Primary Care Networks are not being abolished, and no decision has been made requiring them to change. What has changed is that NHS England opened a consultation on 16 July 2026, running until 10 September 2026, on two new contract types, a Single Neighbourhood Provider (SNP) and a Multi-Neighbourhood Provider (MNP), that are explicitly described as a possible evolution of the PCN Directed Enhanced Service (DES). Nothing in that consultation is final, but GP partners and practice managers should understand what is actually being proposed now, rather than relying on secondhand summaries.
We advise GP partnerships and PCNs on contracts, governance and incorporation, and this is currently the single most common question we are being asked. This post sets out, from NHS England’s own consultation document, what the proposed SNP model actually involves, how it relates to the existing PCN DES, and what a sensible practice or PCN should be doing between now and the September deadline. For the wider policy context, see our companion post, The Neighbourhood Health Framework: What It Means for Your GP Practice, and our existing guide, Primary Care Networks Explained: A Legal Guide for GP Practices.
What Is Actually Confirmed as at 28 July 2026
Three things are settled, direct from NHS England’s own documents. First, the Neighbourhood Health Framework, published 17 March 2026, does not itself change the PCN DES or any GP contract. Second, the consultation on the proposed SNP and MNP contracting models opened on 16 July 2026 and closes on 10 September 2026, with NHS England stating explicitly that responses will “inform further, detailed consultation on firmer proposals for both the Multi Neighbourhood Provider and Single Neighbourhood Provider Contracts later this year”. Third, the GMS contract itself is not within the scope of this consultation at all: NHS England states plainly that “Government policy is to keep and reform the GMS Contract”, and that GMS, PMS and APMS contracts will continue to determine core general practice services nationally.
Everything else, how the SNP contract would actually work, whether your PCN would move to it and when, and what happens to Additional Roles Reimbursement Scheme (ARRS) funding in the transition, is currently a proposal open for consultation, not a decision.
How the Proposed SNP Contract Relates to the PCN DES
NHS England’s consultation document describes the SNP Contract as “an evolution of the Primary Care Network Contract Directed Enhanced Service (PCN DES) which local systems can take forward at their own pace”. The document is explicit that the SNP Contract and the PCN DES are not intended to co-exist in the same geography, since they would cover the same population within an MNP footprint. In other words, this is being framed as a replacement pathway for the DES in areas that adopt it, not an additional layer on top of it.
Three commissioning options are set out for how a PCN’s area could move (or not move) towards the SNP model. Systems and PCNs would need to choose one; the options are not intended to run in parallel.
| Option | How it works | What happens to the PCN DES |
|---|---|---|
| Option 1: Local variation through PCNs | With PCN agreement, ICBs request NHS England approval to vary elements of the PCN DES locally. This route has already been available from 1 May 2026. | PCN DES continues, with locally agreed variations. ICBs must maintain funding at least equivalent to the standard PCN DES, including ARRS. |
| Option 2: ICB commissions each SNP directly | Practices voluntarily switch from the PCN DES to an SNP Contract commissioned directly by the ICB. Unlike the annual PCN DES, an SNP Contract could run over multiple years. | PCN DES ends for that neighbourhood once practices move across. Minimum funding equivalent to PCN DES (including ARRS) is required initially. |
| Option 3: ICB commissions an MNP, which sub-contracts to SNPs | The ICB commissions a Multi-Neighbourhood Provider to coordinate services across several neighbourhoods; the MNP then sub-contracts primary medical elements to SNPs (or to PCNs, where no SNP exists in that footprint). | Same minimum SNP funding protection applies, but contracting effort shifts to a single MNP relationship rather than multiple direct ICB-SNP contracts. |
Under all three options, NHS England’s stated position is that ICBs would be required to maintain a minimum investment in neighbourhood-level primary medical services equivalent to the current PCN DES, including ARRS staff funding, at least in the initial stage of any transition. That funding floor is a proposal in the consultation, not a guarantee written into any contract yet, and should be treated accordingly until the further consultation NHS England has said will follow later in 2026.
Population Size and Governance: What Changes for PCNs Practically
The working assumption in both the Neighbourhood Health Framework and the SNP/MNP consultation is that a single neighbourhood, and therefore a potential SNP, would cover a population of around 50,000, while a Multi-Neighbourhood Provider footprint would typically be 250,000 or more. NHS England is explicit it will not mandate these sizes nationally. In many parts of the country, the existing PCN footprint (commonly in the 30,000 to 50,000 range) already maps reasonably closely onto the proposed SNP population, which is precisely why NHS England has framed the SNP as a natural evolution rather than a completely new structure.
The governance point that matters most for GP partners is this: an SNP Contract must be held by a legal entity. The consultation gives examples including a lead GP practice acting on behalf of a consortium, a limited liability partnership, or a Community Interest Company. There is no requirement to form a new legal entity if practices do not wish to, but PCNs that want to take an SNP Contract on at scale, hold pooled budgets, or employ staff directly rather than through a lead practice arrangement, will need to think carefully about which structure fits, whether that is a lead practice arrangement, a limited liability partnership or a Community Interest Company. This is exactly the decision covered in our guide, PCN Incorporation: The Why and the How, and it interacts directly with each partner’s existing GP partnership agreement, particularly around liability, profit sharing and what happens if one practice in a consortium wants to exit.
What the Consultation Does Not Answer Yet
Being precise about the gaps matters as much as being precise about what is confirmed. As at 28 July 2026, NHS England has not yet published: the detailed contractual terms of either the SNP or MNP contract; a national timetable for when, or whether, any given area must move from PCN DES to SNP; how existing PCN Clinical Director roles and PCN participation agreements would map onto an SNP governance structure; or how procurement law (the Provider Selection Regime and the Procurement Act 2023) would apply in practice to smaller GP-led providers taking on an MNP or SNP contract, beyond a general commitment that requirements will be “proportionate” and will not disadvantage smaller providers.
NHS England has said a further, more detailed consultation on firmer proposals for both contracts will follow later in 2026, after this first consultation closes on 10 September. Any practice or PCN making structural decisions based on the current proposals alone, rather than waiting for that further detail, should do so with its eyes open about what is still subject to change.
What PCNs and GP Partners Should Do Now
- Read the consultation itself, not just commentary on it, and consider responding before 10 September 2026, particularly if your PCN has views on the three commissioning options or on how procurement requirements should apply to smaller providers
- Review your existing PCN participation agreement and your practice’s GP partnership agreement now, so you understand your current liability and decision-making arrangements before any move to a new contract structure is even on the table
- Hold off on incorporating a new legal entity purely in anticipation of the SNP model until the further consultation later in 2026 clarifies the detailed terms, unless there is a separate, existing reason to do so
- Keep a clear record of your PCN’s current ARRS-funded roles and DES income, so that if a funding transition does happen, you can hold commissioners to the stated minimum funding commitment
- Engage with your ICB directly about how it is approaching neighbourhood footprints locally, since this will shape which of the three options is realistic in your area
What This Means for Your Practice
PCNs have a future. What is genuinely uncertain is their future form: whether your PCN continues broadly as it is under a locally varied DES, evolves into a Single Neighbourhood Provider with its own multi-year contract, or becomes one of several SNPs sitting under a Multi-Neighbourhood Provider. All three routes are live possibilities under NHS England’s own consultation, and which one applies to you will likely be decided locally by your ICB over the next 12 to 18 months rather than nationally overnight. The practical priority now is making sure your governance and partnership arrangements are in good order before that decision is made, not after.
If you would like advice on your PCN participation agreement, GP partnership structure, or how to prepare for a possible move to a Single Neighbourhood Provider contract, get in touch with our healthcare team, or read more about our work on NHS regulatory compliance. Call us on +44 207 566 1188 or email info@gurvelegal.com.
