Guidance

[Withdrawn] Appendix A: instructions to GP commissioners on COVID-19 PPE reimbursement process

Updated 11 March 2022

This guidance was withdrawn on 7 March 2023

This page has been withdrawn because the deadline to submit claims has passed.

Applies to England

1. The claims process

This finance guidance is to support commissioners in the administering of personal protective equipment (PPE) costs in relation to COVID-19 pursuant to NHS England and NHS Improvement’s (NHSEI) letter of 4 August 2020 and the associated guidance, The COVID Support Fund – Finance Process Guidance for CCGs.

Both documents stated that further instructions were to follow from the Department of Health and Social Care (DHSC). This document contains those instructions. These instructions supersede the instructions relating to PPE in The COVID Support Fund – Finance Process Guidance for CCGs.

Commissioners (CCGs or NHS England and NHS Improvement (NHSEI) regional teams where the CCG is not delegated) can use locally designed forms to capture the relevant information from GP practices. It is up to the commissioner to determine the design of the form that would most efficiently align with their operating practices. Existing forms can be either adapted, new forms designed, or appendices requested to be submitted alongside existing forms. However, the following information must be captured and held by the commissioner in the administration of the scheme in some form and provided to NHSEI or DHSC if requested:

• quantity and type of PPE purchased being claimed in this process with evidence that it has not formed part of a previous COVID-19 fund claim
• time period of purchasing
• associated evidence of spend, for example invoices
• staff risk assessments and clinical assessments to support claims for any items not listed in this guidance
• claims declaration form (see Annex B)

2. The claim process dates

Commissioners can go live with the process as soon as practically possible. The claims submission window period for GPs should run until 5 February 2021, after which no further claims can be considered.

This is for COVID-19 PPE^{[footnote 1]} items purchased from 27 February 2020 to 31 December 2020, for use in the delivery of NHS general practice services in line with COVID-19 infection control guidance.

Practices should already be obtaining their COVID-19 PPE free of charge through the DHSC portal and no further reimbursement will be made for PPE purchased after the date of 31 December 2020.

Claims must be for COVID-19 PPE that is intended for use prior to 31 March 2021.

3. Eligible items for reimbursement

COVID-19 PPE items for general practice are defined as:

• type I/IIR masks
• aprons
• gloves
• eyewear (visors and goggles)
• hand sanitiser
• clinical waste bags

COVID-19 PPE is classed as the PPE that providers are required to use over and above business-as-usual use, due to COVID-19 infection control guidance, rather than what would have been used pre-pandemic.

4. Practice claim process

Practices should submit all claims for COVID-19 PPE to their commissioner (CCG or regional team where their CCG is not delegated) by 5 february 2021.

Claims should be accompanied by any associated evidence and invoices. Any claims submitted without evidence and invoices should be returned to the practice.

Where any item of information or evidence is not provided, then the commissioner must not approve the claim and must contact the GP claimant to request the information is provided. Only when all relevant information is received, and the commissioner has assured itself that standard claims criteria is met can the payment be made.

Practices should not submit claims for PPE for which they have already been reimbursed.

5. Commissioner review process

The commissioner (CCG or Regional Team where their CCG is not delegated) will receive claims for COVID-19 PPE costs already incurred with any associated evidence or invoices.

The commissioner should follow this guidance in approving and validating these claims to ensure the spend is eligible and justified. The commissioner should assess claims based on the published guidance whether claims fall within the ‘standard’ claim thresholds. Claims that fall within these thresholds with evidence provided as outlined, can be paid out by the commissioner. Where any item of information or evidence is not provided, then the commissioner must not approve the claim and must contact the GP claimant to request the information is provided. Only when all relevant information is received, and the commissioner has assured itself that standard claims criteria is met can the payment be made.

Where the commissioner has already approved claims they should check the supporting information is in line with this guidance and seek additional information if required. Where the claim is not approved the commissioner will reject and return to the practice to review and resubmit if appropriate.

The commissioner needs to ensure that checks are in place to ensure there is no duplication of reimbursement of PPE claims.

Commissioners will need to assess all claims against the following criteria before authorising payment:

• invoices for the period covered
• practice open during the claim period
• date practice signed up to the PPE portal to receive free COVID-19 related PPE
• only eligible items have been claimed for
• thresholds criteria has been considered
• check against any previous payments made to the practice in relation to PPE
• standard approval procedures used by the commissioner

Records should be maintained on the verification checks undertaken, the number of rejected claims and the amount of funding not paid due to verification checks identifying incorrect submissions for counter fraud monitoring purposes.

Threshold criteria

Practice claims should be defined as either standard or exceptional claims:

• standard claims: fall within their practice list size banded rate to cover standard COVID-19 PPE use from 27 February 2020 to 31 December 2020. See Table 1 below
• exceptional claims: cover any PPE purchased between 27 February 2020 and 31 December 2020 in excess of the standard claim value and/or outside the standard COVID-19 PPE items and to be used prior to 31 March 2021

To support commissioners to consider the validity of claims, Table 1 below identifies which claims can be considered standard, with all others being treated as exceptional claims. The thresholds are based on modelling to benchmark valid monthly costs that practices would have incurred for medical grade PPE.

Assumptions underpinning modelling of ‘standard’ claims

Modelled costs within ‘standard’ claim thresholds take into account the following:

• activity assumptions based on:
  • registered list size (from NHS Digital reported data)
  • average face-to-face activity (NHS Digital reported data)
  • adjusted by proportion of contractors registered on the PPE e-Portal by September 2020
• PPE requirements based on assumed activity under PHE infection control (IPC) guidance
• cost of PPE based on March to June wholesaler prices

For standard claims the modelling assumes PPE used between 27 February and 31 October was procured outside of the portal and for 1 November onwards was supplied via the portal.

General practice can submit claims that include amounts covering 1 November to 31 December, but these will be considered an ‘exceptional claim’ by the CCG, as only a minority of practices were still not signed up to the portal in this period.

Commissioners must also consider whether the practice has followed PHE guidance in using the PPE for which it is claiming.

Table 1: modelled thresholds for standard COVID-19 PPE reimbursement claims

Practice list size (registered patients)	Standard claimable total to cover 27 February to 31 October	Additional claimable amount to cover 1 November to 31 December for practices not signed up to portal in this period
Up to 3,281	£5,196	£1,778
3,281 to 4,439	£7,030	£2,406
4,439 to 5,548	£8,786	£3,007
5,548 to 6,650	£10,532	£3,605
6,651 to 7,829	£12,398	£4,244
7,829 to 9,084	£14,386	£4,924
9,085 to 10,604	£16,793	£5,748
10,605 to 12,443	£19,705	£6,745
12,443 to 15,442	£24,454	£8,370
15,443 to 20,000	£31,672	£10,841
20,001 to 30,000	£47,508	£16,261
30,001 to 40,000	£63,345	£21,682
40,001 to 50,000	£79,181	£27,102
50,001 to 60,000	£95,017	£32,523
60,001 to 70,000	£110,853	£37,943
70,001 to 80,000	£126,689	£43,363
80,001 upwards	£134,382	£45,997

Standard claims

Where a standard claim is received for COVID-19 PPE that meets the reimbursement criteria and is within the claim thresholds detailed below the commissioner can approve reimbursement to the practice. Commissioners may approve payment of standard claims that exceed the amounts in Table 1 by 10%, where it can be demonstrated this is justified and evidenced.

Exceptional claims

Where an exceptional claim is received that exceeds the claim thresholds in Table 1 or does not meet the reimbursement criteria in section 5 then the commissioner may require explanation or further evidence to be submitted.

For any claims that the commissioner considers to be in the exceptional criteria, they will want to request further evidence such as:

• staff risk assessments for any higher-grade PPE used
• activity levels for the claim period
• whether the practice is a designated hub for patients displaying COVID positive symptoms (see NHSEI guidance on the operation of hot hubs/sites for COVID patients)
• is the practice delivering flu vaccines on behalf of other practices

Where claims relate to PPE that is outside the standard list – type I/IIR masks, aprons, gloves, eye wear (visors and goggles), hand sanitiser, clinical waste bags – the practice will need to be able to evidence the need for that PPE if requested to do so.

Should a practice exceed its claim threshold by 25% then the commissioner should refer the claim to the NHSEI primary care regional team for further assurance, similar to the COVID-19 Support Fund process.

Post-verification checks

The commissioner will be required to carry out post-payment verification checks in line with the COVID Support Fund process. Guidance on the post verification checks for the COVID Support Fund will be issued in due course.

The following information must be kept by the Commissioner and supplied to NHSEI if requested:

Full detail of claim and accompanying evidence submitted.

Full decision log by claim with rationale:

• approved
  • standard claims must detail how the Commissioner assessed criteria was met and verification checks undertaken
  • payment records
• approved based on amendment/further detail:
  • reason for initial rejection
  • rationale for payment based on further evidence submitted
• rejections: rationale for rejection

6. Commissioner/CCG finance claims process

To ensure the PPE funding is managed effectively, to support detailed analysis and to report accurately to DHSC there is an additional reporting requirement for commissioners to complete and return.

Commissioners should include the details of the PPE expenses in their non-ISFE submission. There is a specific column included on the COVID worksheet within non-ISFE for this. This includes claims already approved.

This column must reconcile to the corresponding columns in the non-ISFE report.

7. Commissioner/CCG cash drawdown process

Each month, each commissioner will need to collate the claims for the PPE costs and include the request for the cash requirement within its main monthly drawdown.

8. Commissioner/CCG payment to practice process and coding

Once the practice has submitted a claim for payment which has been approved the commissioner needs to process a Manual Payment transaction with a description of PPE costs which must be coded to:

• the CCG CORONAVIRUS A1 code, and
• the appropriate Practice A2 code and broken down using the following subjective codes:

Category	Subjective code	Description
PPE	52161002	Clinical and Medical Goods and Services – Supplies and Services – Clinical Other

The transaction once approved will be available to pay on the Commissioner’s next scheduled payment run.

Commissioners should ensure that all payments recorded against the fund are coded correctly in the ledger, including retrospective ones.

Commissioners should check that all expenditure is correctly reflected each month in their non ISFE submission.

Annex A: general practice COVID-19 reimbursement claim process flow

All claims made must be for eligible COVID-19 PPE purchased between 27 February 2020 and 31 December 2020 for use by 31 March 2021 to deliver NHS primary care medical services.

Step 1: contractor submits claim form with invoice evidence to commissioner

Standard claims need only submit invoice evidence.

Exceptional claims for values exceeding standard claims threshold and/or claims for non-eligible PPE may require further explanation or evidence to be submitted to the commissioner.

PPE must be intended for use by 31 March 2021.

Step 2: commissioner processes claim

Standard claims are reimbursed following basic checks.

Exceptional claims may be subject to further checks to justify claim before eligible payment is made.

All claims will be checked against previous COVID-19 PPE reimbursement payments made and any adjustments made before payment.

Step 3: pre and post-payment verification

All claims submitted will be accompanied by invoice evidence as a pre-payment check.

Exceptional claims may require further evidence to be submitted, for example risk assessments.

All claims will be checked against previous COVID-19 PPE reimbursement payments made.

Annex B: Declaration

Primary care provider declaration for reimbursement claims

Please tick all boxes to acknowledge agreement.

I declare that the reimbursement claims made are relating to reimbursement for:

• PPE required to meet the COVID-19 infection control guidance
• PPE that has been purchased, not provided free of charge
• PPE eligible for reimbursement as stated in the Primary Care PPE reimbursement guidance
• PPE used by the contractor for the protection of staff and patients and not for onward re-sale

Additionally, I agree to the following:

• That the items claimed for are due to additional net costs incurred and are in line with national rules outlined in guidance, for example Public Health England guidance.
• I will provide any and all evidence to support claims if required as part of the Payment Verification (PV) process, including evidence of pre COVID-19 PPE usage and costs to the clinical commissioning group (CCG) or NHS England and NHS Improvement (NHSE/I) as part of the PV process or investigation as required.
• I agree that the CCG/NHSE/I may require an appropriate portion of claims to be repaid – or may set off against practice global sum or such other monies due under the provider contract – if funding was outside the terms of this guidance or it is considered by the CCG or NHSE/I that there were inaccuracies or inconsistencies in the claim.
• I confirm that the information given on the declaration form is correct and complete.
• I understand that if I withhold information or provide false or misleading information, disciplinary action may be taken, and they may be liable to prosecution and or civil proceedings.
• I understand that personal data will be processed, and the relevant controller is NHSE/I. More information about these rights can be found in NHS England’s privacy notice or by or by contacting 0300 311 22 33.

Name of individual making the declaration

Job title/role within the practice (must be contract holder)

Signature: In signing this, you are confirming that you as a contract holder you are signing for and on behalf of the practice and that you have authority to make the declaration on behalf of the practice

Date of declaration

Documents may also be shared with NHSE/I and the Department of Health and Social Care who have commissioned the reimbursement process.

1. COVID-19 PPE is classed as the PPE that providers are required to use over and above business-as-usual use, due to COVID-19 infection control guidance, rather than what would have been used pre-pandemic ↩