they have to disrupt something that is already in place and generally working well - at a time when there are so many other pressing priorities.

    However, if AQP is going to happen then primary care needs to prepare. Things that need consideration:
    - The AQP submission: Assume this is some 20 pages of A4 text, covering a variety of questions but which will likely include: Experience; Care pathway; Follow Up Care; Working with Local and Social Services; Subcontractor Relationships; Clinical Governance Processes, including Governance Framework, Clinical Incident Reporting, Dealing with Immediate Critical Incidents, DBS/CRB checks; Proposed Innovation beyond the specification; Workforce Continuous Development; Compliance with Public Sector Equality Duty; IT Architecture including Information Govenance Arrangements; Clinic Locations; Access Plan re Working People and the Disabled; Mobilisation Plan. The last one we did had a max word count of 500 words on most of the above items (and you would be well advised to use up the word limit - one line answers rarely show you at your best). Yes, if you have done one before the there are efficiencies in preparing a PQQ submission a second time around - but how many practices are currently in this position?
    - Are you ready for a 100+ page NHS contract? Whilst there is little room to negotiate any variation, anyone signing up to it should still read it and understand it properly
    - Will the CCGs really want a contract with each and every practice (100+ pages for each ??) or will they prefer one 'consolidated' provider who can provide the pan-CCG solution; if the answer is one consolidated provider then what primary care organisation is going to hold the contract? Does that legal entity already exist? Is it CQC registered?
    - Who is going to undertake the ongoing contract management duties such as performance monitoring, reporting etc

    My advice......practices should start working together now so that they are in a position of strength if / when they have to tender against some of the big private providers who arent so focused on local engagement and integration and who have dedicated teams who can crank out AQP submissions by the bucket load.

    There are a number of organisations being created by groupings of GP practices which is encouraging - however this process needs to accelerate if primary care is to be ready for LES/DES AQPs from April 2014. Watch this space for an Association of GP Provider Organisations - coming soon !

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