PCN commissioning paramedic services requires a distinct contractual process that differs significantly from a single practice engaging a locum or agency clinician. This guide is written for PCN clinical directors and network business managers who have already decided they want paramedic capacity and now need to understand the governance and contractual steps to bring a third-party provider in at network level. For background on ARRS funding eligibility, see ARRS Paramedic Funding 2026. For contract payment changes, see GP Contract 2026/27 Changes.
This article is written for PCN clinical directors and network business managers. It does not constitute legal, contractual, or procurement advice. Always confirm requirements with your commissioner and LMC before entering any sub-contracting arrangement.
Author: Flemming Jensen, Founder, NorMed | Last reviewed: September 2026
What PCN-Level Commissioning Actually Means
PCN commissioning paramedic services at network level is a fundamentally different transaction from a single GP practice paying an agency for cover. When a PCN contracts a third-party clinical provider, that provider is delivering services under the Network Contract Directed Enhanced Service, not simply filling a rota gap. The PCN, as a legal entity, becomes the contracting party. Member practices benefit from the service, but the liability, governance, and contractual obligations sit at network level.
This distinction matters operationally. The PCN clinical director carries responsibility for clinical governance across the network. The network business manager is typically responsible for ensuring that contracts are in place, that information governance obligations are met, and that the commissioner is appropriately informed. Neither role can delegate those responsibilities to a provider without the correct documentation being in place first.
PCNs with no changes to membership or information do not need to re-submit sign-up information to their commissioner for 2026/27, as practices already signed up in 2025/26 automatically participate in the updated DES. However, adding a new third-party provider is a change that does require commissioner engagement, regardless of sign-up status.
The Contractual Route: Sub-Contracting Under the Network Contract DES
The primary mechanism for PCN commissioning paramedic services from a third-party organisation is sub-contracting under the Network Contract DES. NHS England publishes a standard template titled “Sub-contract for the provision of services related to the Network Contract DES 2026/27.” PCNs must use this template, or a locally agreed variant, when contracting a third party to deliver services under the DES. Using a bespoke commercial contract in isolation is not sufficient and may place the PCN in breach of its DES obligations.
The sub-contract template governs the scope of services, clinical governance responsibilities, reporting requirements, and termination provisions. It also sets out the liability position between the PCN and the provider. Additionally, the NHS England Network Contract DES guidance makes clear that sub-contracted services must remain within the scope of what the DES permits. This means the paramedic-led activities delivered must align with agreed DES service specifications.
From 2026/27, PCNs may recruit or contract a broader range of ARRS roles, where agreed with the commissioner. This flexibility is relevant when scoping a paramedic-led service, because the activities you commission must map to permitted ARRS functions. For a full overview of how community paramedic roles work within general practice, refer to NorMed’s dedicated guide.
The Documents a PCN Needs in Place
PCN commissioning paramedic services from a third party requires four core documents before any clinical activity begins. Each serves a distinct legal and governance function. Confusing them, or missing one, creates risk for the network.
- Network agreement: NHS England publishes a mandatory Network Contract DES network agreement template. This governs the relationship between member practices and the PCN itself. It must be in place before any sub-contracting can occur.
- Sub-contract: The NHS England DES sub-contract template, completed between the PCN and the third-party provider, governs service delivery obligations, clinical governance, and liability.
- Data sharing agreement: NHS England also publishes a template data sharing agreement. This governs what patient data is shared between the PCN, member practices, and the provider, and under what conditions.
- Data processing agreement: Where the provider processes personal data on behalf of the PCN, a data processing agreement is required under UK GDPR. NHS England publishes a template for this purpose.
All four documents should be reviewed by the PCN’s legal adviser or solicitor before signature. The LMC can also advise on whether the terms reflect local norms. For remote clinical triage services specifically, the cost of outsourcing GP triage article sets out what financial due diligence looks like at practice level, though network-level contracting will involve additional layers.
Who Has to Approve What
PCN commissioning paramedic services from a third party is not a decision the clinical director can make unilaterally. Several approval steps are required, and the sequence matters. First, the PCN board or equivalent governance body must agree the decision in principle. Second, the commissioner, typically the Integrated Care Board (ICB), must be informed and, in many cases, must agree before the sub-contract is executed.
ICB involvement is not optional where the sub-contracted service draws on ARRS funding, because that funding is administered through the ICB. The ICB will want to satisfy itself that the provider is delivering within DES scope and that governance arrangements are adequate. Some ICBs publish their own local guidance on acceptable sub-contracting arrangements, so it is worth requesting this early.
Where a commissioner is minded to require a PCN to include a particular practice, the commissioner must engage with the relevant LMC and have regard to the LMC’s views. More broadly, the LMC is a valuable early consultation point when a PCN is structuring a new provider arrangement, particularly where member practices have differing views on participation. The NHS England GP contract investment guidance provides further context on the commissioner’s role in network oversight.
Local Variations from May 2026 and Why They Matter
From 1 May 2026, ICBs can request local variations to the Network Contract DES, known as Network Contract DES LV. These variations are limited to amendments to sections 7, 8 and 10.1 to 10.5 of the specification. This allows arrangements to be tailored to local circumstances, including how paramedic-led services are structured at neighbourhood level.
For PCNs, this is significant. A PCN building a neighbourhood health model that includes extended access paramedic services may find that local variation enables a configuration not available under the standard DES. However, any local variation must still be requested through the ICB and agreed formally. PCNs cannot simply self-declare a local variation. The NHS England guidance on the DES from May 2026 sets out which sections are eligible for local variation and the process for requesting one.
PCN clinical directors should review the DES from April 2026 guidance alongside the May update to understand what changed and when. ARRS funding continues into 2026/27, including funding for cohorts of GPs recruited during 2024/25 and 2025/26, totalling £197 million for the full year. Local variation decisions should account for how that funding is allocated across the network.
Information Governance for a Remote Clinical Provider
Information governance is frequently the area that delays service start dates most significantly. When a PCN commissions a remote clinical triage provider, that provider’s clinicians need access to patient records held in EMIS or SystmOne. This access must be formally established and governed before any patient contact takes place.
The data processing agreement sets out the lawful basis for record access and the provider’s obligations as a data processor. However, the practical steps required by EMIS or SystmOne suppliers typically include a formal request from the data controller, which is the PCN or member practice, and evidence that appropriate data sharing agreements are in place. System suppliers will not grant access on the basis of a verbal assurance.
Additionally, the provider must demonstrate compliance with the Data Security and Protection Toolkit, and individual clinicians must hold appropriate professional registration. Establish all of these requirements explicitly in the sub-contract, not as an implied expectation. The same requirements apply to any community-based service the PCN commissions, including care home paramedic in-reach.
Practical Sequencing: From Decision to Service Start
PCN commissioning paramedic services follows a logical sequence, and skipping steps creates delays later. The following order reflects what most PCNs will need to work through in practice.
- Step 1: Internal agreement. Secure agreement from the PCN board and member practice leads. Confirm the service scope, intended patient cohort, and funding source.
- Step 2: Commissioner engagement. Notify the ICB of the intention to sub-contract. Request any local commissioning requirements or preferred provider lists. Check whether a Network Contract DES LV is relevant.
- Step 3: LMC consultation. Brief the LMC early, particularly if member practices have divergent views. The LMC can also advise on whether the sub-contract terms are appropriate.
- Step 4: Document preparation. Complete the network agreement, sub-contract, data sharing agreement, and data processing agreement. Have all four reviewed by a legal adviser before signature.
- Step 5: Information governance setup. Apply for system access through EMIS or SystmOne. Confirm DSP Toolkit compliance and indemnity cover with the provider. Set a go-live date only once access is confirmed.
- Step 6: Clinical governance sign-off. The clinical director should formally sign off the clinical governance framework, including escalation pathways, supervision arrangements, and audit requirements, before the first patient contact.
This sequencing applies whether the PCN is commissioning remote clinical triage, face-to-face community paramedic sessions, or a blended model. The GP workforce challenges driving demand for paramedic-led skill mix are well documented; see NorMed’s overview of the GP workforce shortage in 2026 for context on why PCNs are moving in this direction.
How NorMed Works with PCNs at Network Level
NorMed is a paramedic-led primary care services provider working directly with PCNs and GP practices across the UK. At network level, NorMed supports PCN commissioning paramedic services by providing all required governance documentation as standard, including a compliant data processing agreement, evidence of DSP Toolkit compliance, and HCPC-registered clinicians with appropriate indemnity cover.
NorMed’s clinical lead and contract team work alongside PCN business managers to complete the NHS England sub-contract template and to prepare the information required for ICB sign-off. The service operates across both remote clinical triage and face-to-face community paramedic models, and can be configured to align with local Network Contract DES LV arrangements where applicable.
NorMed does not operate as a locum agency. The service is structured as a clinician-led, managed service, which means the PCN receives a governance-ready provider relationship rather than individual clinician placements. For PCNs considering extended access delivery, NorMed’s extended access paramedic service is specifically designed for network-level deployment.
Frequently Asked Questions
Does a PCN need ICB approval before signing a sub-contract with a paramedic provider?
In most cases, yes. Where the sub-contracted service draws on ARRS funding or falls within the scope of the Network Contract DES, the ICB needs to be informed and typically must agree before the sub-contract is executed. PCN commissioning paramedic services without prior commissioner engagement risks placing the network in breach of its DES obligations. Always confirm the specific approval requirements with your ICB and seek LMC advice early in the process.
Which NHS England documents does a PCN need when commissioning a third-party paramedic provider?
A PCN commissioning paramedic services from a third party needs four core documents: the NHS England Network Contract DES network agreement, the NHS England DES sub-contract template completed with the provider, a data sharing agreement, and a data processing agreement. NHS England publishes standard templates for all four. Each document serves a distinct legal and governance function, and all four should be in place before clinical activity begins. Legal review is strongly recommended before any signature is applied.
What does Network Contract DES LV allow a PCN to do differently from May 2026?
From 1 May 2026, ICBs can request local variations to the Network Contract DES, known as Network Contract DES LV. These are limited to amendments to sections 7, 8 and 10.1 to 10.5 of the specification. In practice, this allows local arrangements to be tailored, which may affect how paramedic-led services are structured at neighbourhood level. PCNs cannot self-declare a variation. The ICB must request and agree it formally. Review the NHS England DES from May 2026 guidance for the specific sections eligible for variation.
Can a PCN use its own commercial contract instead of the NHS England sub-contract template?
No. When commissioning services under the Network Contract DES, PCNs are required to use the NHS England standard sub-contract template, or a locally agreed variant approved by the commissioner. Using a standalone commercial contract in isolation is not sufficient and may place the PCN in breach of its DES obligations. If a provider proposes their own contract document, this should be reviewed against the NHS England template requirements before signature.
How long does the commissioning process typically take from decision to service start?
The timeline varies, but most PCNs should allow a minimum of eight to twelve weeks from the point of internal agreement to service go-live. Commissioner engagement, LMC consultation, document preparation, legal review, and information governance setup each take time. EMIS and SystmOne access applications in particular can introduce delays if not initiated early. PCN commissioning paramedic services works most smoothly when the business manager initiates commissioner contact at the same time as internal governance discussions begin, rather than sequentially.
