Health contributions and the primary care case
Health contribution requests convert your unit mix into patients and then into premises cost. Each step is checkable, and the link to a named project is where most fail.
A health contribution request on a housing scheme usually arrives as a short letter from an integrated care board with a spreadsheet attached, converting your unit mix into new patients and then into a capital sum for premises. It is a section 106 obligation like any other, so it has to satisfy regulation 122 of the Community Infrastructure Levy Regulations 2010. Plenty of these requests do not.
The weak point is almost never the arithmetic. It is the link between the money and a specific premises project that your residents would use.
Who asks, and on what basis
Since the Health and Care Act 2022, integrated care boards commission most local health services and hold the estates picture for primary care in their area. Requests may come from the board directly, from an estates team acting for it, or through the local planning authority as part of a consolidated infrastructure request.
The policy hook is national and local. The National Planning Policy Framework expects planning decisions to support healthy communities and to take account of the health infrastructure needed to serve new development, and most adopted local plans carry a developer contributions policy that names health among the infrastructure types.
That gets the request onto the table. It does not answer regulation 122.
Population growth and list size calculations
The standard method runs in four steps. Dwellings are multiplied by an average occupancy figure to give a new population. That population is multiplied by a registration rate to give additional patients on practice lists. The patients are converted into a floorspace requirement using a space standard per patient or per clinical room. The floorspace is costed using a build cost per square metre, plus fees and sometimes equipment.
Each step is checkable.
Occupancy is where the largest errors sit. Applying an all-dwellings average to a scheme of one-bedroom flats overstates the population, sometimes badly, and an age-restricted or student scheme has a different profile again. Ask which occupancy source is being used, from which census or household survey, and whether it varies by dwelling size.
Registration rates should reflect that some new residents are already registered locally. On a scheme in an established urban area, a proportion of buyers move from a few streets away and stay with the same practice, so they are not new patients at all. That point is rarely made and often accepted.
Where the scheme includes a specialist product, the tenure and unit mix set out in the Affordable Housing Statement is the document that supports the occupancy argument, so keep the two consistent.
The tests a health request has to satisfy
| Test in regulation 122 | The question to put to the health body |
|---|---|
| Necessary to make the development acceptable | Which named premises lack capacity, and what is the evidence of that shortfall? |
| Directly related to the development | Are those premises ones your residents would realistically register with? |
| Fairly and reasonably related in scale and kind | Does the contribution fund only the share attributable to your population? |
A request that names no project fails the first test. A request pointing to a practice on the far side of the district fails the second. A request calculated on the whole cost of a new health centre, with no apportionment between your scheme and existing unmet need, fails the third.
Ask for the board's estates strategy or infrastructure plan. Where one exists, it usually names the premises projects, their costs and their funding sources, and it will show whether your contribution is filling a gap or topping up a scheme already funded.
Where requests are refused as unrelated
Two arguments recur, and both are sound when the facts support them.
The first is that general practice funding is largely revenue rather than capital. Payments to practices under national contract arrangements follow registered patients, so a growing list brings growing income. A contribution towards running costs is not infrastructure and does not meet the tests. Capital contributions towards premises are a different matter, which is why requests should be framed around buildings.
The second is double counting. Where the charging authority collects the levy and its published spending priorities include health facilities, a section 106 contribution for the same facility is difficult to justify. Ask what the authority's infrastructure funding statement says about health spending before agreeing anything.
Neither argument means health contributions are never justified. Where a board can show a specific practice at capacity, a costed expansion project, and a shortfall attributable to your development, the request meets the tests and paying it is the sensible course.
Health impact assessment and its role
Some authorities, particularly in London, require a health impact assessment above a stated threshold. That is a different document from a contribution request, and it does a different job. It looks at how the scheme affects the determinants of health, including housing quality, access to open space, active travel, air quality and food environment.
A well-prepared Health Impact Assessment can strengthen your position on contributions, because it shows what the scheme itself provides. A development delivering walkable routes to an existing centre, play space and dual-aspect homes is answering part of the health question through design rather than through cash.
It also flags where a genuine need exists. Do not commission one expecting it to defeat every request.
Securing delivery rather than a payment
On larger schemes, providing the space is often better for everyone than paying for it. A shell unit for a practice, offered at a nominal rent under a long lease, delivers capacity on the site where the population is, and it removes the argument about apportionment.
The complications are real. A board has to want the location, the unit has to be the right size and configuration, and someone has to fit it out. Timing matters too, because a practice will not move into a building surrounded by construction.
Where in-kind delivery is on the table, get the health body into the design conversation early and record the arrangement in the heads of terms with a clear trigger and a fallback payment if the space is not taken up.
Questions to put before you agree
Five questions settle most of these discussions.
- Which premises are affected, and what are their current list sizes against capacity?
- What is the costed project the contribution would fund, and what else funds it?
- What occupancy and registration assumptions have been used, and from what source?
- Has any allowance been made for residents already registered locally?
- Does the authority's infrastructure funding statement already commit levy income to this project?
Run those alongside the other contribution requests rather than separately. Education, health, open space and transport requests usually arrive within weeks of each other, and the cumulative total is what tests the scheme. Where it does, the answer belongs in a Viability Assessment rather than in correspondence, and the wider supporting evidence base should be scoped so the whole package is argued once.
This is general guidance, not legal advice. Health body methodologies and local policy vary, so check the position with your local planning authority or a qualified professional before relying on it.
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Frequently asked questions
Who asks for health contributions on a planning application?
Integrated care boards commission most local health services following the Health and Care Act 2022, and requests usually come from a board or its estates team, sometimes routed through the local planning authority. The request is a proposed section 106 obligation, so it must satisfy regulation 122 of the Community Infrastructure Levy Regulations 2010 like any other.
Can a contribution fund running costs at a GP practice?
Generally no. Practice funding under national contract arrangements follows registered patients, so a growing list brings growing revenue. Planning obligations are for infrastructure, which in this context means premises. A request framed around a named, costed premises project is far more defensible than one framed around general pressure on services.
How is the population figure calculated?
Dwellings are multiplied by an average occupancy figure, then by a registration rate, to give additional patients. Ask which occupancy source is used and whether it varies by dwelling size, because applying an all-dwellings average to a block of one-bedroom flats overstates the population. Ask too what allowance is made for residents already registered locally.
What if the council already collects the levy for health facilities?
Then a section 106 contribution for the same facility is hard to justify, because regulation 122 requires the obligation to be necessary. Check the authority's annual infrastructure funding statement, which reports levy income and what it has been allocated to. Double counting between the two mechanisms is a common and legitimate objection.
Is providing space better than paying a contribution?
On larger schemes it often is. A shell unit let to a health body on a long lease at a nominal rent delivers capacity where the population is and removes the apportionment argument. It only works if the board wants the location, the unit suits clinical use and someone funds the fit-out, so agree a trigger and a fallback payment.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.