Question 1

Where can I find The National Health Service (General Medical Services Contracts) (Wales) Regulations 2023 - aka GMS regulations?

Accepted Answer

The latest version of The National Health Service (General Medical Services Contracts) (Wales) Regulations 2023 - aka GMS regulations - is available here.(https://www.legislation.gov.uk/wsi/2023/953/contents)

GPDF h(https://gpdf.org.uk/)ave provided Consolidated Regulations for 2025 which include:
 • NHS Performers List Regulations Wales Consolidated 2025(https://gpdf.org.uk/wp-content/uploads/2025/12/GEN0010028-Performers-List-Regs-Wales-2004-as-at-01.10.25.pdf.pdf)
 • NHS General Medical Services Contracts Regulations Wales Consolidated 2025(https://gpdf.org.uk/wp-content/uploads/2025/12/GEN0010028-GMS-Contracts-Regulations-Wales-2023-as-at-01.10.25.pdf.pdf)
 • NHS Statement of Financial Entitlements Regulations Wales Consolidated 2025(https://gpdf.org.uk/wp-content/uploads/2025/12/GEN0010028-SFE-Wales-as-at-01.10.25.pdf.pdf)

Question 2

Where can I find the latest information about the 2025-26 Contract?

Accepted Answer

Read about the outcome of tripartite negotiations for the Welsh GMS contract, which covers 2025/26 and investment for 2026/27 on the BMA website.(https://www.bma.org.uk/pay-and-contracts/contracts/gp-contract/welsh-gp-contract-2025-26) This includes a joint letter form GPC Wales and Welsh Government (https://www.bma.org.uk/media/gptljek0/20251212-joint-letter-to-gps-gms-contract-2025-26-and-26-27-outcome-eng.pdf)and a summary of the changes which have been considered and agreed through the course of formal negotiations to date, setting out a full picture of the final overall contract package offer.(https://www.bma.org.uk/media/lbkmrebv/20251212-joint-letter-to-gps-annex-a-gms-negs-25-26-final-outcomes.pdf)

Question 3

Should our practice sign up for an enhanced service?

Accepted Answer

Enhanced services vary across Wales, and there is no single resource describing them. Morgannwg LMC has created a summary spreadsheet (in both excel and pdf format) describing the services available in every Healthboard in Wales. The information was obtained by making freedom of information requests to each Healthboard and also to Welsh government. All information in the spreadsheet comes directly from these public sources.

Please use it to support your business planning and negotiations.

This project was made possible through a generous grant from GPDF.(https://www.gpdf.org.uk/) If you have any questions or suggestions please contact Morgannwg LMC.(https://www.morgannwglmc.org.uk/)

The information is available as an Excel spreadsheet (https://download-files.wixmp.com/ugd/3f3663_f9250696d829493daa6817b42baf7168.xlsx?token=eyJhbGciOiJIUzI1NiIsInR5cCI6IkpXVCJ9.eyJpc3MiOiJ1cm46YXBwOmU2NjYzMGU3MTRmMDQ5MGFhZWExZjE0OWIzYjY5ZTMyIiwic3ViIjoidXJuOmFwcDplNjY2MzBlNzE0ZjA0OTBhYWVhMWYxNDliM2I2OWUzMiIsImF1ZCI6WyJ1cm46c2VydmljZTpmaWxlLmRvd25sb2FkIl0sImlhdCI6MTc0MjkwMDg5NCwiZXhwIjoxNzQyOTM2OTA0LCJqdGkiOiIyNDJlOWQxNC1kNGQxLTRiZDAtYjAzZC1jMjdlNmE0NTJmMjQiLCJvYmoiOltbeyJwYXRoIjoiL3VnZC8zZjM2NjNfZjkyNTA2OTZkODI5NDkzZGFhNjgxN2I0MmJhZjcxNjgueGxzeCJ9XV0sImRpcyI6eyJmaWxlbmFtZSI6IkVuaGFuY2VkIFNlcnZpY2VzIFdhbGVzIDEyMTEyMDI0Lnhsc3giLCJ0eXBlIjoiYXR0YWNobWVudCJ9fQ.jmqauNbd-koAm3OYLNxtqsF95D9zpPMX9GM7q3d4OjA)or PDF a(https://download-files.wixmp.com/ugd/3f3663_99468e42ad5f4d12a3ce56376ee59d0e.pdf?token=eyJhbGciOiJIUzI1NiIsInR5cCI6IkpXVCJ9.eyJpc3MiOiJ1cm46YXBwOmU2NjYzMGU3MTRmMDQ5MGFhZWExZjE0OWIzYjY5ZTMyIiwic3ViIjoidXJuOmFwcDplNjY2MzBlNzE0ZjA0OTBhYWVhMWYxNDliM2I2OWUzMiIsImF1ZCI6WyJ1cm46c2VydmljZTpmaWxlLmRvd25sb2FkIl0sImlhdCI6MTc0MjkwMDkzMiwiZXhwIjoxNzQyOTM2OTQyLCJqdGkiOiJkOWVkZmRhMy1jYTkxLTQ4NDEtYWYxMS00ZTBiNjg5OTFhY2IiLCJvYmoiOltbeyJwYXRoIjoiL3VnZC8zZjM2NjNfOTk0NjhlNDJhZDVmNGQxMmEzY2U1NjM3NmVlNTlkMGUucGRmIn1dXSwiZGlzIjp7ImZpbGVuYW1lIjoiRW5oYW5jZWQgU2VydmljZXMgV2FsZXMgMTIxMTIwMjQucGRmIiwidHlwZSI6ImF0dGFjaG1lbnQifX0.oXw4WMKB3El-ZrRw8ugwFKvT519srNf6hxmcijWSBYk)nd the source information is available here.(https://download-files.wixmp.com/archives/3f3663_ad44434d10054f27a100437b62f5e2bc.zip?token=eyJhbGciOiJIUzI1NiIsInR5cCI6IkpXVCJ9.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.nnnDCqzhAR7_sZkaAcuYCKWVci9lj5tAIbT95by2ZpY)

https://static.wixstatic.com/media/3f3663_d3b29b20a0a949e9a3d4f4d3e01cf741~mv2.png

Budgeting and forecasting

To help practices to calculate costs incurred in providing supplementary services, Gwent LMC have developed a useful calculator which has been included below. It is necessary to factor in human resource expenses (salary, oncosts and mandatory training) , building expenses (including insurance) and materials and fixed costs. This means including proportionally the number of clinical and admin staff involved and all the running costs such as fridges, beds, lights in minor surgery room, extra cleaning etc.

Enhanced Service Financial Calculator

Gwent LMC have developed a calculator to aid business decisions about the viability of enhanced services for practices. It will allow additional costs such as pension, NI contributions etc to be automatically included. Just input hourly staff rates and time spent by differing members of the practice team to get an overall estimate of practice costs to complete an activity.

Gwent LMC Enhanced Service Calculator(https://www.gwentlmc.org.uk/_common/getdocument?id=263180)

Recent Uplift from SBUHB

Please note that MLMC were unable to reach a mutually agreeable position regarding an uplift with SBUHB. SBUHB felt that their offer of a 5% uplift was reasonable considering their financial position, but MLMC did not feel that they could endorse the offer based upon the information contained in the comparative spreadsheet.

If practices would like a further discussion about supplementary services please do not hesitate to get in touch with MLMC.(https://www.morgannwglmc.org.uk/contact)

The letter from SBUHB can be downloaded for reference here.(https://download-files.wixmp.com/ugd/3f3663_cd0104125659405fa56e26e16e037095.pdf?token=eyJhbGciOiJIUzI1NiIsInR5cCI6IkpXVCJ9.eyJpc3MiOiJ1cm46YXBwOmU2NjYzMGU3MTRmMDQ5MGFhZWExZjE0OWIzYjY5ZTMyIiwic3ViIjoidXJuOmFwcDplNjY2MzBlNzE0ZjA0OTBhYWVhMWYxNDliM2I2OWUzMiIsImF1ZCI6WyJ1cm46c2VydmljZTpmaWxlLmRvd25sb2FkIl0sImlhdCI6MTc0MjkwMDgzNywiZXhwIjoxNzQyOTM2ODQ3LCJqdGkiOiJlZDg0MTQ3MS00ZTkzLTRiYTQtYjNhNC1mMDE4MGViZTNhMzAiLCJvYmoiOltbeyJwYXRoIjoiL3VnZC8zZjM2NjNfY2QwMTA0MTI1NjU5NDA1ZmE1NmUyNmUxNmUwMzcwOTUucGRmIn1dXSwiZGlzIjp7ImZpbGVuYW1lIjoiU0JVIEhCIHVwbGlmdCBsZXR0ZXIgTm92ZW1iZXIgMjAyNC5wZGYiLCJ0eXBlIjoiYXR0YWNobWVudCJ9fQ.7gK1w-Q0tRifbSNsOJPCDCjRFQJ4jtDOWqOLAVaD0A8)

Question 4

How does my practice withdraw from an enhanced service?

Accepted Answer

Work out the cost of the service
 • Look at current level of remuneration and cost to deliver service.
 • Have a chat amongst clinical team and with practice manager to decide next steps.
 • If you wish to continue then read no further

Payment not covering costs and / or impacting on GMS care?
 • You can withdraw from the service
 
How to withdraw:
 • Give 3/12 notice in writing to the Health Board of your intention and reasons.
 • Ask for them to inform you of where to redirect patients once notice period has ended. Put a time date on response to this and put a diary marker in your diary to check this has been responded too.
 • Copy in the other services affected by the decision

Top tip – make sure you get confirmation of receipt – email 	route perfect for this

Continue to provide the service for 3/12
 • Start updating your staff that service is no longer going to be provided and ensure all know where to refer patients once service has ended. Consider giving them a “script” to use when faced with such requests
 • Start to inform your patients via posters / screen messages / during consultations of when this service will no longer be available and why (if appropriate)
 • The LMC will be developing patient information materials for you to use in some cases
 • Consider how you can best utilise the freed up resource/ time to provide additional capacity within your clinical team

Keep track
 • Make a note on your systems when service is due to end
 • Remind all staff after that date that you no longer provide these services and where they should send patients.

What if the HB don’t tell you what to do with patients after notice period?
 • Contact the LMC Office

Morgannwg LMC is here to support you! 
It is not unusual to feel concerned at stopping work OR to think that you are the only practice considering taking this action. YOU ARE NOT. Practices can no longer continue providing services at financial or clinical capacity costs to themselves.  Follow the checklist above, discuss as a practice and reach your own conclusion.

Question 5

I'm confused by the 2025-26 Influenza vaccination requirements, what are the requirements?

Accepted Answer

Contractual Requirements and Data Entry
 
 • A new flu vaccination delivery model has resulted in some operational challenges.
 • All provider practices must adhere to the National Primary Care Contractual Instruments (PCCIs) Schedule 2025, which is the same for both general practices and community pharmacy to ensure equity of service.
 • The specification requires that vaccine administration and stock checks must be data entered onto the WIS system by the end of the working day.
 • Due to significant and sporadic outages of the WIS system, practices were previously authorized to input data on the following working day, a situation which may have caused confusion.
 • Practices must log any data upload concerns with the primary care team and immunisations team via the general primary care email (even on weekends) to maintain an audit trail. A DHCW service point call is also recommended for evidence.
 • The Health Board (HB) agreed to send out a communication to clarify contractual data entry requirements and address any confusion.
 
Functionality and Use of WIS
 
 • Practices reported that WIS flu invites were being sent too late, causing patients to miss appointments.
 • WIS is sending generic blanket text messages that invite patients to a session rather than a specific time.
 • It was agreed that the specification allows practices to use their in-house appointment systems or "established booking system including GP Clinical systems" to invite patients for flu vaccination; the specification does not mandate using WIS for flu invites.
 • Opportunistic administration of the flu vaccine is encouraged.
 • There is confusion because the requirement is to ONLY use WIS to invite patients for the COVID-19 vaccine, which is difficult to manage alongside the separate rules for flu, especially given changes to the eligible age ranges.
 • The HB confirmed the technical ability to use WIS for both flu and COVID-19 invites, but noted "teething problems."
 • The HB agreed to issue a clarification immediately to address misinformation regarding invitation methods.
 
WIS Write-Back Delays
 
 • Significant WIS write-back delays were reported (up to four days), which creates a clinical governance risk as patients could receive the vaccine from another provider (e.g., a pharmacy) during the delay period.
 • A national update was shared indicating the WIS platform had been down from 6-9 October to address duplicate entries. Duplications were found from both clinical systems (EMIS/Vision) and WIS, as well as some unexplained duplicates.
 • The impact of these delays on the practice's ability to call and recall patients will need to be monitored.

HB Vaccination Assurance
 
 • The HB has not started any general 'mop-up' programme and plans to begin administering to the general population only on December 1st, 2025, as per the national specification.
 • Requests to vaccinate housebound patients have been declined, with a request made for those practices signed up to the supplementary service to administer.
 • The HB has agreed to a request to vaccinate care home residents for flu. This area needs greater clarity and coordination for future years, as the HB administers COVID-19 in care homes while practices are asked to do the flu vaccine.
 • A national Task and Finish Group has been set up to specifically resolve care home vaccination challenges.
 • Other groups who may have been vaccinated by the HB include pregnant women at HB clinics and NHS staff, which may have caused confusion.
 • Due to responding to specific practice-based requests, the HB is currently unable to issue an assurance that no flu vaccines have been administered.

Uptake Targets
 
 • Practices still have a 75% target rate for vaccination.
 • The HB is confident there is enough stock for all eligible over 65s.
 • Uptake for 2-3 year olds and at-risk groups remains low, consistent with previous years.
 • A representative noted that recent negative discussions in the media have affected this year's uptake, and asked the HB to update the website with more guidance to help patients research vaccine safety.
 • The HB agreed to look into ways to disseminate patient information.
 
Patient Booking Phone Line
 
 • Patient delays were reported when using the immunisation service booking line.
 • The HB confirmed a phone outage on one specific day in October. Outside of this, the average call waiting time was 3 minutes, with the longest reported wait being 10 minutes.

Question 6

What is the Health Board approach to taxation and employment status of GPs working in directly managed practices or Health Board managed Out of Hours services?

Accepted Answer

What is the problem? HMRC has recently taken a keen interest in the employment status of many independent contractors which includes GPs working in a sessional capacity. In essence, if it determines that you are employed, as opposed to being self-employed, then your tax and national insurance contributions will be removed by the organisation which pays you. In addition, if the organisation has, in HMRC’s opinion, wrongly treated you as self-employed then the organisation can face a significant fine and interest which can potentially go back as far as 20 years. Therefore, this is causing much angst amongst employers. In particular, Health Boards have become very concerned about their potential liabilities and have commissioned specific advice from Deloitte. The Health Board interpretation of this advice has concluded that GPs working for the Health Board but not in a salaried position (e.g. in out of hours centres; in prisons; doing shifts in a minor injuries unit; working in directly managed practices) should be classed as employed for taxation purposes but not for employment purposes. Thus, you would be unable to access employment rights, which includes annual leave / sick leave / maternity leave / and other parental rights. Their assertion applies to all sessional GPs whether working through an intermediary (where IR35 applies) or not. Please note, for avoidance of doubt, this guidance applies also to GP principals or salaried GPs offering services and directly contracting with the Health Board on a sessional basis for the types of work as outlined above.
Does GPC Wales believe that the Health Board interpretation of the taxation status is correct for GPs working in above settings?
Sadly, it appears that the HMRC toolkit to determine whether an individual is employed or self-employed isn’t always that clear-cut, and thus there are risks to any organisation in getting it wrong. However, we support the guidance in other parts of the UK; namely that blanket application of the ruling is wrong as it doesn’t allow for differences in an individual’s circumstances.
Does GPC Wales believe that the Health Board interpretation is correct for the employment status / ability to access employment rights of GPs working in above settings?
We do not feel this interpretation is correct. The tests to determine whether an individual is employed for taxation purposes and for access to employment rights are very similar, and it seems nonsensical to say they apply to one section and not to the other. We believe this could be open to challenge by GPs who contract directly with the Health Board. However, if you are working through an intermediary/ personal service company (see below) then it is unlikely that you could argue you are employed for employment benefits.
Isn’t this just about the HMRC IR35 regulation?
This is wider than the application of IR35 regulations. IR35 solely applies to GPs working through an intermediary such as limited liability companies. These are often described as a personal service company which individuals have set up so that they avoid paying tax and are liable to a lower rate of tax via corporation tax (which currently stands at 19% rather than the tax levels for higher earners) and this is why HMRC at trying to close the loophole. The approach from the Welsh Health Boards applies to all sessional GPs working as above. Matt Mayer from the BMA sessional GPs committee has written an excellent blog on this issue which can be accessed here.(https://www.bma.org.uk/connecting-doctors/the_practice/b/weblog/posts/a-locum-sguide-%20to-the-changes-to-ir35-legislation)
Should I just accept the HB advice?
We would say no. There are a few issues to consider
 • Lack of consultation: is this fair or right given the significant change to your terms and conditions of service?
 • The assertion that employment status does not confer employment rights Do your own HMRC toolkit assessment and take individual accountant advice
 • Talk to your LMC or contact the BMA if you are a member (unfortunately neither are in a position to offer individual legal or financial advice).
WHAT ACTIONS ARE POSSIBLE?
1. What can I do?
1. Consider the BMA website advice, complete the HMRC toolkit and discuss the results with your accountant. You could use it to challenge the Health Board to apply non-employed status to you. However, it is unlikely the Health Board will change its stance and the toolkit isn’t quite clear cut.
2. Consider whether you want to continue working for an organisation that has taken this unilateral action. Your accountant may be able to help guide this with respect to impact on tax brackets etc.
3. Consider whether to ask your LMC to act on your behalf and outline what course of action you wish them to take. You should do this whether you continue working or not.
4. Consider whether you are willing to withdraw services or not? The BMAs sessional GP subcommittee states that you can consider the following:
    • If you are willing to withdraw services, then further think about whether you would add your name to signatures to be gathered by LMCs threatening to withdraw services OR write to the Health Board declaring a termination of service in accordance with the contractual obligations to which you are subject.
    • If you are not willing to withdraw services, then (if you are a GP who contracts directly rather than via an intermediary) consider writing to the Health Board telling them that you believe you are entitled to statutory employment protection and reserve the right to take them to an employment tribunal, and advise them, if employment tribunal found in your favour that you would be chasing historic holiday pay / sick pay / pension etc. back to your start date. This latter needs to be done by an individual GP.

2. What can your LMC do?
LMCs do have the responsibility of acting on behalf of all GPs in their area in all their working roles. To do so effectively they need a clear mandate from the workforce affected – therefore you have to play your role in making your feelings known. The LMC can:
1. liaise with Health Board to ask further questions as to validity of this change to terms and conditions of service through seeking to see evidence, challenging lack of consultation, highlighting potential adverse impact on sustainability of workforce and service provision (including whether this is on the Health Board’s risk register)
2. work with the Health Board to find possible solutions e.g. deferred implementation date of changes to enable consultation, devising a zero-hours contract for local GPs to work under which could confer some employment rights etc.
3. keep local GPs up to date with likely impact of these decisions and progress on solutions
4. work on your behalf without you having to raise your head above the parapet e.g. gather signatures from affected GPs threatening to withdraw services; OR collate responses from GPs to the Health Boards declaring a termination of services in accordance with the contractual obligations to which they are subject.
3. What is GPC Wales doing?
GPC Wales is:
1. working closely with LMCs to support them in progressing local discussions and solutions on behalf of GPs in their area (that’s why it is important to make your views and situation known to LMCs)
2. in our regular meetings with the Welsh Government, highlighting risks to service provision and workforce sustainability in an already creaking service area, requesting that it seeks assurance from Health Boards on how these risks have been considered, including in respect of winter pressure plans
3. considering what other national solutions may need to be implemented after listening to the profession and seeing how the Health Boards respond e.g. a national zero-hours contract for GPs working in settings as above What already happened in Wales and elsewhere?
    • Betsi Cadwaladr UHB did not use Deloitte to determine its stance but instead worked directly with HMRC. This has already been put in place and GPs have made individual decisions whether or not to accept changes, and this has resulted in less GPs working in directly managed practices.
    • In Dorset, a blanket policy was applied early in 2017 which was challenged by GPs, LMC and GPC. A new deal was offered to GPs with better pay and employment rights and a catastrophe was averted.
    • In Swindon, the OOH trust applied a blanket policy but despite pressure did not back down and this resulted in great difficulty in sourcing doctors.

What should I do next?
It comes down to whether you as an individual want to take action on this. Please review this guidance carefully and consider all the available options before deciding on your response. The Local Medical Committees and GPC Wales are here to help. We need to know your views to inform our next steps in discussions with Health Boards at a local level, and the Welsh Government on a national basis. Please inform your LMC about what you want to see happen.

Question 7

I work in Out of Hours (OOH), am I covered by General Medical Practice Indemnity (GMPI)?

Accepted Answer

The Scheme for General Medical Practice Indemnity (GMPI) is a discretionary state-backed scheme that covers clinical negligence claims for incidents occurring on or after 1 April 2019.

The indemnity coverage differs significantly depending on how the GP is engaged:

1. Out of hours services (OOH) provided via contractual arrangements between a Health Board and an independent provider/sub-contractor, are captured by the scheme for GMPI. This includes any locum or agency staff who are engaged via such independent provider/sub-contractor. However, all locum doctors who are engaged by an independent provider sub-contractor (other than those doing locum work solely in their own GP practice) are required to join the All Wales Locum Register, to have access to the scheme for GMPI

2. Any employees, locum, agency or bank workers who are directly engaged by a Health Board are captured by standard NHS indemnity arrangements. (this is not GMPI)

So you need to be quite clear as to your employment status and if it qualifies for section one then you are covered under the GMPI and need to be on the whole Wales register but don't have to document every Out Of Hours shift.

So for peace of mind individuals should get clarity about their contractual status with the health board and then contact their indemnity provider to see if they are covered.

The other burning question is all the guidance talks about Out Of Hours services and again clarification would need to be gained from GMPI regarding NHS111 which operates in hours.

Update 27/1/26

Further to enquiry from SBHB they can confirm that when an OOH service is provided directly by a HB—whether the HB employs staff or engages locums/agency workers—those individuals are fully covered under the longstanding NHS indemnity not GMPI, just as hospital doctors are with no requirement for this work to be recorded in Locum Hub Wales. There is of course the additional requirement for MDU/MPD etc indemnity for professional issues. The same applies to NHS 111 workers.

Do I Need to Register for the All Wales Locum Register?(https://nwssp.nhs.wales/ourservices/employment-services/employment-services-documents/primary-care-sustainability/lhw-quick-reference-guide/)