I am writing to confirm that I have now completed my search for the information which you requested.

Request

The NHS Business Services Authority (NHSBSA) received your request on 08/01/2026.

We have handled your request under the Freedom of Information Act 2000 (FOIA).

Our response

The NHSBSA does hold the requested information relating to the Urgent Dental Care Incentive (UDCI) scheme; however, we consider that this information is exempt from disclosure under section 22 of the FOIA. This provides an exemption from the duty to disclose information where the requested information is intended for future publication.

The Information Commissioner’s Office guidance states that “the public authority must, at the time of the request, hold the information and intend that it or ‘any other person’ will publish it in future. This means that it must have a ‘settled expectation that the information will be published at some future date’.”

The information is intended for future publication by the NHSBSA and NHS England from August 2026.

Section 22 is a class-based, qualified exemption and is subject to the public interest test. This means that not only does the information have to prejudice one of the purposes listed, but before the information can be withheld, the public interest in preventing that prejudice must outweigh the public interest in disclosure.

Considerations for disclosure:

• Inherent public interest in openness, transparency and accountability of public authority dealings and use of public funds
• Transparency in relation to the UCDI scheme
• Increased public understanding of the UCDI scheme

Considerations against disclosure:

• The UCDI scheme runs from September 2025 to end March 2026. The scheme is therefore still ongoing and data is not currently complete for the duration of the scheme.
• Publishing data from September to November will only give a partial picture of delivery against the scheme and not accurately reflect contractors who join or leave the scheme and therefore the associated scheme costs.
• Data will be incomplete and subject to revision until year end activities. Putting unverified data into the public domain prior to planned publication could create confusion and lead to misinterpretation or misrepresentation of the data.
• There is an inherent public interest in not disclosing information which could be misleading to the public and may not accurately reflect the scale and cost of the scheme.
• The information is intended for future publication once finalised.

Conclusion:
We consider that the advantage to releasing this information now (rather than upon the planned publication) is outweighed by the potential prejudice to the completeness and consistency of the data provided.

Please see the following link to view section 22 in full — https://www.legislation.gov.uk/ukpga/2000/36/section/22//www.legislation.gov.uk/ukpga/2000/36/section/22