Registration guidance: primary care networks, federations and GP services working in collaboration

Page last updated: 18 October 2023

NHS GP practices and primary care teams are increasingly working together in collaboration to provide a range of services to a larger population. The most common arrangements are GP federations or primary care networks (PCNs).

Practices can work together using:

  • formal arrangements where they may create a limited company or a formal partnership
  • informal arrangements, including not for profit organisations.

Both types of collaborative arrangements can support practices to bid for and deliver a wider range of services. They can also share experience and knowledge.

Federations

Federations are groups of GP primary care providers. They form a single organisational entity and work together to deliver services for their combined patient communities. This makes it easier to develop services to meet specific local needs and commission services on a larger scale.

Primary care networks (PCNs)

Primary care networks (PCNs) were introduced in July 2019 by NHS England to support the delivery of the NHS Long Term Plan. PCNs usually consist of groups of NHS general practices working together with a range of local primary care providers. These can include community services, social care, and the voluntary sector. PCNs offer more personalised, co-ordinated health and social care to their local populations. Some of these roles will be funded through the Additional Roles Reimbursement Scheme

PCNs are normally based around natural local communities. They typically serve populations of between 30,000 and 50,000, although some are larger. They should be:

  • small enough to maintain the traditional strengths of general practice
  • large enough to provide resilience and support the development of integrated teams.

Registration requirements for federations and PCNs

See What is registration? for guidance and an explanation of legal terms.

This supplementary guidance applies to both federations and PCNs.

GP practices joining or forming a federation or PCN must decide if they:

It is an offence to carry on regulated activities without the correct registration

Registration issues to consider

It is the legal entity carrying on the regulated activity that must register – not the location or care setting where it is carried out. 

We register the regulated activity that will be carried on, not service types or professions. To decide whether registration is needed it is important to determine:

  • what regulated activity will be carried on
  • who or which legal entity is responsible for it.

These are the issues to consider:

  • Legal entity: Federations and PCNs usually form incorporated organisations.
  • Regulated activity: See Scope of Registration to confirm which activities are being carried on. The most common regulated activities carried on by primary care providers are:
    • Treatment of disease, disorder, or injury
    • Diagnostic and screening
  • ‘Carrying on’ (directing and controlling) a regulated activity: This means the provider:
    • has supplied instructions, guidance, policies, processes and or advice. This includes what work should be done and how it must be done. The provider can decide who does what job and move people around to ensure contracts are met.
    • is responsible for complying with the regulations and legislation when delivering the service under the regulated activity.
  • Locations: See What is a location? For federations and PCNs this would be the premises where a primary care provider carries on the regulated activity. The location is then a condition of registration.
  • Registered managers: If you need to register and you are an incorporated company or legal partnership, then you will need a manager.
  • Statement of purpose: You must submit a statement of purpose when you apply to register with us. It must be up-to-date and contain certain information. See our information about a statement of purpose

Employment

Providers are responsible for the staff they 'employ.' However, the meaning of 'employed' in the regulations is wider than just staff employed on an employment contract.

It means anyone who works for the provider, under its ongoing direction and control. The provider needs to be assured about the ‘fitness’ of those people. You should always ask for information for confirmation and assurance that all fitness checks are complete and satisfactory. Never assume that checks have been completed. See Regulation 19: Fit and proper persons employed and related guidance.

Responsibilities

Where there is an agreement between the PCN and or federation and the GP practices, you should develop a service level agreement. This should clearly reflect the responsibilities and accountabilities of both and should cover areas related to:

  • employment
  • training
  • supervision
  • management of locations

The statement of purpose should be updated to reflect the changes in how the regulated activities are to be delivered and to whom. See Changes to your statement of purpose

Even if you think you do not need to change your registration, we still recommend that you tell us, for information only, of changes in the contracting structure. 

Example scenarios

These scenarios cover the most common ways that federation, PCN and GP partnerships may work together or be set up.

Scenario 1

A PCN or federation has been awarded a contract to deliver the extended hours service for a group of GP partnerships that are part of the PCN or federation. The PCN/federation confirmed that it has subcontracted the extended hours to the GP partnerships. The extended hours will be delivered by the GPs who are employed in the individual partnerships on an agreed rotational basis. The GP partnerships have agreed:

  • GPs employed in individual partnerships will deliver the extended hours on a rotational basis
  • which GP locations will be used and when.

Who should be registered?

  • There is no change to the registration of the GP partnerships as they are already registered to carry on the regulated activities.
  • The PCN/federation would not need to register as it has contracted the regulated activities to the GP partnerships. This would also be the case if the PCN/federation was a legal entity.

Action needed

  • The GP partnerships should update their individual statements of purpose to include the extended hours.

Scenario 2

A PCN forms a limited company. It tenders and is awarded a contract to manage long-term conditions such as chronic obstructive pulmonary disease (COPD) and diabetes. The PCN limited company does not employ any staff itself. It subcontracts the management of the long-term condition contract to the participating GP partnerships.

Who should be registered?

  • Each GP partnership is already registered to carry on the regulated activities required to deliver the long-term condition contract.
  • The PCN, although a limited company, is not carrying on any regulated activities. It has subcontracted the long-term condition contract to the GP partnerships. So, the PCN is not required to register.

Action needed

  • The GP partnerships should update their individual statements of purpose to include the long-term condition contract.

Scenario 3

A PCN has formed a limited company, which includes representatives from 5 GP partnerships. The PCN has directly employed healthcare professionals, including nurses, doctors, occupational therapist, and physiotherapists. The PCN has been awarded a contract to deliver hospital at home services to people in care homes and living at home.

Who should be registered?

  • The PCN limited company must submit an application to register as a new provider for the regulated activities it would be carrying on.
  • The GP partnerships, although associated with the PCN, are not carrying on the regulated activities for this contract. So, they do not need to change their registration.

Action needed

The PCN needs to submit:

  • a statement of purpose with its registration
  • an accompanying registered manager application.

Scenario 4

The PCN has formed a limited company. The directors of the company are representatives from 9 NHS GP partnerships. The PCN has been awarded a contract through the integrated care board (ICB) to deliver an extended minor surgery service. This service will be run from its headquarters but will be delivered in one or more of the existing GP partnerships locations.

The PCN employs and seconds staff to deliver this extended minor surgery service.

Who should be registered?

The PCN needs to register. It:

  • is a legal entity in its own right
  • directly employs staff
  • holds and delivers this contract, therefore it has ‘command or control’ over the regulated activities to be delivered

Action needed

The PCN needs to submit:

  • a statement of purpose with its registration application. This must include the GP practices it uses on a sessional basis to deliver this service, listed as satellites.
  • an accompanying registered manager application.