Thank you for your request for information.

Request

‘Dear NHS Business Services Authority, Under the Freedom of Information Act 2000, I would like to request the following information: Since the introduction of the Immigration Health Surcharge (IHS) reimbursement scheme in March 2020:

1. How many applications or appeals for IHS reimbursement have been approved where the applicant was not directly employed by an NHS body, but by another organisation such as a local authority, education provider, or social care provider?

2. Of these approved cases, how many were determined primarily on the basis of evidence of the applicant’s direct health or social care duties (for example, personal care, medication support, safeguarding, or community-based care) and/or the employer’s eligibility, rather than their specific job title or occupational classification?

3. How many successful applicants have been employed in educational settings, including schools or special needs schools, where care duties formed an essential part of the role (e.g., providing personal care, medication administration, or behavioural and safeguarding support)?

4. More generally, how many applicants who were not directly employed within a health or social care organisation have been reimbursed under the IHS reimbursement scheme?

5. Please also provide any internal guidance, policy notes, or assessment criteria used by NHSBSA staff to determine whether an applicant’s duties and employer qualify as working in a “relevant health or social care context.”

Please provide the information in aggregated and anonymised form.’

Response

Questions 1, 2 and 4

The NHSBSA does hold the requested information; however, we estimate that the cost of compliance with the request would exceed the appropriate limit under section 12 of the FOIA.

We estimate that the cost of complying with your request would exceed the non-central Government limit of £450. The limit has been specified in The Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004 and represents the estimated cost of one person spending 18 hours in determining whether the NHSBSA holds the information, and locating, retrieving, extracting and checking the information.

Although the employer name is captured during the reimbursement application process, it is entered as free text. As a result, the data is not standardised or categorised and would therefore require manual interrogation.

There have been 328,074, Health & Care IHS reimbursement claims approved since March 2020. We estimate this would take us 27,339.5 hours to manually interrogate this amount of records.

All applications are assessed individually in line of Annex A: eligibility criteria, Immigration health surcharge: guidance for health and care reimbursements - GOV.UK. Please note that Annex A: eligibility criteria specifies: The applicant will be employed to provide or to support the provision of, regulated activities as prescribed in Schedule 1 (read with Schedule 2) to the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (S.I. 2014/2936), and who is also employed or engaged by an institution or organisation registered with the Care Quality Commission.

Question 3

I am writing to advise you that following a search of our paper and electronic records, I have established that the information you requested is not held by the NHSBSA.

We are unable to provide data in response to this question as care duties is not captured as a specific field as part of the application process. All applications are assessed against Annex A: eligibility criteria, Immigration health surcharge: guidance for health and care reimbursements - GOV.UK.

Question 5

Under Section 21 of the FOIA we are not required to provide information in response to a request if it is already reasonably accessible to you.

The information you requested is available at the following link:

https://opendata.nhsbsa.net/dataset/foi-03159

Please be advised that this guidance reflects the information that is publicly available on the GOV.UK website outlined above and the NHSBSA Knowledge Base website which can be accessed here: https://faq.nhsbsa.nhs.uk/knowledgebase/category/?articlecategory=Immigration%20health%20surcharge%20%28IHS%29&id=CAT-05789&parentid= This is due to NHSBSA processes being governed by the information provided within the GOV.UK guidance.

Please see the following link to view the section 21 in full - https://www.legislation.gov.uk/ukpga/2000/36/section/21

Data Queries

Please contact foirequests@nhsbsa.nhs.uk ensuring you quote the above reference if you have any specific questions regarding this response; or, if you feel you may be misunderstanding or misinterpreting the information; or, if you plan on publishing the data. Reusing the data and copyright

If you plan on producing a press or broadcast story based upon the data please contact communicationsteam@nhsbsa.nhs.uk. This is important to ensure that the figures are not misunderstood or misrepresented.

The information supplied to you continues to be protected by the Copyright, Designs and Patents Act 1988 and is subject to NHSBSA copyright. This information is licenced under the terms of the Open Government Licence detailed at: http://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/

Should you wish to re-use the information you must include the following statement: “NHSBSA Copyright 2025” This information is licenced under the terms of the Open Government Licence:

http://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/

Failure to do so is a breach of the terms of the licence.

Information you receive which is not subject to NHSBSA Copyright continues to be protected by the copyright of the person, or organisation, from which the information originated. Please obtain their permission before reproducing any third party (non NHSBSA Copyright) information.