Fonagy review proposes new data rules for Right to Choose providers

The Fonagy review (the independent review into mental health conditions, ADHD and autism, published by DHSC on 9 October 2026) wants every ADHD and autism provider, Right to Choose included, to report activity, quality and outcomes data as a condition of funding and accreditation, with NHS-funded and private work reported separately. Commissioners now pay independent providers for most NHS-funded ADHD assessments, and get data from very few of them. In a separate point, the review also says linked data should show commissioners each patient's whole journey. Neither is required so far. If they go ahead, commissioners would see three things about your clinic that they cannot see today.

What this means for you

• Commissioners would see your NHS-funded and private waits side by side. At the same providers, NHS-funded patients waited roughly seven to eight times as long, on our calculation from its figures.
• With the linked data the review also wants, they would see waits across all of a patient's referrals, not just the time since you accepted them. In one city, counting that way about doubled the median time to diagnosis.
• They would see how often you assess for both ADHD and autism, which pays more than either alone. Record the clinical reason every time.
• You can check now whether your records can produce these numbers, before anyone asks.

1. Commissioners fund most of this work but get data from few providers#

Provider estimates in the review say independent providers delivered more than half of NHS-funded ADHD assessments and more than a third of autism assessments in 2025/26. Around 90% of that went through Right to Choose with no local contract (p306).

Right to Choose is a legal right rather than a contract, so providers generally do not have to send the routine data that commissioners can ask for under a contract. Of about 120 ADHD providers, only around 10 submitted data (p329).

About how many ADHD providers submitted dataSubmitted dataDid not submit dataAround 10 of about 120 ADHD providers submitted data.Around 10of about 120 ADHD providers submitted dataIllustrative. The review gives approximate counts (approximately 120 providers, around 10 submitted data) and no date for the count. The dot positions do not stand for specific providers.Source: Independent review into mental health conditions, ADHD and autism, DHSC, 2026, Chapter 15, p329. Contains public sector information licensed under the Open Government Licence v3.0.

The review says commissioners "often cannot see what they are paying for" and that this is not acceptable (p18). It also says this is no criticism of independent providers in principle.

The review does not date the count of 120 or say where the data went. NHS England's 2026/27 payment guidance already requires NHS-funded assessment providers, Right to Choose included, to send data to MHSDS or CSDS, as our guide to the 2026/27 payment guidance sets out. If you already send it, you are ahead of most providers.

2. The review wants data from every provider, split by payer, but it is not yet required#

Three proposals, including separate reporting of private work#

• Recommendation 5 (p445): all providers, including Right to Choose, should send consistent activity, quality and outcomes data as a condition of funding and accreditation, with NHS-funded and privately funded referrals, waits and outcomes reported separately.
• Recommendation 8 (p447): a minimum dataset, with outcomes broken down by ethnicity, deprivation and other characteristics.
• Mental Health Services Data Set (p430, supporting Recommendations 7 and 8): extend it to cover functioning, participation and outcomes at all providers, including Right to Choose.

Reporting private work is new, and the review does not say how it would be collected.

The government has not adopted the data condition, but NHS England will consult on national prices#

Prices are part of the same problem. Tariffs for what look like the same assessment differ about fourfold between ICBs, which the review says appears to reflect the lack of a consistently evidence-based tariff rather than differences in clinical complexity (p329). The 2026/27 guidance already tells commissioners to approve payment only when data and invoicing standards are met. My guess, not confirmed by anyone, is that national prices will come with data rules too.

3. Reporting by payer and linked data would show commissioners three things about your clinic#

Your NHS-funded patients wait far longer than your private ones#

At the same providers, NHS-funded patients waited a mean of 151 days for ADHD assessment and 170 days for autism assessment. The review gives a single figure for privately funded patients, 21.5 days, not split by condition (pp306-307). That is about five months against about three weeks.

Average wait for assessment at the same providersPrivately funded patientsNHS-funded patientsDay 170ADHD assessmentNHS-funded waited about 7x as longPrivately funded, both conditions (single figure): mean wait 21.5 days, about three weeks.Private21.5 daysADHD, NHS-funded: average wait 151 days, about five months.NHS-funded151 daysAutism assessmentNHS-funded waited about 8x as longPrivately funded, both conditions (single figure): mean wait 21.5 days, about three weeks.Private21.5 daysAutism, NHS-funded: average wait 170 days, about five and a half months.NHS-funded170 daysThe review gives a single private figure, 21.5 days, not split by ADHD and autism. All figures are means. The review gives no source, period or provider count, and does not say when the clock starts. The ratios are our calculation.Source: Independent review into mental health conditions, ADHD and autism, DHSC, 2026, Chapter 14, pp306-307. Contains public sector information licensed under the Open Government Licence v3.0.

In the review's words, "Timely assessment increasingly depends not only on where people live, but also on how care is funded" (pp306-307).

Treat the figures as a rough guide. They are means, which a few long waits can pull up, and the review does not give a source, how many providers, what period or when the clock starts. The seven to eight times ratio is our calculation, not the review's.

Today nobody outside your clinic sees this gap. With reporting by payer, commissioners would see it for every provider. If NHS-funded and private patients share your clinicians, write down how you decide who is seen first.

Your waits, counted per patient rather than per referral#

National waiting figures mostly treat each referral as a separate episode, so the clock restarts after discharge, redirection or re-referral. A regional analysis for the review linked referrals for the same children in one city (Box 14.3, p306).

Median time to diagnosis in one city, counted two waysSame children, counted two ways. Counting per child gives a wait about twice as long.1 year2 years3 yearsCounted per referral: median 18.2 months.Counted per referral18.2 monthsHow national figures count: the clock restarts at each new referralCounted per child: median 38.9 months.Counted per child38.9 monthsThe gap between the two counts is 20.7 months.+20.7 monthsLinking every referral for the same childChildren in one city, from a regional analysis done for the review. The 20.7 month gap is our calculation (38.9 minus 18.2). Source: Independent review into mental health conditions, ADHD and autism, DHSC, 2026, Box 14.3, p306. Contains public sector information licensed under the Open Government Licence v3.0.

Counted per referral, the median time to diagnosis was 18.2 months. Counted per child, it was 38.9 months, about twice as long. Separately from Recommendation 5, the review says linked data should make each person's whole journey visible to commissioners (p313).

If you count from your own acceptance date, you report the shorter number, and linked data, if it comes in, would show commissioners the longer one. Measure from the first referral you hold as well. When a patient switches payer, link the two records rather than starting a new clock.

How often you assess for both ADHD and autism#

Current tariffs, which are not mandatory, may reward combined ADHD and autism assessments, because they pay more whatever the clinical need (p329). NHS England's 2026/27 guide prices, also non-mandatory, follow the same pattern: a face-to-face combined adult assessment is £1,300, against £850 for adult ADHD alone and £1,150 for adult autism alone.

Data on which conditions you assessed would show commissioners how often you do both. The review is not against assessing both. It says that where more than one assessment is needed, they should be done separately, in a planned order, with shared clinical oversight (Recommendation 5, p444), and the same city's combined pathway cut the median time to diagnosis to 9.3 months per referral and 16.0 per child (p306). Record the clinical reason each time you assess for both conditions.

4. Check now that you can produce eight measures by payer#

For any period, split by Right to Choose, other NHS contracts and private:

Then:

1. Take last quarter and try to produce the table above.
2. Make payer a required field at intake, picked from a fixed list, and write down what starts and stops the clock. Our mixed payer guide covers the business side.
3. When a patient switches from NHS-funded to private, close the NHS referral and open a linked private one. If you overwrite the payer, a long NHS wait shows up as a short private one.
4. Keep waits as both a mean and a median, counted from the first referral as well as from acceptance.
5. Work out your cost per assessment, so you know where you stand when national prices are set.
6. Watch for the Mental Health Strategy and the NHS England consultation on national prices.

For the rest of the review, see CQC regulation, assessment standards, the review in charts and the series overview.

5. How Cerebric helps#

Cerebric runs NHS-funded, private and contract work through one pipeline, with every case tagged by payer. Activity and outcome reports split by payer for ICB commissioners, and the MHSDS return exports from the same records. It also takes on the admin around each assessment, from chasing questionnaires to drafting the report for the clinician to review, edit and sign, which lowers the cost of each one. Clinics using it complete 58% more assessments per clinician.¹

6. Footnotes#

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