FOI 2026/1557

Under the Freedom of Information Act 2000, I am requesting information regarding the financial flows and contractual arrangements between the ICB and it’s commissioned NHS Trusts for the provision of medical retina services, specifically concerning anti-VEGF (Vascular Endothelial Growth Factor) medicines [Appendix A].

Please provide answers to the following questions for each NHS Trust provider of Medical Retina services that the ICB commissions. Please provide the information electronically in Excel spreadsheet format, specifying the named NHS Trust for each set of answers.

1. Contractual Structure

1. Are anti-VEGF drug costs currently reimbursed to the Trust via:
   •  A pass-through mechanism (cost-and volume)?
   •  A fixed block contract (inclusive of drug spend)?
   •  An Aligned Incentive Contract (AIC) or “Blended Payment” model?
2. If a blended/AIC model is used, what is the specific split between the fixed element and the variable (volume-based) element for high-cost anti-VEGF drugs?

2. Efficiency and Savings Incentives

1. Is there a formal Gain-Share Agreement in place between the ICB and the Trust regarding the use of biosimilar anti-VEGF agents?
2. If yes, what percentage of the saving is retained by the Trust vs. the ICB, is there a cap on total savings a provider can retain, and is the gainshare for new patients only?

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3. Funding flows in 2026/27

• Are announced ICB arrangements for merger/cluster/split from April 2026 changing the anti-VEGF funding contractual structure and/or gain-share agreement with the Trust, and if so how?
• What is the NHSE-recommended reference price for anti-VEGF drugs in your region, and is the ICB implementing this reference price with the Trust from April 2026?

Appendix A: Medical Retina Drugs Covered by this Request

Please include data for the following agents in your response: Alfibercept, Ranibizumab, Faricimab, Bevacizumab, Brolucizumab.

1. Contractual Structure

1a. Where the drugs are national tariff exclusions, then these are funded as pass through.

1b. Not a blended model

2. Efficiency and Savings Incentives

2a NHS Greater Manchester (NHS GM) High Cost NHSPS-Excluded Drugs

Gainshare Policy is publicly available on Greater Manchester Medicines Management Group (GMMMG) website. The policy sets out the framework for the gainshare arrangements, however, each scheme is decided on case-by-case basis. In line with section 16 of the Freedom of Information Act please find below a link to the website to assist you.

You searched for gainshare – GMMMG

2b. Please refer to the policy via the link provided in the response above.

3. Funding flows in 2026/27

3a. There are no announced NHS GM arrangements for merger/cluster/split from April 2026 for Greater Manchester.

3b. NHS GM does hold the information requested; however, the information is exempt from disclosure under section 43(2) Commercial Sensitive of the Freedom of Information Act. In addition, the disclosure of would constitute an actionable breach of confidence and are therefore exempt under section 41(1)(a)(b) Information Provided in Confidence,

Section 41(1)(a)(b) Information Provided in Confidence

This exemption applies to information which has been provided in confidence. The Act requires that:

• The information must be obtained by the public authority from another person (outside of NHS GM) and.

• Disclosure of the information to the public would constitute a breach of confidence, actionable by that person.

The conditions for an actionable breach of confidence to be established would require that the information has a ‘quality’ of confidence (i.e. it is confidential in nature and not widely known) and that it has been imparted in circumstances that suggest there is a ‘obligation’ of confidence upon the receiver, or an expectation given to the provider of that information that it would be treated as confidential.

Section 43(2) of the Freedom of Information Act 2000 states:

“Information is exempt information if its disclosure under this Act would, or would be likely to, prejudice the commercial interests of any person (including the public authority holding it)”.

Factors favouring disclosure.

There is an inherent public interest in ensuring that there is openness and transparency in the spending of public money. Transparency is likely to increase confidence in procurement processes and the purchasing decisions made by NHS GM. It also enables the public to understand whether NHS GM is getting value for money from its purchasing decisions.

Factors favouring non-disclosure.

However, we believe that disclosure of the requested information would prejudice the current or future negotiating capabilities of NHS GM. Disclosure of this information would be likely to prejudice the commercial interests of the providers and the negotiating capabilities of NHS GM, particularly in relation to future negotiation and value-for-money considerations. Additionally, the reference prices are commercially sensitive information from overall NHS and national perspective.

Balancing Test.

After considering the arguments outlined above, we have decided to withhold this information.