The CHC Annual Review: What Can Change & How to Protect It

Every year, an NHS assessor sits down with a person's care records and asks the same question the original assessment asked: does this person still have a primary health need?

The answer determines whether a family continues to receive fully-funded NHS care — or faces bills of up to £1,300 a week. In Q2 2025/26, the answer was "no longer eligible" for 28,362 people (NHS Digital, November 2025). That number has risen from around 25,119 per quarter in 2021/22. The annual review is not a formality. It's a real decision with real consequences.

Learn what CHC funding covers and who qualifies

TL;DR: The National Framework 2022 requires a 3-month review, annual reviews, and a review on significant change. NHS Digital data shows 28,362 people were found no longer eligible in Q2 2025/26 — a figure that has grown year-on-year. Families who attend reviews with domain-mapped evidence, written submissions, and a named advocate are better placed to maintain eligibility. If funding is removed, 13% of local resolution disputes result in restored eligibility.

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What Triggers an NHS CHC Review?

The National Framework for NHS Continuing Healthcare (2022) specifies three types of mandatory review. Knowing which applies to your situation is the first step to being prepared.

The 3-month review happens within the first three months of a person starting CHC. It exists because a newly eligible person's needs may stabilise after an acute episode — their situation at month one may not reflect long-term need. This review tends to be lower-stakes than subsequent ones, but it can result in funding being removed if recovery has been significant.

The annual review is a full reassessment, typically scheduled around the anniversary of eligibility. The assessor revisits every domain of the Decision Support Tool and reaches a fresh conclusion about whether a primary health need still exists. Nothing from the original assessment is carried forward automatically. The mechanics of how this assessment plays out in practice are covered in our CHC MDT assessment process guide — the procedural steps that an annual review and a first-time assessment share.

The significant change review is triggered by a material change in health, care setting, or personal circumstances. Hospital admissions, a new diagnosis, a move to a different care home, or a change in the care package can all prompt this review. Families can also request one proactively — a right that's especially useful when a person's needs have worsened and the current assessment no longer reflects reality.

The 2022 Framework also closed a loophole previously used to avoid reviews for Fast Track patients. Before the update, some ICBs delayed reviews for people on Fast Track (the terminal illness pathway) indefinitely. The 2022 guidance is explicit: Fast Track packages must also be periodically reviewed, though the timing is sensitive to the person's clinical situation.

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What Actually Happens During a CHC Annual Review?

An annual review follows a structured process, but the experience varies considerably between ICBs.

In most cases, the ICB will write to the family several weeks before the review date. The letter confirms when and where the review will take place, who will attend, and what information the family can submit. In-person reviews at the care home are common, but remote reviews by phone or video became more prevalent after 2020 and haven't disappeared. Either way, the family has the right to attend — and should.

The assessor — usually a nurse or social care professional — reviews the person's care records from the past 12 months, speaks with care home staff, and completes a fresh Decision Support Tool. Each of the 12 domains is scored. If four or more domains score Moderate, or if any domain scores High or Severe, a Primary Health Need is more likely to be found. But those thresholds are indicative, not binding — the assessor's professional judgment matters.

The family's role isn't passive. You can submit written evidence in advance, attend the meeting, and challenge any domain scoring you disagree with on the day. What you say at the review — and how well it is evidenced — directly affects the outcome.

After the review, the ICB reaches a decision, which should be communicated in writing. If eligibility is maintained, the care package may be adjusted to reflect current needs. If eligibility is removed, the ICB must give reasons, explain the funding transition plan, and set out the dispute process.

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Can CHC Funding Be Removed at an Annual Review?

Yes — and it happens at scale. NHS Digital data for Q2 2025/26 shows 28,362 people across England were found no longer eligible for CHC during that period alone. The quarterly "no longer eligible" figure has risen from approximately 25,119 in 2021/22 to 28,196 in 2024/25 (NHS Digital).

Quarterly NHS CHC "no longer eligible" figures — NHS Digital, 2021–2026 (avg/quarter where annual data used)

There are two main reasons funding is removed. The first is genuine clinical improvement — a person has recovered from an acute episode, their condition has stabilised, and their care needs are now within what local authority social care can meet. This is legitimate and expected.

The second is more controversial: funding removal despite no material change in health. The Nuffield Trust's "All or Nothing" report (September 2025) identified that ICBs under financial pressure tend to apply the eligibility threshold more conservatively — meaning the same clinical profile can result in different outcomes depending on which ICB reviews the case, and in which year.

Don't assume deterioration protects you. The review looks at all 12 domains, not just the ones that have changed.

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How to Prepare Evidence for a CHC Review

Preparation is the single most controllable factor in a review outcome. Families who submit detailed, domain-specific evidence before the review are better positioned than those who rely on the assessor's interpretation of the care home records alone.

Start at least four weeks before the review date.

Gather records from the past 12 months

Request the following:

• Daily care notes from the care home — ask for 12 months, not a summary
• GP letters and clinical correspondence — any hospital admissions, specialist referrals, or significant assessments
• Hospital discharge summaries — these carry weight because they are written by clinicians rather than care workers
• Medication administration records (MARs) — changes in medication, frequency of PRN (as-needed) medication, and new prescriptions all indicate changing need
• Risk assessment documents — MUST, Waterlow, falls risk — anything showing nursing-level risk

Map evidence to the 12 domains

The 12 DST domains — Behaviour, Cognition, Communication, Psychological/Emotional, Mobility, Nutrition, Continence, Skin (including tissue viability), Breathing, Drug Therapies, Altered States of Consciousness, and Other significant care needs — each need to be addressed individually.

For each domain, identify specific, dated examples from the records that demonstrate the severity of need. "She has dementia" is a diagnosis. "On 14 March, she required physical redirection four times during personal care due to distress and resistance, lasting 25–30 minutes each time" is evidence.

Write a family evidence submission

A written submission, submitted to the ICB assessor at least five working days before the review, does several things. It forces the assessor to read your account alongside the care records. It creates a paper trail. And it signals that the family is engaged and will challenge inaccuracies.

The submission should:

1. State the person's current health condition and its trajectory
2. Walk through each domain with specific evidence
3. Highlight any domains where the person's needs have increased since the last assessment
4. Note any domains where well-managed needs might be underscored (if someone's pain is controlled with regular morphine, that's a High need — not a No need)

The "well-managed needs" principle is important. The National Framework is explicit: if a need is only being met because of intensive intervention (nursing care, specialist medication, behaviour management), the need exists at the unmanaged level — not the managed level. We've covered this in depth in our guide to well-managed needs in CHC, including the exact paragraphs 162–166 wording to cite in a written challenge.

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What to Do If CHC Funding Is Reduced or Removed

If the review results in reduced or removed funding, the ICB must inform you in writing with reasons. The letter will usually set out a funding transition timeline — typically 28 days before the funding stops. Don't let that timeline pressure you into accepting the decision.

Step 1: Request the full Decision Support Tool

You're entitled to a copy of the completed DST — the document that shows how each domain was scored and why. Request it within 10 working days. When you receive it, compare the scoring against your own evidence submission. Look for domains where the assessor has scored lower than the evidence supports, and for any domain where a well-managed need appears to have been scored at the managed level rather than the underlying level.

Step 2: Submit a formal dispute

The ICB must have a local dispute resolution process. You have up to three months to submit a dispute, but act quickly — memories fade and records can become harder to obtain. The dispute should reference specific domain scores, cite specific evidence, and explain why the assessor's scoring is inconsistent with the National Framework.

NHS Digital data shows that 13% of local resolution disputes result in restored eligibility (Q4 2023/24). That's not a high rate — but it represents thousands of families per year who successfully overturn a removal decision. The families who succeed are almost always those who engage in writing with specific evidence, not those who simply say they disagree.

Step 3: Escalate if local resolution fails

If local dispute resolution doesn't restore eligibility, you can escalate to the ICB's Independent Review Panel (IRP). The IRP is independent of the front-line decision and can overturn the local decision. If the IRP also fails to resolve the dispute, the Parliamentary and Health Service Ombudsman (PHSO) can investigate.

For retrospective cases — where you believe your relative should have been eligible for a period in the past — a retrospective CHC claim is also available. Claims can be made for periods back to April 2012 in some circumstances.

Read the full CHC appeals guide

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The Review Process and ICB Financial Pressure

Something families should know: the system doesn't operate in a vacuum.

The Nuffield Trust found that CHC spending rose 17% between 2017 and 2023, while the number of recipients fell 8.8%. That means the NHS is spending more on fewer people — and the threshold for qualifying is, in practice, rising. ADASS Spring Survey 2025 found that 75% of adult social care directors reported an increase in people being displaced from CHC into local authority social care — meaning the NHS is shifting costs, not managing fewer needs. We've covered the ICB-side mechanism in our ICB CHC eligibility cuts analysis, and the family-side impact in our CHC council cost-shifting guide.

For families, this matters because it explains why "your relative hasn't changed, but the outcome has." The National Framework criteria haven't changed. The way they're applied under budget pressure has.

That's not a reason to despair. It's a reason to engage. The National Framework is a legal document. ICBs that remove funding without proper justification are open to challenge through the dispute process, the Ombudsman, and in extreme cases, judicial review. Nuffield Trust's research shows that families who understand their legal rights achieve meaningfully different outcomes from those who don't.

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Your Rights at Every Stage of the Review

The review process comes with specific protections that many families aren't aware of:

• Right to attend: You and the person being assessed have the right to be present at the review. The ICB cannot conduct a review without giving you reasonable notice and an opportunity to participate.
• Right to submit evidence: Written evidence submitted in advance must be considered by the assessor. It cannot be ignored.
• Right to written reasons: Any decision to remove or reduce funding must be explained in writing, with reasons.
• Right to dispute: You have up to three months to formally dispute any CHC decision, including a review-based removal.
• Right to a copy of the DST: You are entitled to the full completed Decision Support Tool, not just a summary letter.
• Right to advocacy support: You can bring a professional advocate, a family member, or a friend to attend the review with you.

These rights apply whether the review is a 3-month, annual, or significant change review. They also apply regardless of which ICB covers your area.

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A Note on Fast Track and End-of-Life Reviews

For people receiving Fast Track CHC — usually people expected to live fewer than six months — the review process is handled differently. Fast Track is designed to provide urgent, unconditional funding without the normal DST process. The 2022 National Framework update requires periodic review of Fast Track cases, but the guidance is sensitive to clinical reality: a review that might remove funding from someone in their final weeks is handled with discretion.

If your relative is on Fast Track and facing a review, the principle is the same: gather clinical evidence, attend, and submit in writing. But the bar for removal at Fast Track is higher — the clinical threshold is different from standard CHC.

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Summary: CHC Annual Review Checklist

Before the review:

• Request 12 months of care home daily notes, MARs, GP letters, hospital discharge summaries
• Map evidence to each of the 12 DST domains with specific, dated examples
• Write and submit a formal family evidence submission at least 5 working days in advance
• Confirm your right to attend in writing

At the review:

• Attend with a named family advocate
• Ask the assessor to explain their domain scoring as they go
• Challenge well-managed needs scoring in real time if possible
• Request a copy of the completed DST before you leave (or within 10 days)

After a removal decision:

• Request the full DST in writing within 10 working days
• Submit a formal dispute within 3 months with specific domain-level evidence
• Escalate to IRP if local resolution fails
• Consider a retrospective claim if historic periods are in question

The review process is more manageable when you treat it as a structured evidence exercise rather than a conversation. The same logic that wins a first-time CHC assessment wins a review dispute. Start with the evidence. Build the case. Put it in writing.