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, with NHS-funded and private work reported separately. It is only a recommendation so far, but the review's findings on waits, prices and missing data show why commissioners will want it.

What this means for you

• At the same providers, NHS-funded patients waited roughly seven to eight times as long as private patients for assessment, on our calculation from the review's figures. Reporting by payer would put your own gap in front of commissioners.
• Prices are likely to change. Tariffs differ about fourfold between ICBs, and NHS England plans to consult on national prices, with new payment arrangements from April 2027.
• If you can pull referrals, waits and outcomes by payer from your records now, you will be ready whatever is decided.

NHS-funded vs private waits: payer reporting would show each provider's gap#

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).

NHS-funded waits averaged 151 days for ADHD and 170 for autism, against 21.5 private#

Within those 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 for ADHD and five and a half for autism, against about three weeks. By our calculation, NHS-funded patients waited roughly seven to eight times as long.

Average wait for assessment at the same providersNHS-funded patientsPrivately funded patientsADHD assessmentNHS-funded waited about 7x as long21.5 days151 daysAutism assessmentNHS-funded waited about 8x as long21.5 days170 days060120180Average wait, 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).

The figures are rough: means only, with no provider count or period#

Treat these as a rough guide. They are means, which a small number of long waits can pull up, and the review gives no medians. It gives a single private figure not split by condition, and does not give a source, how many providers, what period, or when the clock starts. The seven to eight times ratios are our calculation, not the review's.

The review gives no cause; my guess is ICB limits on NHS-funded activity#

The review does not explain the gap. My guess is that ICB limits on NHS-funded activity, which our article on Right to Choose pauses covers, are a large part of it. Whatever the cause, once waits are reported by payer, each provider's own gap will be on show. If NHS and private patients share your clinicians, write down how you decide who is seen first.

Only around 10 of about 120 ADHD providers submitted data, so commissioners see little#

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 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 sums are large. According to Centre for Health and the Public Interest figures the review cites, NHS spending on independent-sector ADHD services rose by around 252% in three years, with a projected £164 million overspend across the ICBs analysed (p18, p265). Evidence gathered by the review suggests a relatively small number of large providers completed around 220,000 NHS-funded assessments in a single year (p328).

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 have the evidence the review says commissioners lack.

Tariffs vary about fourfold between ICBs, and national prices could flatten them#

Tariffs for what look like the same assessment differ by around fourfold between ICBs. The review says this seems to reflect the lack of an evidence-based tariff more than differences in how complex the cases are (p329).

The review wants Right to Choose and independent providers held to the same rules as directly commissioned services: a common minimum dataset, consistent pricing, agreed service standards and models of care, and quality and outcome measures as conditions of funding and registration (p329). The government has gone part of the way. NHS England will consult on national prices for NHS-funded ADHD and autism services, covering assessment, post-diagnostic support and follow-ups, with new payment arrangements planned from April 2027 (DHSC, 9 October 2026).

The highest provider margins are approaching one third#

The highest provider operating margins are approaching one third. NHS trusts typically run close to break-even (p329).

Combined assessments pay more than single ones#

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. That is less than two separate assessments (£2,000) but more than either one.

Clinics paid well above guide prices should plan for a lower, flatter price#

What this could mean for your pricing:

• If your ICB pays well above the guide prices, plan for a lower, flatter price.
• Record the clinical reason each time you assess for both conditions. 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 one city's combined pathway shortened time to diagnosis (below).
• Know your cost per assessment: clinician time, report writing and missed appointments. With a flatter price, that is where your margin comes from.
• Count post-diagnostic contacts now. The 2026/27 guide prices already pay for ADHD titration and annual reviews. For autism, post-assessment support is part of the assessment price, with no separate price for later support. The consultation covers post-diagnostic support, so that may change; our article on the Fonagy review's post-diagnostic offer covers what the review asks for.

Per-patient counting more than doubled one city's median time to diagnosis#

National waiting figures mostly treat each referral as a separate episode. The clock restarts after discharge, redirection or re-referral. A regional analysis for the review linked referrals for the same children in one city, and the picture changed (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.Counted per referral18.2 monthsHow national figures count: the clock restarts at each new referralCounted per child38.9 monthsLinking every referral for the same childChildren in one city, from a regional analysis done for the review. 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. The city's combined autism and ADHD pathway reduced both: 9.3 months per referral and 16.0 per child. The review wants linked data that show commissioners each person's whole journey (p313).

This matters for any provider that quotes an average wait. Count from your own acceptance date and you report the shorter number. If linked data arrive, commissioners will see the longer one. Measure from the first referral you hold. When a patient switches payer, link the two records rather than starting a new clock.

Right to Choose data condition is recommended only; national prices go to consultation#

The review makes three data 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 9 October government response did not include the data condition#

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

You should be able to produce eight measures, split by payer#

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

Six steps now prepare a clinic for payer reporting#

1. Take last quarter and try to produce the table above, split by payer.
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 and test it against a lower national price.
6. Watch for the Mental Health Strategy and the NHS England consultation on national prices.

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

Footnotes#

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