Guidance

[Withdrawn] COVID-19 PPE reimbursement for non-hospital providers

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This guidance was withdrawn on 7 March 2023

This page has been withdrawn because the deadline to submit claims has passed.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

Introduction

The Department of Health and Social Care recognises that not all settings undertaking NHS services received personal protective equipment (PPE) from central supplies when they needed it. This occurred despite an unprecedented effort across government to purchase and distribute COVID-19 PPE products to all settings requiring it as part of infection control measures.

The department has considered for each contracting group, whether there are additional cost pressures that have not already been met, and if so, the most appropriate mechanism to meet the additional costs incurred by purchase of PPE before central provision was fully stood-up. COVID-19 PPE is classed as the PPE that providers are required to use over and above business-as-usual (BAU) use, due to COVID-19 infection control guidance, rather than what would have been used pre-pandemic.

For some providers of primary care services, the nature of contracting arrangements during the pandemic, and the nature of their requirement for PPE, prompted the department to work with partners in the DHSC group to put in place a scheme for these providers to submit reimbursement claims at individual contractor level. These claims are for PPE purchased where such items could not be supplied centrally. These contracting groups are:

• general practice
• dentistry
• pharmacy

For other primary care contracting groups, the department has concluded that the costs of PPE incurred during the pandemic (where PPE could not be supplied centrally) before 31 December have either already been met through contracting arrangements put in place during the pandemic, or are met most efficiently and effectively through alternative means to a claims-based reimbursement system. This decision is based on advice received from NHS England and NHS Improvement (NHSEI) and representative professional bodies.

For providers where an individual claims-based reimbursement process will operate, they will be able to make reimbursement claims towards PPE bought from 27 February to 31 December 2020 for use in delivery of NHS clinical services by 31 March 2021. There will be no further entitlement to reimbursement for PPE purchased after 31 December 2020 as supply via central channels has been fully extended to all providers delivering NHS clinical services through the e-Portal channel.

Model of reimbursement

The model for each contracting group has been developed with an acknowledgement that demand and use of PPE in delivering services changed over time since the outbreak of the pandemic. It is recognised that operating model guidance across all contractor groups changed as part of the need to respond flexibly to changing circumstances.

It was necessary to meet the aspiration to maintain usual services where possible while protecting the safety of patients and staff. It is also recognised that infection prevention and control (IPC) guidance was updated over time as scientists learned more about the novel coronavirus COVID-19 and adjusted infection control measures accordingly.

The reimbursement scheme applies only to the types of personal protective equipment as laid out in the Public Health England (PHE) guidance. Any additional costs incurred by providers as part of the COVID-19 response are exempt from this process.

The reimbursement scheme has been constructed with the aim of making the process as simple as possible for providers to claim, and to minimise the administrative burden. DHSC, with NHSEI, has considered the following elements when determining claims thresholds in which it is anticipated most providers eligible to submit claims in this scheme will fall:

• infection control guidance application relevant to each contracting group’s service delivery
• operating guidance to the contracting group over time
• modelled quantities of PPE it is expected will have been used based on provider size and service delivery
• PPE item costs at the height of the pandemic

It is acknowledged that the modelled approach will not capture the circumstance of each provider. Therefore, any claims that meet the criteria of the scheme but fall outside the modelled thresholds for ‘standard’ claims will be considered as part of the scheme, subject to relevant evidence for the claim being submitted. These will be referred to as ‘exceptional’ claims.

It is recognised that for some aspects of service delivery in the pandemic, or where local risk assessment deemed it necessary, higher grade PPE may have been required across different settings. In such cases, contractors are asked to submit any risk assessments undertaken in support of such claims.

Reimbursement mechanisms

General practice

For general practice, the reimbursement process will be undertaken by clinical commissioning groups (CCGs) or NHSEI regional teams where the CCG is not delegated on behalf of DHSC. Payments will be made by CCGs or NHSEI regional teams to claimants following approval of a submitted claim.

CCGs or the region will communicate with GP practices outlining how the process will work. Instructions to CCGs on requirements in administering the scheme can be found in Appendix A.

The period in which claims can be submitted to CCGs will open as soon as possible and close on 5 February 2021.

CCGs will confirm with GP practices the local arrangements.

General practice contractors will be able to submit claims for PPE purchased between 27 February 2020 and 31 December 2020 for use in the delivery of NHS general practice services as a result of COVID-19 infection control guidance.

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

• type IIR masks
• aprons
• gloves
• eye protection (visors and goggles)
• hand sanitiser
• clinical waste bags

Dentistry

For dental contractors, the reimbursement process will be undertaken by NHS Business Services Authority (NHSBSA) on behalf of DHSC. Payments will be made by NHSBSA to claimants following approval of a successful claim.

Dental contractors will be able to submit claims for COVID-19 PPE purchased between 27 February 2020 and 31 December 2020 for use in the delivery of NHS dental services as a result of COVID-19 infection control guidance.

Standard COVID-19 PPE items for dental contractors are defined as:

• type IIR masks
• FFP2/3 masks
• gowns (sterile and non-sterile)
• aprons
• gloves
• eye protection (visors and goggles)
• hand sanitiser
• clinical waste bags

Activity modelling for thresholds underpinning ‘standard’ claims considers the dental operating model and contracting arrangements throughout different periods of the pandemic.

The period in which dental contractors can submit claims via the COMPASS portal will be announced soon and is expected to be as soon as possible. Contractors will receive further information confirming the go live date and arrangements for submitting a claim.

Pharmacy

For pharmacy contractors, the reimbursement process will be undertaken by NHSBSA on behalf of DHSC, as set out in the Drug Tariff. Payments will be made by NHSBSA to claimants following approval of a successful claim.

Pharmacy contractors are eligible to claim for PPE that was purchased between 27 February 2020 and 31 December 2020 for use in the delivery of NHS pharmaceutical services up to 31 March 2021 as a result of COVID-19 infection control guidance.

Claims must be submitted on the MYS portal. Pharmacy branches that are part of a multiple (defined as having 6 or more branches) should consult their head office on whether claims will be made at either branch or head office level. Dispensing appliance contractors are eligible to claim the standard payment based on their dispensing volumes in the same way as pharmacies.

The deadline to submit claims is 12 February 2021.

The standard items that can be claimed are:

• aprons
• gloves
• type IIR masks
• hand sanitiser

Between 27 February 2020 and 30 June 2020, any protective equipment purchased in substitution for unavailable standard items can be covered under standard claims.

Timelines

The department’s intention is to go live with the relevant reimbursement claims process as soon as is practical for each contracting group. The reimbursement process is tailored to each contracting group with the aim of it being as straightforward as possible and aligning as far as possible to existing payment mechanisms. The department has also engaged professional bodies with a view to determining the most suitable reimbursement model for each group.

Each contracting group will have its own process and timetable for how the reimbursement scheme will operate and will be confirmed by the relevant body administering the scheme for each contacting group on behalf of the DHSC. Guidance relating to the remaining contractor groups will be made available by the administrators of the scheme on behalf of DHSC once the details of their arrangements are finalised.

Reimbursement for Independent Sector Providers (ISPs) carrying out NHS services

NHSEI, Department of Health and Social Care (DHSC) and Arden and GEM CSU (health and social care system support) are working in collaboration to give independent sector (non-acute) providers (ISPs) the opportunity to seek reimbursement for any PPE purchased before they had access to the PPE portal. This reimbursement only applies to the costs incurred delivering NHS work.

In addition to reimbursing COVID-19 PPE, NHSEI are offering reimbursement for other non-PPE COVID-19 related costs, incurred during delivery of NHS work, to reduce the administrative burden on ISPs. This work is therefore being undertaken, together with the PPE reimbursement, in one exercise.

The reimbursement period for COVID-19 PPE costs covers from 28 February 2020 until providers were onboarded to the PPE portal. The reimbursement period for non-PPE COVID-19 costs is from 28 February 2020 to 31 March 2022. There will be no reimbursement after this period.

Any ISP organisation wishing to seek reimbursement should contact Agem.ISPClaims@nhs.net for the guidance and a template to complete.

The timeframe for reimbursement is as follows:

To support ISPs through the reimbursement process, NHSEI will facilitate a workshop on 16 March 2022 at 10:30am so ISPs can understand exactly how they should complete the template. We will make a recording of the workshop available to help eligible providers make a valid claim. NHSEI will provide FAQs, guidance, and process maps to support the template. Arden GEM will communicate details of how to access these workshops and additional support.

Providers wishing to seek reimbursement must return an initial template with high level estimates and details of NHS organisations that have received the services during this period. Providers should also include any detail of existing reimbursement payments. The deadline for this initial return is 30 March 2022.

Following this initial return, there will be a further period to allow providers to complete the full detail of the returns to support the reimbursement. NHSEI will make reimbursements based on evidenced actual costs incurred. The final date for this completion is 29 April 2022. Providers can choose to complete the full detail at the earlier stage if they wish.

There will then be a period of challenge and due diligence from May to July 2022. NHSEI will require providers to operate on an open book basis and give full access to any information required.

NHSEI will make the payment directly to ISPs once the assurance process has taken place. We expect this to take place in July or August 2022.