Digital providers should be offered financial “incentives” to encourage them to “maximise their offerings”, according to Babylon.

The digital-first provider also called for primary care IT infrastructure to be updated to allow Babylon GP at Hand’s technology to work seamlessly with existing systems.

This would make it easier for healthcare providers to use Babylon’s technology to run their own digital-first service, the company said.

It comes in response to NHS England’s consultation on digital first primary care, launched in June, to review funding inequalities between local GP practices and digital first providers, while also addressing high patient churn associated with digital services.

Babylon said they “fully agree” with NHSE plans to tackle the challenges, but that proposals to limit patient list sizes to CCG areas had “unworkable practical and administrative implications for providers and commissioners”. Instead the list sizes should be assigned to STP/ICS areas.

They also argued that proposed changes to rent and rate reimbursements, which could limit digital providers access to compensations, sends a “clear signal” the NHS favours traditional practices over digital-first providers.

NHSE proposes to change out-of-area registration rules so when a practice exceeds a threshold – which Babylon suggests should be 1,000 – their contract is disaggregated and an alternative provider medical services (APMS) set up, including a physical premises.

Babylon argued a payment should be made on a “per registered patient” basis to cover costs borne as a result of the new APMS.

“This also avoids additional costs to commissioners should other digital-first providers not be able to match Babylon GP at Hand’s high proportion of digital interactions and consequently require more clinical space,” the consultation response said.

“Whether the area is under-doctored or not, it is very important that the reasonable costs to deliver digital-first services are provided for in the APMS contracts, particularly where these costs are outside the control of the digital-first provider.

“For example, the costs of integrating with local NHS and GP core IT systems have been very significant for Babylon GP at hand, with no reimbursement whatsoever. This creates an inequity in which digital-first providers are not reimbursed for reasonable and unavoidable costs of service provision, whereas traditional providers are.”


The consultation proposes to:
  • Amend out-of-area registration rules so when a practice exceeds a threshold of out-of-area patients (possibly between 1,000-2,000), their contract is disaggregated
  • Change the allocations system to allow quarterly recalculation of CCG funding to reflect patient movements of the sort which have been stimulated by registration with digital-first practices in London
  • Make no changes to the GP payment formula for new patients at this point, but only pay if a patient remains registered with a practice for a defined period, likely to be between six to 12 months
  • Use practice entry rules to address inverse care law – NHSE suggests allowing digital first practices to register patients in under-doctored areas, for example CCGs in the bottom 10-20%
  • Potentially remove the need for most local Alternative Provider Medical Services (APMS) procurements by looking to PCNs as the default mechanism for maintaining primary care provision

To ensure digital providers can fully access local pathways GP system suppliers should be “instructed” to make necessary software developments to support a “multi-tenant model”, Babylon said.

Paul Bate, managing director of NHS Services at Babylon, added: “This really is a transformative opportunity for the NHS to ensure patients can access digital-first primary care, in line with the aims of the NHS Long Term Plan.

“These proposals can enable the NHS’s vision of digital-first services to become a reality. Babylon’s technology means that patients can go from waiting times of weeks to appointments within hours. These new plans would mean more patients could choose the type of service they want, whenever they want.”

The consultation closed on August 23.

The British Medical Association called for out-of-area GP registration rules to be “withdrawn” to prevent digital providers prioritising healthy patients in their response to the consultation.

If the out-of-area registration rules remain the same, a reduced payment should be applied to patients who have registered with a digital first provider, the BMA added.

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