OFNC Guidance on Covid-19 Funding for Optical Practices in England

28 October 2020

As set out in our statement of 26 October, this guidance provides more information about the COVID-19 funding arrangements set out in NHS England’s letter of 26 October (reference 001559). This OFNC guidance has been endorsed by the NHS England-Improvement optical commissioning team.

We may update this guidance to reflect further questions from the sector, and as we receive more information from NHS England. Please always check that you are accessing the most recent version. This version is the original guidance issued on 28 October.

Future additional support payments

1. What does my practice have to do to obtain the average GOS payments for August and September?
   NHS England has now confirmed practices will receive the average GOS payment for both August and September if they delivered at least 40% of their pre-pandemic GOS 1 (sight test) activity. The August payment was made in September. Due to the delay in NHS England confirming the September payment, it will be made retrospectively in November.
   We understand the NHS Business Services Authority (BSA) will audit a random sample of practices that receive these average GOS payments, to check their activity has met the 40% threshold.
   If your practice does not receive an average GOS payment for August or September, and you believe it has delivered at least 40% of pre-pandemic GOS 1 activity, you should contact your normal PSCE contact in the first instance.
2. What average GOS support will be available after September?
   Further support after September will only be available to:
   • Domiciliary contractors (additional services contract holders)
   • Fixed practice contractors (mandatory services contract holders) whose GOS claims would normally be at least £2,500 a month and comprise more than 40% of practice income, are in deprived areas, are struggling to recover, and which meet the new criteria to qualify for support, or can show they need support on an exceptional basis (see FAQ 6 below)
   The support available to qualifying domiciliary contractors will be:
   • 60% of historic average GOS (as paid in previous months) to cover October 2020 – this payment will not be made until December, because of NHS England’s delay in finalising its announcement on further support
   • 45% of historic average GOS to cover November 2020 – this payment will be made in December
   • 30% of historic average GOS to cover December 2020 – this payment will be made in January 2021.
   The support for other qualifying contractors will take the form of additional payments on top of their actual GOS activity levels in October, November and December 2020, to bring their total GOS income for each qualifying month up to 90% of their average GOS payment. The payments for October and November will be made in December, and the payment for December will be made in January 2021.
3. How do I find out if my practice will meet the criteria to qualify for further support after September?
   Domiciliary contractors will be automatically eligible for further support payments covering October,  November and December 2020. They will not have to apply for the support, and will not have to meet service delivery targets to qualify for the support.
   Fixed practice contractors will only qualify  for further support payments covering these months if they meet all the following criteria:
   1) The practice is located in the first or second most deprived decile in England as measured by the Index of Multiple Deprivation
   2) The practice can show from its management accounts that before the pandemic, GOS claims made up at least 40% of the practice’s normal income across the full year 2019/20
   3) The practice had historic GOS income of at least £2,500 a month in the period from March 2019 to February 2020
   4) The practice submits a declaration that it is experiencing financial hardship because of the impact of COVID-19
   5) The practice delivers at least the following proportion of its pre-pandemic GOS 1 (NHS sight test) activity:
   • 55% in October
   • 65% in November
   • 80% in December
4. What must I do to claim the further support?
   Domiciliary contactors will receive the support automatically.
   Fixed practices will be contacted by the NHS BSA (via email where contact details are held, or by letter) if they believe you meet the deprived area requirement, to assess whether your practice meets the other criteria listed in FAQ 3 above, and is therefore eligible for further support payments.
   Fixed practices wishing to claim the support will need to complete a declaration form provided by NHS England, and submit it to NHS England & NHS Improvement Extended Contract Arrangements at england.dentaloptoms@nhs.net. All applications must be made by email. If you need an electronic copy of the declaration form, you should contact england.dentaloptoms@nhs.net.
   If you think your fixed practice meets the deprived area requirement, but you do not receive an invitation to apply for financial support, you should contact NHS England & NHS Improvement at england.dentaloptoms@nhs.net to request a declaration form. You can then use that form to submit the required information in support of your application.
5. Why are these criteria being applied now?
   NHS England anticipates that most GOS contractors are now able to provide sufficient face-to-face care to ensure the ongoing viability of their businesses. However, following representations by the OFNC, NHS England accepts that domiciliary GOS contractors, and contractors in areas of high relative deprivation which depend heavily on GOS income, are likely to need ongoing support after the end of September to maintain eye care services to their respective populations.
6. What happens if my practice doesn’t meet these criteria but is still suffering real financial hardship because of COVID-19 and needs support?
   NHS England has confirmed that regional teams will consider applications for support on an ‘exceptional’ basis, where practices don’t meet these criteria but are reliant on GOS income and can demonstrate hardship as a direct result of COVID-19. If you need support but do not meet all the criteria, you should contact NHS England and NHS Improvement at england.dentaloptoms@nhs.net and apply for inclusion in the scheme. You will be asked to complete a declaration form and provide as much information as possible in support of your application.
   If necessary, your representative body (ABDO, AOP or FODO) will be able to provide further advice on how to make a special case for support.
7. I’m a domiciliary contractor – will I be eligible for further support payments in autumn 2020?
   Yes. All providers in England with additional services (domiciliary) contracts will receive the following support payments:
   • 60% of historic average GOS (as paid in previous months) to cover October 2020 – this will be paid in December
   • 45% of historic average GOS to cover November 2020 – this will also be paid in December
   • 30% of historic average GOS to cover December 2020 – this will be paid in January 2021.
   You will not have to meet any activity requirements or other additional criteria to receive these payments. You should not need to contact your NHS England regional team to arrange these payments, and should contact PCSE directly if you do not receive a payment you are expecting.
8. My optical practice does some domiciliary work – will it be eligible for further support payments?
   If you made GOS claims for domiciliary work between March 2019 and February 2020, your practice will be eligible for support payments in respect of that element of its work. The support payments will be the relevant percentage (60%, 45% or 30% as above) of the historic average value of your practice’s GOS domiciliary work between March 2019 and February 2020. You will not receive support payments in respect of non-domiciliary GOS work during that period, unless your practice qualifies under the criteria for ongoing support for fixed practices.
9. What will happen after these new support payments end?
   NHS England and the OFNC will keep developments under review and will provide further information nearer the time.
10. What will happen if there’s a local or regional lockdown affecting my practice?
    The NHS England letter of 26 October says that if public health measures require it, it may be necessary to return contracts back to the operating model used between 1 April 2020 and 17 June 2020, when practices were not able to provide routine care, and received average GOS payments if they were open for essential care.
    This is only likely to happen if a regional lockdown or further national lockdown significantly reduces GOS contractors’ ability to provide routine care. The OFNC will issue further guidance if this becomes necessary. There is more information about what practices need to do to be considered open for essential care in the OFNC FAQs of April 2020.

Reduction to past support payments

11. What is the reduction, and why is it being imposed?
NHS England’s letter of 1 April, which set out the plan for average GOS support payments to practices that remained open for essential care during lockdown, said that “an agreed and fair reduction for any variable costs associated with service delivery (e.g. in recognition of reduced consumable costs associated with dispensing of frames and lenses) will be applied to all reimbursements. This will be discussed and agreed with the OFNC.”
The level of the reduction negotiated between the OFNC and NHS England is confirmed in NHS England’s letter of 26 October. The reduction will be:
• 6.43% of those average support payments made to holders of mandatory (fixed practice) contracts in respect of the period from 1 April to 17 June 2020
• 7.86% of those average support payments made to holders of additional services (domiciliary) contracts in respect of the same period.

12. When and how will NHS England recover this money?
NHS England has said it will recover this money by deducting it from payments to be made to GOS contractors, over a period between a starting point to be confirmed, and 31 March 2021.
The OFNC will provide further information on this once the position is confirmed.

13. How have these reduction been calculated?
The reductions were agreed between the OFNC and NHS England. The 6.43% reduction for mandatory contracts reflects an estimate of the average saving that contractors will have made during the period from 1 April to 17 June by receiving payments based partly on historic GOS voucher claims, without incurring costs relating to frames and lenses. The 7.86% reduction for domiciliary contracts also reflects an estimate of the average saving to contractors from reduced travel costs during that period.
For comparison, NHS England has negotiated a reduction of 16.75% to average support payments to dental contractors over the equivalent period.

Reimbursement for PPE costs

14. How will I be reimbursed for additional costs relating to PPE during the pandemic?
The Department of Health and Social Care has now provided access to free PPE for all GOS contractors, via an online portal which went live on 17 August. More information about the PPE portal is available here. The OFNC is aware that some GOS contactors have experienced difficulty in ordering the amount of PPE they need to support their GOS work from the portal, and is in urgent discussion with DHSC and NHS England to resolve this.
NHS England has said that it will reimburse contractors for additional PPE costs incurred before they were able to access free PPE via the portal. The mechanism for this reimbursement has not yet been confirmed. The OFNC will provide further information on this once the position is confirmed.

NHS England Standard Operating Procedure

15. What changes have been made to the revised NHS England-Improvement guidance and standard operating procedure: Primary care optical settings in the context of coronavirus (COVID-19) compared with the version issued on 17 June?
We are reviewing the changes to the SOP, but understand that they largely reflect existing sector guidance on operating under COVID-19 conditions. We will issue further guidance if necessary.