FOI 2026/1668

I am writing to request information under the Freedom of Information Act 2000 (FOIA) regarding NHS funding frameworks, Individual Funding Requests (IFRs), and Prior Approval pathways for the specialist assessment and treatment of complex trauma and dissociative disorders.

Clarification regarding Section 21 (Information Accessible by Other Means):

For Part 1, I am requesting direct “Yes/No” answers to factual questions regarding your internal clinical commissioning processes. Because the application of generic mental health policies to specific complex conditions is rarely explicit in published documents, providing direct Yes/No answers will satisfy this request without requiring document retrieval or website redirection.

Manchester locality:

Part 1: Clinical Decision-Making Frameworks

Please provide a “Yes” or “No” answer to the following four questions regarding how the ICB assesses funding for Dissociative Identity Disorder (DID) and other dissociative conditions:

1. Does the ICB hold a written policy, clinical pathway, or bespoke criteria specifically tailored for assessing funding requests for dissociative disorders? (Yes/No)
2. If no, are funding requests for dissociative disorders evaluated solely against the ICB’s generic IFR “clinical exceptionality” policy? (Yes/No)
3. When evaluating funding requests for dissociative disorders, does the ICB explicitly require clinical input or panel representation from a specialist with formal expertise in complex trauma and dissociation? (Yes/No)
4. When evaluating funding requests for dissociative disorders, does the ICB apply a specific clinical effectiveness and/or cost-effectiveness criterion to the decision? (Yes/No)
5. Does the ICB explicitly classify specialist treatments for dissociative disorders as a “Low Priority” treatment, or include them within a “Procedures of Limited Clinical Value” (PLCV) or “Not Routinely Commissioned” policy list? (Yes/No)
6. Does the ICB currently hold a block contract or formal commissioning arrangement with a local NHS mental health trust that specifically includes a dedicated, specialist diagnostic and treatment pathway for Dissociative Identity Disorder (DID)? (Yes/No)

Part 2: IFR Statistics & Specialist Provider Approvals (1 July 2022 – 31 December 2025) Section 11 (Format of Disclosure):

Under Section 11(1) of the FOIA, I formally request that this data be provided in an electronic spreadsheet format (.xlsx or .csv). As established by the Court of Appeal (Innes v Information Commissioner), providing tabular data in an un-editable PDF when a spreadsheet is requested does not satisfy Section 11 obligations.

Please provide the following data fields, structured with separate columns for the following years:

• 2022 (1 July 2022 to 31 December 2022)
• 2023 (1 January 2023 to 31 December 2023)
• 2024 (1 January 2024 to 31 December 2024)
• 2025 (1 January 2025 to 31 December 2025)

Assessment and Treatment Data:

7. Total number of IFR/Prior Approval requests received for specialist dissociative disorder assessments.
8. Total number of these assessment requests approved.
9. Total number of IFR/Prior Approval requests received for specialist dissociative disorder treatments.
10. Total number of these treatment requests approved.

Funded Specialist Providers:


11. Of the approved treatment requests identified in Question 8, please provide a numerical breakdown of how many were funded for the following specialist independent clinics and NHS services:

• Clinic for Dissociative Studies (CDS)
• CTAD Clinic / Cheshire Psychology –
• The Pottergate Centre
• South London and Maudsley (SLaM) Trauma and Dissociation Service (TDS)
• Other external/independent providers (grouped total)

Further Data:

12. Total combined number of IFR/Prior Approval requests received across ALL medical and mental health conditions.
13. Total combined number of IFR/Prior Approval requests approved across ALL medical and mental health conditions.

Further clarification regarding questions 12 & 13:

My apologies for the poor wording. These questions relate to all conditions (no specificity). The sum of all IFR/Prior Approval requests.

An inference was made that the data may be held separately. To clarify, I am seeking all requests, ideally in one central spreadsheet that hosts all this data.

PLEASE NOTE the following information:

ADDITIONAL INFORMATION – Please note that, in reference to the following paragraph, I have provided an important update that further clarifies my request:

‘Section 12 (Cost Limit): For questions 10 and 11, please provide the top-level aggregate figures exactly as they are recorded in your central reporting system. There is no need to manually review files to separate “IFRs” from standard “Prior Approvals.” If compiling any single data point still exceeds the Section 12 cost limit, please omit only that specific data field and provide the remaining information in the requested spreadsheet format, in accordance with your Section 16 duty to provide advice and assistance.’

UPDATE: An additional two questions were added after the creation of “Section 12 (Cost Limit)”. They currently say ‘For questions 10 and 11’. To correct my mistake, this ought to say ‘question 12 and question 13’. My apologies for that error. Please refer to questions 12 and 13 when reading that paragraph. Thank you.

Guidance for Processing and Statutory Exemptions:

• Section 40(2) (Personal Data): If any exact figure in Part 2 falls between 1 and 4, and you believe disclosure risks identifying a patient, please apply standard statistical disclosure control by using the symbol “<5” for that specific cell. Do not refuse the wider request.
• Section 12 (Cost Limit): For questions 10 and 11, please provide the top-level aggregate figures exactly as they are recorded in your central reporting system. There is no need to manually review files to separate “IFRs” from standard “Prior Approvals.” If compiling any single data point still exceeds the Section 12 cost limit, please omit only that specific data field and provide the remaining information in the requested spreadsheet format, in accordance with your Section 16 duty to provide advice and assistance.

Part 1: Clinical Decision-Making Frameworks

1. No, NHS Greater Manchester (NHS GM) does not hold a written policy, clinical pathway, or bespoke criteria specifically tailored for assessing funding requests for dissociative disorders
2. No, funding requests for dissociative disorders evaluated solely against NHS GMs generic IFR “clinical exceptionality” policy. There are no current guidelines in place to support decision making, and each locality has their own model for how these are reviewed. This normally takes the form of a clinical panel that reviews the information, comparing clinical need to commissioned services, with clear local governance guidelines to guide decision making
3. No, NHS GM does not explicitly require clinical input or panel representation from a specialist with formal expertise in complex trauma and dissociation
4. No, NHS GM does not apply a specific clinical effectiveness and/or cost-effectiveness criterion to the decision

5.No, NHS GM does not explicitly classify specialist treatments for dissociative disorders as a “Low Priority” treatment, or include them within a “Procedures of Limited Clinical Value” (PLCV) or “Not Routinely Commissioned” policy list

6.No, NHS GM does not currently hold a block contract or formal commissioning arrangement with a local NHS mental health trust that specifically includes a dedicated, specialist diagnostic and treatment pathway for Dissociative Identity Disorder (DID)?

Part 2: IFR Statistics & Specialist Provider Approvals (1 July 2022 – 31 December 2025) Section 11 (Format of Disclosure):

Under the Freedom of Information Act 2000 (FOIA), this section of your request is exempt by virtue of the following exemption, Section 12(1). Section 12. — (1) Section 12(1) does not oblige a public authority to comply with a request for information if the authority estimates that the cost of complying with the request would exceed the appropriate limit.

The Freedom of Information Act allows Public Authorities to decline to answer FOI requests when we estimate it would cost us more than £450 (equivalent to 18 hours, calculated at £25 per hour) to identify, locate, extract, and then provide the information that has been asked for.

NHS GM consists of the 10 Greater Manchester localities, Bolton, Bury, Heywood, Middleton and Rochdale, Manchester, Oldham, Salford, Stockport, Tameside, Trafford and Wigan (former Clinical Commissioning Groups), and as such information is held on various data bases over the 10 localities.

The scope of the request has been carefully considered. The work would involve reviewing records across approximately ten localities over multiple years, drawing on a combination of digital and analogue sources. For digital records, there is no automated coding or searchable field available to extract the required information, meaning each record would need to be individually accessed, read, and interpreted; the same manual approach would also apply to analogue records. This process would need to be replicated across all ten localities, significantly increasing the overall time required.

Based on a more detailed assessment, with each record taking approximately 12–15 minutes to locate, review, and extract the relevant information, reviewing in the region of 55–60 records per locality (approximately 550–600 records in total) would result in an estimated time of around 72 hours of work. This is approximately four times the statutory cost limit set under Section 12 of the Freedom of Information Act 2000 (£450, equivalent to 18 hours at £25 per hour). As such, it would not be feasible to complete the request within the cost limit.

On this basis, section 12 has been applied to the request for data for the years prior to 2025/26 as this would exceed the appropriate limit prescribed in the act.

Assessment and Treatment Data 2025/26:

7. – 13.

**An excel document was sent to the requester with this response.  If you require a copy of the full response, together with the attachments, please contact NHS GM’s FOI team – nhsgm.foi@nhs.net **

12 & 13 As explained above in the response above NHS GM consists of the 10 Greater Manchester localities, Bolton, Bury, Heywood, Middleton and Rochdale, Manchester, Oldham, Salford, Stockport, Tameside, Trafford and Wigan (former Clinical Commissioning Groups), and as such information relating to Mental Health IFRs is held on various data bases over the 10 localities.

Under the Freedom of Information Act 2000 (FOIA), this section of your request is exempt by virtue of the following exemption, Section 12(1). Section 12. — (1) Section 12(1) does not oblige a public authority to comply with a request for information if the authority estimates that the cost of complying with the request would exceed the appropriate limit.

The Freedom of Information Act allows Public Authorities to decline to answer FOI requests when we estimate it would cost us more than £450 (equivalent to 18 hours, calculated at £25 per hour) to identify, locate, extract, and then provide the information that has been asked for.

This is because the data relating to Mental Health IFR cases, unlike physical health IFR cases is not held in a single, consistent format across systems. There is no common coding applied that would allow these records to be easily identified and extracted through an automated search. In some systems, relevant information is recorded manually in free text, while in others it is stored digitally but without standardised classification

In addition, there are complexities in determining which cases fall within scope. Distinctions between Individual Funding Requests (IFR), Exceptionality (EUR), complex care packages, and placement-funded packages are not consistently or explicitly recorded. As a result, each record would need to be reviewed individually to determine whether it meets the criteria of the request.

To locate the information requested it is estimated that each record taking approximately 2-5 minutes to locate, review, and extract the relevant information, reviewing in the region of 50–100 records per locality (approximately 500–1000 records in total) exceeding the statutory cost limit set under Section 12 of the Freedom of Information Act 2000 (£450, equivalent to 18 hours at £25 per hour). As such, it would not be feasible to complete the request within the cost limit.

On this basis, section 12 has been applied to the request for the total Mental Health IFR cases as this would exceed the appropriate limit prescribed in the act.

In line with section 16, the data for medical IFR cases has been provided to assist you.