Continuing Healthcare Funding 2026: The Family Guide

CT
CareAdvocate Team·Article·2026-05-13·22 min read
Reviewed by legal professionals and social care professionals
An elderly couple reviewing bills and care paperwork at home — the financial decision every family faces when researching how NHS Continuing Healthcare funding actually works in 2026.

Key Facts

  • The NHS spent £6.5 billion on Continuing Healthcare in 2023-24 (Commons Library, 2024)
  • 52,096 people were eligible for CHC at 31 March 2024 — 34,055 Standard Pathway, 18,041 Fast Track (Nuffield Trust, June 2024)
  • Average CHC spend per recipient: £65,012 per year — varying from £47,300 (most-deprived ICBs) to £95,085 (least-deprived) (Nuffield Trust, 2024)
  • Top-up fees are unlawful under CHC — the ICB must pay the full assessed care cost (nhs.uk, April 2024)
  • 25,402 CHC-eligible adults have a Personal Health Budget in Q3 2025-26 (NHS England Digital, 2025)
  • Retrospective claims under PUPoC recover fees back to 1 April 2012 (gov.uk, March 2025)
  • The £86,000 care cap was cancelled in July 2024 — self-funding has no upper limit (Community Care, 2024)

The NHS spent £6.5 billion on Continuing Healthcare in 2023-24 (Commons Library, 2024). 52,096 people were receiving it at the end of March 2024 (Nuffield Trust, June 2024). And yet the national eligibility rate at full assessment is now just 17% — down from 31% in 2017-18 (Healthwatch England, October 2025). The gap between the system's published scale and the families it actually serves is the story of CHC funding in 2026.

Most families never encounter CHC until they're six months into self-funding care. By then, the funding has been paid out of capital that the NHS — if asked correctly — would have covered. This guide explains how the money actually flows. What CHC pays. What it doesn't. How to recover what should have been paid since 2012. And the four delivery routes the NHS uses to get the funding to the family.

Reviewed by legal professionals and social care professionals.

TL;DR: NHS Continuing Healthcare pays 100% of care costs for adults with a primary health need — no means test, no upper cap. National budget £6.5bn in 2023-24 (Commons Library, 2024), serving 52,096 eligible at March 2024. Top-ups are unlawful (nhs.uk, 2024). PUPoC retrospective claims recover fees back to 1 April 2012. The £86,000 care cap was cancelled in July 2024 — self-funding has no upper limit.


What is Continuing Healthcare funding in 2026?

NHS Continuing Healthcare funding is the only NHS funding route that pays for all of a person's care — accommodation, personal care, nursing, equipment — when their needs meet the primary health need test. It is not means-tested, has no upper cost cap, and is paid by Integrated Care Boards under section 1 of the NHS Act 2006 (the NHS's comprehensive duty).

The legal architecture has two pillars. The NHS's duty to provide comprehensive health services sits in the NHS Act 2006. The local authority's social-care duty sits in the Care Act 2014. Where the boundary falls between the two is decided by the primary health need test — set by the Court of Appeal in R v North & East Devon HA, ex parte Coughlan [1999] EWCA Civ 1871 and codified in section 22 of the Care Act 2014. Above the line, the NHS pays. Below it, the local authority pays — and means-testing applies. For the deeper legal framework, see our primary health need legal test guide.

Since 1 July 2022, the body that decides and pays CHC is the Integrated Care Board (ICB) in each area. ICBs replaced Clinical Commissioning Groups (CCGs) under the Health and Care Act 2022, but the eligibility test — and the funding architecture — didn't change. The 2022 National Framework set the operational rules ICBs apply (DHSC). See our deeper guide to what the criteria actually require and to who qualifies for CHC funding.

The scale matters. £6.5 billion of NHS spending. 52,096 people eligible at the end of March 2024 — 34,055 on the Standard Pathway, 18,041 on Fast Track. The total eligible fell slightly to 51,582 at the end of March 2025 (NHS England, Q4 2024-25). This is not a marginal funding route. It's a major NHS programme — but one where most affected families never reach the door.


How CHC funding is paid — the four delivery models

CHC funding reaches the recipient through four mechanisms: direct ICB payment to a care provider (the default), Personal Health Budgets for home-based recipients, Direct Payments (delivered as one mode of a PHB), and joint packages that combine CHC and local authority funding for mixed-need cases. The mechanism shapes what families can control and what they cannot.

Direct ICB payment to a care provider

This is the default model. The ICB contracts directly with the care home or domiciliary care agency and pays the assessed weekly rate. The family sees no invoice. The provider sees no top-up gap.

The legal rule on top-ups is unambiguous. NHS guidance states plainly: "it is not possible to top up NHS continuing healthcare packages" (nhs.uk, April 2024). The ICB pays the full assessed care cost. Care homes that ask families to "top up" because the home's self-funder rate is higher than the ICB-contracted rate are operating outside CHC rules.

There's one lawful alternative families should know. A privately purchased additional service — different staff, different time, separately invoiced, not part of the assessed care plan — is permitted. A top-up on the same care package is not. The distinction is whether the extra payment buys something genuinely additional, or just covers a rate gap on the same care.

Personal Health Budgets (PHBs)

Everyone living at home on CHC has a "right to have" a Personal Health Budget unless exceptional circumstances apply (NHS England). PHBs let recipients arrange their own care — choosing providers, scheduling visits, and in some cases hiring carers directly.

In Q3 2025-26, 25,402 CHC-eligible adults had a PHB (NHS England Digital). PHBs come in three flavours: notional (the NHS arranges and pays for the care — about 79% of cases), direct payment (the individual receives payment to buy care and support — around 18%), and third-party (another organisation receives the payment and arranges the care — about 3%).

Why PHBs matter financially. Local authority homecare is commissioned at around £24.10 per hour — well below the £32.14 per hour minimum sustainable rate identified by the Homecare Association (Community Care, June 2025). A PHB lets CHC-funded care be commissioned at the true market rate. The cap that limits social-care choice doesn't apply.

Joint packages of care

Some needs straddle health and social care cleanly enough that one body shouldn't fund all of it. The 2022 National Framework provides a 24/48-hour analysis method for these cases — classifying the person's needs as (a) clearly health-led, (b) cross-cutting, or (c) clearly social-care-led, then proportionally allocating cost.

Means-testing implications follow the split. The social-care portion is means-tested under the Care Act 2014. The CHC portion is not. Families with mixed needs often discover their relative qualifies for a joint package even where full CHC was refused — and the joint route still removes the largest chunk of the means-tested liability.

How payment timing works

CHC pays from the date the decision takes effect (2022 National Framework). Care paid for before that date isn't automatically reimbursed — but it can be recovered retrospectively via PUPoC (see below). Eligibility isn't permanent either. The ICB must reassess at least annually; if needs change, eligibility can be removed or extended.


What CHC funding covers — and what it doesn't

CHC funding covers all assessed care needs — including care home accommodation, personal care, nursing care, specialist equipment, continence supplies, therapies, end-of-life care, and mental health interventions. It does not cover rent or mortgage if at home, food and utilities beyond what's part of a care plan, or privately requested additional services that fall outside the assessed plan.

What CHC, FNC and Local Authority social care each coverCHC funds all care. FNC and Social Care do not.Coverage across six care categoriesCHCFNCLA Social CareAccommodation ✓Not coveredMeans-testedPersonal care ✓Not coveredMeans-testedNursing care ✓Partial£267.68/wk onlyNot coveredEquipment ✓Not coveredLimitedTherapies ✓Not coveredNot coveredEnd-of-life care ✓Not coveredNot coveredSource: 2022 National Framework + nhs.uk + gov.uk FNC rate (April 2026)
CHC covers all six categories in full. FNC contributes only to nursing time. Social Care covers means-tested personal care.

The included list reads broadly: care home accommodation and board, all personal care, all nursing interventions, specialist equipment your relative needs for the assessed care plan, continence supplies, allied health therapies, mental health interventions where they're part of the package, and end-of-life care including palliative interventions. The 2022 National Framework treats all of these as part of the single CHC commitment (gov.uk).

The excluded list matters too. CHC doesn't cover rent or mortgage payments if your relative remains in their own home. It doesn't cover ordinary food and utility costs beyond what's clinically necessary (special therapeutic diets are included; ordinary meals are not). It doesn't cover privately purchased extras that sit outside the assessed plan. And it doesn't cover anyone whose needs are entirely social-care-led — that's where the Coughlan line bites.

Why exclusions matter in practice. Families sometimes pay for "extras" that a care home presents as essential — bigger room, extra outings, premium meals — when the home should be delivering the assessed plan at no cost to the family. If a charge isn't part of the assessed plan, ask whether it's a genuine additional service or a disguised top-up. Top-ups on the same care package are unlawful.


How much CHC funding is worth — the financial scale

CHC funding is worth, on average, £65,012 per recipient per year in England — with significant variation by deprivation (Nuffield Trust, June 2024). For a self-funded family paying £1,000-£1,500 per week for nursing care, CHC eligibility removes a £52,000-£78,000 annual liability (Age UK, 2025).

The deprivation gap is striking. ICBs serving the most-deprived areas spend an average of £47,300 per CHC recipient per year. ICBs serving the least-deprived spend £95,085. That's not because the legal test changes — the Coughlan primary health need bar is identical everywhere. It's because the package each ICB commissions to meet the same eligibility looks different, partly because local care market prices differ, and partly because deprived-area ICBs face tighter overall budgets.

Annual cost to your family under each funding routeAnnual cost to your family — nursing home careBased on £1,267/week average UK nursing fees (Age UK, 2025)£0CHC100% NHS-funded~£52,000FNC£267.68/wk NHS contribution only~£65,000+Self-fundAbove £23,250 thresholdAnnual figures rounded. Specialist dementia care above £1,500/wk widens the gap further.
CHC vs FNC vs self-funding — the same care, three very different family bills.

The national budget has grown steeply. CHC spending was around £4.3 billion in 2015-16; £5.9 billion in 2022-23; £6.5 billion in 2023-24 (Commons Library, 2024). That's roughly 50% real-terms growth over eight years — while the eligibility rate at full assessment has fallen from 31% to 17%. More money, fewer people. The same legal test. The arithmetic only works because the people who do qualify have increasingly intense needs.

What this means for your relative. If specialist nursing or dementia care is running at £1,400+ per week (Alzheimer's Society), CHC eligibility is a £72,000+ annual transfer of liability from your family to the NHS. Over five years of care, that's £350,000+. That figure is why proper preparation at the Checklist stage — see our CHC Checklist guide — pays for itself many times over.


Retrospective CHC claims (PUPoC) — recovering fees back to 2012

Families who paid for care without a CHC assessment can claim retrospectively under the PUPoC (Previously Unassessed Period of Care) process — for periods from 1 April 2012 onwards (gov.uk, March 2025). The ICB where the person was resident at the time of the care period reviews the case using the same primary health need test that applies today.

The April 2012 date is fixed in policy. NHS England closed earlier periods through a series of close-down exercises between 2014 and 2017. Claims for care before 1 April 2012 are no longer accepted. From April 2012 onwards, there is no time limit on when a claim can be submitted — only an ICB time limit on how quickly it must be processed once received.

The PUPoC process moves in stages: application → eligibility check → evidence gathering → a "Needs Portrayal" document that reconstructs what the person's needs looked like during the period claimed → Checklist screening if appropriate → full assessment via Decision Support Tool if the Checklist is positive → written decision. ICBs are targeted to complete claims under one year duration within 6 months, and longer periods within 12 months, with exceptional-circumstance exemptions.

The evidence requirement is substantial. ICBs need care home daily records, GP records, hospital records, any contemporary social care assessments, and payment evidence proving who actually paid for the care. Where records are thin, the claim is harder.

NHS England doesn't publish national PUPoC success rates. Assume high effort, no published outcome data. Families considering a PUPoC claim should treat it as a paperwork-heavy, long-running, but potentially high-value exercise — for a family that paid £52,000+ per year self-funded since 2020, the cumulative recoverable sum can exceed £250,000. For the practical route, see our retrospective CHC claim guide.

The PUPoC route is the only mechanism that recovers what should have been paid since 2012. If your relative was paying for care during any period since 1 April 2012 without a CHC Checklist being offered, a PUPoC claim is the route to test whether they should have been NHS-funded all along.


CHC vs FNC — and the trap of being routed wrongly

NHS-funded Nursing Care (FNC) is a flat NHS contribution toward registered nurse time in a nursing home — £267.68 per week from 1 April 2026 (a 5.4% rise from the previous £254.06) (gov.uk, 2026). FNC is awarded only when CHC is refused but a nursing need remains. You cannot receive CHC and FNC at the same time. The trap families fall into: being awarded FNC when a full CHC assessment was never even triggered.

The eligibility distinction is sharp. CHC = primary health need met = full NHS funding of all care. FNC = nursing need below CHC threshold = £267.68 per week NHS contribution toward the cost of registered nurse time only. A small group of pre-October 2007 cases retain the higher rate of £368.24 per week. Everyone else awarded from October 2007 onwards is on the standard rate.

The "parked on FNC" pattern is one of the most common funding mistakes families discover months or years after the fact. The hospital social worker arranges a discharge to a nursing home. FNC is set up. Self-funding kicks in for everything FNC doesn't cover — accommodation, personal care, food, equipment. The CHC Checklist that should have been offered first never happens. Six months later, the family is £25,000+ deep into self-funding when a friend mentions Continuing Healthcare. By then the question is "should we have been on CHC from the start?" — and the answer is often yes.

The route back is open. Any FNC recipient can request a CHC reassessment at any time. The ICB must in any case review annually. For periods before the request, PUPoC is the route to recover historic fees. For the FNC mechanics in detail, see our NHS-funded Nursing Care guide.


CHC vs social care funding — and what the cancelled care cap means

Local authority social care is means-tested at £23,250 upper / £14,250 lower thresholds — frozen for the 15th consecutive year (Community Care, 2025). The October 2025 reforms — including the £86,000 lifetime care cap and raised capital limits — were cancelled by the Chancellor in July 2024, saving the Treasury £1.1 billion (Community Care, 2024).

What the frozen thresholds actually mean. The upper limit (£23,250) is the asset point above which the local authority provides no help with care costs. The lower limit (£14,250) is the point below which capital is disregarded entirely. Between the two, a tariff-income calculation applies. Both numbers have been frozen since 2010-11. Real-terms inflation over 15 years means the thresholds now bite at far lower real wealth than they did when set.

The cap cancellation is the policy change families researching CHC need to know. Andrew Dilnot proposed a lifetime care cap in 2011. Successive governments planned, deferred, replanned, and then in October 2025 the cap was due to take effect at £86,000. In July 2024, the new Chancellor cancelled it — describing the £1.1 billion saving as part of a wider fiscal correction. Dilnot's own response was direct: "simply wrong... a tragedy" (Community Care, 2024).

What this means for CHC. With no cap, the alternative to CHC eligibility is unlimited self-funding above the capital threshold. A family whose relative spends ten years in specialist dementia care at £1,500+ per week is now looking at unconstrained liability. There is no upper ceiling that limits the family's exposure. This changes the economics of whether to pursue CHC. For families considering options, see our guides on the 12-week property disregard and on deferred payment agreements.


How to challenge a refused CHC funding decision

Three escalation routes exist when CHC funding is refused or wrongly applied. About 13% of local resolution requests result in eligibility being granted (Nuffield Trust, June 2024) — roughly one in eight ICB decisions are overturned at first review on the same evidence.

The three stages run in order. A Local Resolution Meeting with the ICB is the first stop — informal, faster than later stages, focused on the assessment itself. If that doesn't resolve the issue, an Independent Review Panel convened by NHS England takes the case to a formal panel. If procedural failure remains after that, the Parliamentary and Health Service Ombudsman investigates — but only after the NHS complaints process has been exhausted.

All three turn on a single question: did the decision-maker apply the Coughlan primary health need test with reasons? The 2006 High Court decision in R (Grogan) v Bexley NHS Care Trust [2006] EWHC 44 (Admin) established that ICBs must give reasons, not labels. "Needs were not complex" is an assertion, not analysis. The Grogan requirement is what every challenge ultimately rests on.

For the full appeal route, see our guide on how to challenge a CHC decision. For the legal test the challenge engages, see our primary health need legal test explainer.


How to start a CHC funding application

There are four entry routes. Ask a registered nurse, allied health professional, or social worker to complete a CHC Checklist before hospital discharge — the standard route. Ask the GP, palliative nurse, or hospital doctor to submit a Fast Track Pathway Tool if the condition is rapidly deteriorating. Submit a PUPoC retrospective claim to the ICB for care since 1 April 2012. Contact the ICB directly to request a CHC assessment outside hospital — particularly for care home residents or people whose needs have changed.

The written request template most often used at hospital discharge sits on our Checklist guide. Address it to the ward manager, copy the hospital social worker, cite the National Framework, and don't agree to discharge into a care home until the Checklist is complete.

When to request which pathway. Fast Track if the condition is rapidly deteriorating or entering a terminal phase — completed assessments have a very high acceptance rate per the latest NHS England data. PUPoC if your relative paid for care without assessment since 2012. Standard Pathway Checklist in all other cases where ongoing significant needs are present. For a deeper decision tree, see our who qualifies for CHC funding guide.

If you're at the start of the process, our free Eligibility Screener triages your case in three minutes — no commitment, no charge. If you're preparing for a Checklist, the Checklist Evidence Pack (£597) is our family-priced evidence preparation service — the structured document the assessor actually reads. If you've already been refused, the Case Strength Report (£97) triages whether to pursue an appeal before you commit further time.


What this means in 2026

The NHS spends £6.5 billion a year on a funding route most affected families never encounter. The legal test that decides eligibility hasn't moved since 1999. The application has tightened — 31% eligibility in 2017-18 is now 17%. Three things follow from where the funding architecture stands in 2026:

  • The four delivery models matter. Direct ICB payment is the default, but Personal Health Budgets give home-based recipients the most control — and 25,402 people are now on one.
  • Top-ups on the same care package are unlawful. If a care home asks the family to "make up the difference" under CHC, the ICB hasn't paid its full assessed cost.
  • The £86,000 care cap was cancelled. Self-funding now has no upper limit — which makes CHC eligibility (and PUPoC retrospective claims) economically far more consequential than under the planned cap regime.

From 14 May 2026, NHS England moves CHC reporting into All Age Continuing Care management information (NHS England). The funding architecture is unifying. The eligibility test isn't. The numbers will still be there — just published differently.

For the family-side view of how all this fits together, our cluster of guides walks you from who qualifies, to what the criteria actually require, to the legal test behind every CHC decision, to the Checklist screening tool itself.

Reviewed by legal professionals and social care professionals.

CT

CareAdvocate Team

Editorial Team

Our content is written with AI assistance and reviewed by a legal and regulatory professional, a senior social worker, and experienced local government social care professionals. Individual reviewers are not publicly named while still employed.

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