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NHS Payments System – Filling in the Consultation


NHS England have clarified that members of the public can respond and we ask that you do so to ensure the report data is overwhelmingly negative on this.

NHS England tell us that next year they’re going to change the language of the consultation documents to make it clear that members of the public can respond.

A step by step guide to responding to the consultation

Step 2

Click to the button to start the process

Step 3

Ignore the parts that says only commissions and providers of services count for the objection threshold. 

The objection thresholds for this consultation are based on the number of objections received from commissioners and providers of services in scope of the NHSPS. As such, we ask for details of people responding to the survey. As well as calculating objection thresholds, we also use the information provided here in our analysis of responses, and to follow up with individuals on specific points raised where necessary”.

Step 4

Fill in your name and email address

Step 5

We have asked NHS England for advice on how to fill this in for individuals. We note there is a Yes/No answer to are you “Responding on behalf for multiple organisations”. But no Yes/No to whether you are an individual OR any clear way to indicate you are an individual. This indicates strongly they didn’t intend for individuals to be answering this.

To ensure answers are considered we advise filling as follows:

For organisation details:

Name of organisation: “Individual”

Organisation Code: Leave Blank

Organisation Type: “Other”

Step 6

Select “No” for responding on behalf of multiple organisations.

Step 7

Click “Next” to get to page 2. “Accepting or rejecting the proposed NHS Payment Scheme

Step 8

We have asked NHS England if individuals are supposed to answer this. As objections only count from Commissoners and Providers. In the meantime we think we should mark it as rejected.

 

Click “Reject”

Step 9

Enter your reasons. There is template text below if you want to use it:

 

Stakeholders were not appropriately consulted. Including a lack of consultation from patient groups, charities, the ADHD Taskforce, nor patients themselves. There has been no meaningful publicity of this campaign. The most significant publicity has come from the charity ADHD UK; however, these changes have the potential to impact a wide range of patient groups and the awareness within those circles is completely unknown.

The exact implication is not understood with a lack of clarity on how the new rules will impact services available to patients and the effective impact on Right to Choose for patients. Including the impact on accessibility. It is a mirage of Right to Choose, and does not comply with legislation, if the option isn’t accessible to patients. Compliance to legislation is not clear.

The equalities impact is not substantial enough. There is a SINGLE  paragraph on the impact on people with disabilities that concludes, “We are not aware of any other information that would suggest that the 2025/26 NHSPS proposals would have a disproportionate impact on this group of patients”. It appears an absence of known information is considered adequate and that absolutely isn’t enough. It does not outline what if any, work has been done to learn about the issues that might occur for people with ADHD or another disability. ADHD is formally recognised as a disability, and this directly affects care for individuals with ADHD. It does not appear that any adequate level of research has been done. I do not believe that the obligations to ensure equality and reduce health inequality as relevant in the Equalities Act, the Health and Social Care Act, or the NHS Constitution, have been fulfilled.

The consultation itself and the online survey appear to have not done anything to ensure that marginalised groups are aware of it, nor are there any meaningful attempts to ensure inclusivity. For individuals responding, no demographic data is taken, so there can be no way to know that the responses are representative nor identify who is not represented.

 

Step 10

Click “Strong negative impact”

Step 11

Fill in your answer for the question: “Do you have concerns that there are distinct groups with protected characteristics that our policies may impact negatively?”

As an option write: Individuals with ADHD and/or Autism.

 

Step 12

Fill in your answer for the question: “Please explain your reasons for your answers?”

As an option write: I am concerned about the availability, accessibility, and timeliness of ADHD and/or Autism Assessments and ADHD and/or Autism Support for individuals with suspected ADHD/Autism and/or with a diagnosis of ADHD/Autism. This is critical support for individuals with ADHD/Autism and these proposals are at high risk of negatively impacting that support.

 

Step 13

Click NEXT to go to page 3 “Proposals applying to all payment mechanisms

 Click STRONGLY OPPOSE to the first TWO.

Strongly oppose: To what extent do you support the proposed one-year NHSPS?

Strongly oppose: To what extent do you support the proposed payment principles?

You don’t need to add an explanation. You can then skip over the rest.

Step 14

Click CONTINUE to go to page 4 “Elective and activity-based payments

This is the especially important answer section that deals with Right to Choose. The next steps will guide you through filling it in.

Step 15

For the question: “To what extent do you support the proposal to require commissioners to set payment limits for elective activity, and all services paid for on an activity basis?

Click strongly oppose

Step 16

For the question: “Please explain the reasons for your answer” please write in as you want you can also use our template below:

I am concerned about the availability, accessibility, and timeliness of ADHD Assessments and ADHD Support for individuals with suspected ADHD and/or with a diagnosis of ADHD. This is critical support for individuals with ADHD and these proposals are at high risk of negatively impacting that support. I am concerned about the impact on other clinical areas and the lack of review on the impact for each of them.

I am concerned about the impact on waiting times for ADHD Assessments and the change in clarity on how long individuals can expect to wait. I am concerned on the impact on health inequalities (including regional health inequalities, socio-demographic inequalities, ethnicity based inequalties, disability based inequalities, gender based inequalities and aged based inequalities).

We know that there is an underdiagnosis of ADHD in the UK and higher levels of underdiagnosis in girls. More women in later life are realising they have ADHD and are coming forward for a diagnosis. The Right to Choose ADHD Pathway is disproportionately female. The consultation shows no evidence it has considered the impact on Women and ADHD.

Stakeholders were not appropriately consulted prior to this publication. Including a lack of consultation from patient groups, charities, the ADHD Taskforce, nor patients themselves. There has been no meaningful publicity of this campaign. The most significant publicity has come from the charity ADHD UK; however, these changes have the potential to impact a wide range of patient groups and the awareness within those circles is completely unknown.

The exact implication is not understood with a lack of clarity on how the new rules will impact services available to patients and the effective impact on Right to Choose for patients. Including the impact on accessibility. It is a mirage of Right to Choose, and does not comply with legislation, if the option isn’t accessible to patients. Compliance to legislation is not clear.

The equalities impact is not substantial enough. There is a SINGLE  paragraph on the impact on people with disabilities that concludes, “We are not aware of any other information that would suggest that the 2025/26 NHSPS proposals would have a disproportionate impact on this group of patients”. It appears an absence of known information is considered adequate and that absolutely isn’t enough. It does not outline what if any, work has been done to learn about the issues that might occur for people with ADHD or another disability. ADHD is formally recognised as a disability, and this directly affects care for individuals with ADHD. It does not appear that any adequate level of research has been done. I do not believe that the obligations to ensure equality and reduce health inequality as relevant in the Equalities Act, the Health and Social Care Act, or the NHS Constitution, have been fulfilled.

The consultation itself and the online survey appear to have not done anything to ensure that marginalised groups are aware of it, nor are there any meaningful attempts to ensure inclusivity. For individuals responding, no demographic data is taken, so there can be no way to know that the responses are representative nor identify who is not represented. 

Step 16

Click Continue to go through multiple sections. Stop at page 11. “Any other comments

Step 17

You can write into this section. If you would like a template you can use ours below:

“The proposed changes and their impact to NHS Choice and Right to Choose have the potential for significant patient impact. This process is not suitable or proper for a consultation with patients. Patient engagement has been limited. The documentation and forms are not patient-friendly. This form has been complex to fill in and many of the questions do not suit an individual answering.

The charity ADHD UK reports that over 11,000 emails have been sent to MPs outlining their concern about this process and this plan. I think you need to take those into account as a part of your evaluation of the changes the impact has on Right to Choose / NHS Choices”.

Step 18

Click continue until you reach the last page. At your option enter your email then click SUBMIT RESPONSE.

The form will not be sent without clicking SUBMIT RESPONSE.

Finished!

You can close the window.

If you gave an email address then you should get an email from them of your submission.

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