NHS England is using a large-scale patient list review to address a gap of roughly six to seven million registrations between official population estimates and the number of people recorded with GP practices in England, a process that could affect practice funding and patient access.
NHS England Is Targeting A Multi-Million-Patient Discrepancy
The scale of the exercise emerged from an Equality and Health Inequalities Impact Assessment obtained through a Freedom of Information request and reported by Pulse Today.
Analysis by NHS England and the Office for National Statistics identified what the document describes as an approximate six to seven million difference between Census population figures and the number of patients registered with GP practices in England.
NHS England’s Patient List Inflation team is working to reduce that discrepancy while also changing how practices verify whether patients should remain registered.
The issue has immediate financial implications for surgeries because patient list size feeds into the formula used to calculate the global sum, one of the main sources of core GP funding. When registered patient numbers fall, practice income can fall with them.
Local medical committees have warned that some surgeries have already lost tens of thousands of pounds through the process, with practices in deprived areas reportedly among those experiencing the largest effects.
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The Verification Window Has Been Cut In Half
Under the established process, NHS England can contact patients when it believes their registration may no longer be valid and ask them to confirm their status within 30 days.
If the patient does not respond, a flag known as FP69 is added to the record. Practices previously had six months to verify the patient before automatic removal from the list.
That changed in October 2025, following an amendment to the GMS contract. Practices now have three months to respond.
NHS England considered removing the FP69 stage altogether, according to the assessment, but concerns raised by the BMA’s GP Committee and the Royal College of General Practitioners led it to retain the step.
The GP Committee warned that incorrect deductions could cause confusion and drive some patients toward emergency departments. The RCGP raised the risk of vulnerable patients being removed from GP lists in error.
Those concerns are central to the debate because registration does more than determine funding. It also links patients to routine follow-up, screening, medication reviews, recall systems and continuing care.
NHS England Plans More Automated And Frequent Checks
The impact assessment outlines several changes intended to make the patient list maintenance system faster and more targeted.
These include changes to processing times, more frequent contact with selected patient groups and broader use of a Statistical Assessment Model, or SAM, to decide which registrations require verification.
NHS England is also using activity information from the Personal Demographics Service alongside established clinical datasets to exclude some patients who have recent evidence of NHS contact and therefore may not need to confirm their registration.
Another proposal involves removing reminder letters and shifting toward digital-first communication.
That change has not yet been supported by a completed consultation process.
The document said: “Consultation on the specific proposal has not however been undertaken, and further research/analysis would provide an understanding of the impact of operational changes (e.g., removing reminders) on patient response rates.
“Ongoing design discussions and analysis will help refine approaches as part of the overall patient list inflation programme to better serve all future cohorts, with particular attention given to data-driven decision-making and equal access for vulnerable or underserved populations.”
The assessment itself remains a draft working document and, according to the FOI response, had not yet received formal organizational sign-off.
Vulnerable Patients Remain A Major Focus
The impact assessment examines whether changes to the list-maintenance system could disproportionately affect specific groups, particularly people who may have greater difficulty responding to official correspondence.
The document said: “The proposal does not have a direct or explicit impact based on race, ethnicity, nationality, or language. Ethnicity data is not used in any processes to act as a filter. Current processes have options available for letters in a variety of languages.
“Individuals with disabilities, including those with long-term mental health conditions or neurodivergence (e.g., autism, ADHD), may be more vulnerable to stress, anxiety, or confusion arising from formal communications.
“Patients with disabilities who access ongoing clinical support from the NHS are likely to be under-represented in the cohort as SAM uses well established clinical data sets (E.g. HES, Prescribing) to filter out patients who do not need to be contacted on their registration status.
“Disabled patients would not be disproportionately adversely affected by the reminder removal.”
GP representatives have nonetheless argued that some groups could be more exposed to mistaken deregistration, particularly people experiencing homelessness, patients who move frequently, and those who struggle to respond promptly to administrative requests.
Several local medical committees have called for greater scrutiny of the program. A group previously sought a parliamentary investigation into how the process had been approved, while the LMC Support Network wrote to the health secretary and NHS England asking for the exercise to be paused and for its methodology to be published. That letter was signed by 74 LMCs across England.
Funding Questions Are Increasing The Pressure On Practices
The financial consequences remain one of the most sensitive parts of the program.
Because GP payments are linked in part to registered patient numbers, removing people from practice lists can quickly translate into lower income. GP leaders in London have called for emergency “parachute payments” for surgeries facing abrupt reductions.
NHS England has previously pledged that money saved through the exercise will “remain in general practice.”
The wider question is how that money will be redistributed and whether practices experiencing sudden reductions in list size will receive enough support to avoid disruption.
For now, the list-maintenance drive continues against the backdrop of a discrepancy estimated at six to seven million registrations, while the principal equality assessment disclosed through the FOI process remains a draft that has not yet received formal NHS England sign-off.
