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Fonagy review 2026: what changes for ADHD and autism providers

Summary of the Fonagy review (DHSC, October 2026) for ADHD and autism providers: the four changes it proposes, what the government has committed to, and next steps.

Cerebric Team· 10 October 2026· 9 min read
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Policy
In this article
  1. 1. Demand grew faster than the checks on it
  2. 2. Every assessment would need CQC registration
  3. 3. Assessments held to common standards
  4. 4. Data by payer, and national prices
  5. 5. Support expected before and after diagnosis
  6. 6. Only CQC regulation and a prices consultation are committed
  7. 7. Five steps, one for each change
  8. 8. Where Cerebric fits
  9. Frequently asked questions
  10. Citations

The Fonagy review (the independent review into mental health conditions, ADHD and autism, published by the Department of Health and Social Care on 9 October 2026) found that demand for ADHD and autism assessment, and the independent market meeting it, grew faster than the checks on either. Independent providers now do more than half of NHS-funded ADHD assessments, on provider estimates the review cites, and only around 10 of about 120 ADHD providers submitted data. The review's answer, for providers, comes down to four changes: CQC registration for every diagnostic assessment, common assessment standards, data reported by payer, and support before and after diagnosis. So far the government has committed to the first, with no date, and NHS England will consult on national prices.

What this means for you

  • CQC. If you only assess, expect to need CQC registration once new regulations are in place, whether your patients are NHS-funded or self-pay. No date has been set.
  • Standards. Your records will need to show how you reached each conclusion: co-occurring conditions, day-to-day functioning, informant evidence, and why you assessed remotely or in person.
  • Data. Expect to report waits and outcomes with NHS-funded and private work kept separate. At the same providers, NHS-funded patients waited roughly seven to eight times as long as private patients, on our calculation from the review's figures.
  • Support. Expect commissioners to ask what people get from you while they wait and after diagnosis, not just how long they wait.

1. Demand and the independent market grew faster than the checks on them#

The final report, chaired by Professor Peter Fonagy, makes ten recommendations. Its central proposal is a move from a "diagnosis-dependent" system to a "needs-led plus diagnosis" one (Recommendation 2), so that people get support as soon as a need is clear, with diagnosis carried on alongside. As Professor Fonagy put it, "Diagnosis remains essential and must be protected - what has to change is that it is no longer the only door through which help can be reached."

Waiting lists are 13 to 17 times their 2019 level#

Open ADHD and autism referrals in England, 2019 to 2025Open referrals waiting for or in assessment, all ages. Values read from the review's Figure 7.4.December 2025:ADHD583,00017.2× April 2019Autism250,00013.8× April 2019Dashed line: from February 2025 NHS England's ADHD figures include new submissions from independent providers, which account for most of that month's jump. NHS England says later months are not directly comparable with earlier ones.Values read from the review's chart and rounded. Counts are open referrals, not people. The review's text gives more than 560,000 ADHD and more than 254,000 autism open referrals at the end of 2025. NHS England says its ADHD figures from February 2025 are not directly comparable with earlier months because of new submissions from independent providers. It also says its December 2025 autism figure rose 9.3% in one month, partly because one independent provider began submitting data. Source: Independent review into mental health conditions, ADHD and autism, DHSC, 2026, Figure 7.4 (NHS England data); NHS England, ADHD Management Information, May 2026; NHS England, Autism Statistics, December 2025. Contains public sector information licensed under the Open Government Licence v3.0.

The review says open ADHD referrals exceeded 560,000 by the end of 2025, more than seventeen times the number in 2019 (p129). By December 2025 more than 254,000 people had an open autism referral, around thirteen times the 2019 level (p164). The review's chart, which our figure redraws, puts December 2025 at about 583,000 ADHD and about 250,000 autism referrals. The ADHD figures are counts of open referrals, not people. Part of the ADHD jump in February 2025 reflects new submissions from independent providers, which NHS England says make later months not directly comparable. NHS England also says its December 2025 autism figure rose 9.3% in one month, partly because one independent provider began submitting data. More than 90% of people with an open autism referral had waited longer than 13 weeks.

The review cannot conclude that overdiagnosis is happening at scale, but says that if present trends continue, the balance of risk is shifting towards misdiagnosis and overdiagnosis. It says the much faster rise in recorded ADHD among females than males is consistent with better recognition of groups missed before, particularly women and girls, and adults (p131), though it finds that no single explanation accounts for the overall rise (p151). Our who is being diagnosed article has the numbers by age and sex.

Independent providers do most NHS-funded ADHD assessment, and few send data#

Provider estimates cited by the review say independent providers did more than half of NHS-funded ADHD assessments and more than a third of autism assessments in 2025/26. NHS spending on independent-sector ADHD services rose by about 252% over three financial years, in the integrated care boards that answered freedom of information requests, figures the review takes from a Centre for Health and the Public Interest report. Yet of about 120 ADHD providers, only around 10 submitted data. Right to Choose providers are generally not required to send commissioners routine data.

The review says it is "not acceptable" that public money spent with independent providers runs without consistent oversight or transparency. It also says its concerns are "no criticism of independent provision in principle". The four changes below are its answer.

2. Every diagnostic assessment would need CQC registration#

Recommendation 5 asks for all ADHD and autism diagnostic assessment to become a CQC-regulated activity. On the day the report was published, CQC said it had been asked to regulate all ADHD and autism diagnostic assessments once new regulations are in place. This is the one change the government has committed to, with no date.

Today, a service that only diagnoses does not need to register, because CQC does not count diagnosing ADHD or autism as treatment. If you prescribe or titrate, you should already be registered for treatment of disease, disorder or injury. DHSC says NHS-funded and self-pay patients will both be covered. Our CQC regulation article covers scope and what registration takes.

3. Assessments would be held to common standards#

The review says misdiagnosis is more likely where assessment is brief, not face to face, split across services, made without informants or records, or focused on one condition. For autism assessment, responding independent and Right to Choose providers reported around 90% remote delivery, and diagnostic conversion rates from 66% to 93% across providers, with averages of 79% to 86% (p165). The review attributes these figures to the Independent Healthcare Providers Network. It says they need careful interpretation, because comparable NHS data on case mix and outcomes are not routinely available.

The proposed standards would require assessment of co-occurring conditions and day-to-day functioning, guidance on when remote assessment is right, and consistent training standards for assessors. None have been written, and the government has not committed to them. Even so, your records can show each of these now: why a case was remote or in person, which informants and records you used, and how you considered other conditions. Our assessment standards article sets out what each record should show.

4. Waits and outcomes would be reported by payer, and prices set nationally#

Recommendation 5 also asks every provider, Right to Choose included, to report activity, quality and outcomes data as a condition of funding, with NHS-funded and private referrals, waits and outcomes reported separately. Two findings show what that would put in front of commissioners:

  • The payer gap. At the same providers, NHS-funded patients waited a mean of 151 days for an ADHD assessment and 170 days for autism, against 21.5 days for privately funded patients. The review gives a single private figure, not split by condition, and no sample size or period, so the ratio of roughly seven to eight times is our calculation.
  • The whole wait. In one city, the median time to diagnosis was 38.9 months counted per child, but 18.2 months counted per referral, because national figures restart the clock after discharge or re-referral. If commissioners link records, they may see a much longer wait.

Prices are changing too. The review found that prices for similar assessments vary about fourfold between integrated care boards, and NHS England will consult on national prices, with new payment arrangements intended from April 2027. The data condition itself has not been adopted. Our data reporting article covers what to have ready.

5. Support would be expected before and after diagnosis#

The review wants waiting to include monitoring and support, and a diagnosis to start support rather than end it. It says "a diagnostic report and signposting alone do not constitute an adequate post-diagnostic offer". In autism services, 40% of clinicians surveyed for the review reported no ongoing post-diagnostic support, and only 12.6% described support beyond a single session.

Waiting does harm too. In CQC's 2024 Community mental health survey, reproduced in the review (p318), the share of people who said their mental health got worse rose from around one in four for waits under two weeks to more than seven in ten for waits over six months. The survey did not cover ADHD or autism waiting lists, and only about one in five people replied.

The gap affects your own patients. The review says GP acceptance of shared care for medication started by independent providers has fallen to an average of around 62% and is still falling, because of concerns about assessment quality and the availability of ongoing specialist support. The proposed national prices would cover post-diagnostic support and follow-ups, so expect to show what you deliver. See our post-diagnostic offer article.

6. The government has committed to CQC regulation and a consultation on national prices; the rest waits for the strategy#

The ten recommendations and where the government standsEach tile is one recommendation, shaded by the government's position on 9 October 2026. Select a tile to see what it asks for and what it means for providers.CommittedBeing explored or left to the strategyNot mentionedCommitted3Being explored1Left to the strategy4Not mentioned2Recommendation 5 · Committed · Affects providersCommissioning, regulation and CQCIt asks forMake all ADHD and autism diagnostic assessment CQC-regulated, set common standards, require data from all providers as a condition of funding and ban direct-to-public advertising of NHS-funded assessments.GovernmentCommitted. The government is 'working towards' CQC regulation, and CQC says it will regulate once new regulations are in place. No date has been given.Different approach. No ban was announced. As part of a review of advertising practices, the Health Secretary will write to the Advertising Standards Authority about adverts for ADHD and autism services.Different approach. ICBs must improve oversight of the assessment services they commission, and the minister said all NHS-funded services will provide high-quality assessments. Common standards for every provider were not mentioned.Not mentioned. Data as a condition of funding was not mentioned. Separately, NHS England will consult on national prices and intends new payment arrangements from April 2027.For providersThe most direct for providers: CQC registration for assessment-only services, standards on co-occurring conditions, functioning, remote or in-person assessment and assessor training, NHS-funded and private work reported separately, and limits on marketing.CQC regulation →Assessment standards →Data reporting →Who would actIn practice DHSC, NHS England, CQC and ICBs (the review does not say who does each action)TimescaleNone set“Providers” on a tile marks the six recommendations that affect assessment providers. Government positions are our reading of the DHSC press release and the minister's speech of 9 October 2026. There is no recommendation-by-recommendation response yet. Source: Independent review into mental health conditions, ADHD and autism, DHSC, 2026, chapter 20. Contains public sector information licensed under the Open Government Licence v3.0.

There is no recommendation-by-recommendation response yet. Based on the DHSC press release and the minister's speech, here is where each of the four changes stands:

ChangeWhere it stands
CQC registration for every diagnostic assessmentCommitted. No date, and no consultation announced.
Common assessment standardsNot mentioned. Among the measures the government says it is exploring is working with NICE to urgently consider what the report means for its ADHD and autism guidance.
Data reported by payer, as a condition of fundingNot mentioned. ICBs must improve oversight of the services they commission.
Support before and after diagnosisSupport without waiting for a diagnosis is backed. Proposed national prices would cover post-diagnostic support; NHS England intends new payment arrangements from April 2027.

Right to Choose was not mentioned, and the review does not propose ending it. No advertising ban was announced; the Health Secretary will write to the Advertising Standards Authority as part of a review of advertising practices. The full response is due in a Mental Health Strategy in the coming months. Our guide to all ten recommendations goes through each one.

7. Five steps to take now, one for each change#

  1. CQC. Check your position. If you only assess, start on governance, safeguarding and evidence of assessment quality.
  2. Standards. Check each assessment file records co-occurring conditions, day-to-day functioning, informant evidence, and why it was remote or in person.
  3. Data. Report referrals, waits and outcomes for NHS-funded and private work separately, and measure waits per patient as well as per referral.
  4. Support. Write down what you offer while people wait and after diagnosis, including a clear GP letter.
  5. Prices. Work out your cost per assessment, so you can answer the prices consultation with numbers.

8. Where Cerebric fits#

Cerebric records each referral with its payer, so waits and outcomes can be reported separately for NHS-funded and private work. It sends, chases and scores questionnaires so informant evidence is on file before the assessment, and drafts reports linked to their sources for the clinician to review, edit and sign. Clinics using it cut report writing time by 75%.1

9. Footnotes#

  1. Measured at UK Right to Choose and private neurodevelopmental providers using Cerebric, 2025–26. ↩

Frequently asked questions

What is the Fonagy review?

It is the independent review into mental health conditions, ADHD and autism, chaired by Professor Peter Fonagy and published by the Department of Health and Social Care on 9 October 2026. It makes ten recommendations, including CQC regulation of all ADHD and autism diagnostic assessments.

Does the Fonagy review end Right to Choose?

No. It wants Right to Choose providers to meet the same standards as other services and to send data as a condition of funding. The government's response on 9 October did not mention Right to Choose.

When will CQC start regulating diagnosis-only ADHD and autism assessments?

No date has been set. New regulations are needed first, and no consultation or timeline had been published by 10 October 2026. Services that diagnose and treat already have to register with CQC.

Does the review say ADHD and autism are overdiagnosed?

Not on current evidence. It says it cannot conclude that overdiagnosis is happening at scale, but that if present trends continue the balance of risk is shifting towards misdiagnosis and overdiagnosis. It also warns that carrying on as before creates "a serious risk of overdiagnosis in the strict use of the word", and it asks for more careful assessment.

Citations

More in the Fonagy review series

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