GP notional rent reviews: is your practice underpaid?

By Nita Kotecha, Senior Manager, Healthcare

The three-yearly notional rent review is the single largest premises reimbursement most GP-owned practices receive, and NHS Digital's most recent Payments to General Practice release put total premises payments at £922.9 million across England in 2024/25. Any practice that has not had its Current Market Rent reassessed by the District Valuer within the last three years is very likely being underpaid, and partners should confirm the date of the last review and request a fresh one where the cycle has been allowed to lapse.

What does the notional rent regime actually pay for?

Under the National Health Service (General Medical Services – Premises Costs) Directions 2024, a practice that owns its surgery is entitled to reimbursement calibrated to a Current Market Rent (CMR) assessed by the District Valuer. The rent is notional in the sense that no money changes hands with a landlord, but the amount reimbursed to the practice is set by reference to what would be paid on the open market on a hypothetical 15-year lease, with the tenant responsible for internal repairs and the landlord for external and structural repairs and insurance.

The CMR is assessed on that hypothetical basis regardless of the actual arrangements in place. Where a practice is a tenant, the same DV process determines the reimbursable rent, and reimbursement is set at the lower of the actual lease rent and the assessed CMR. In addition, business rates, water and clinical waste are claimable where the practice asks, though maintenance, insurance, energy and general upkeep of the building are not.

Why does the three-year cycle catch so many practices out?

The Directions provide that notional rent is subject to a review every three years, and the cycle can be brought forward where there has been a change in use of the premises, capital investment agreed by NHS England, or a landlord rent review in the leasehold case. The problem is that the cycle does not restart automatically. If the last review was carried out in 2022 and no one asks for the next one, it does not happen. NHS England is not obliged to prompt the review, and District Valuers are typically instructed only once a request is on the table.

In conversation with GP-owner partnerships over the last twelve months, dormant reviews are a much more common finding than most partners expect. It is not unusual to see practices where the last CMR was set six or seven years ago, in a very different local property market and before the last two rounds of construction cost inflation. The reimbursement figure that sits on the bank statement each month has quietly stopped bearing any relationship to what the DV would set today.

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"The three-year cycle does not restart automatically. If the last review was carried out in 2022 and no one asks, it does not happen."

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How does the CMR interact with new ARRS-funded staff?

This is the pressure point of the moment. The 2026/27 contract has widened the Additional Roles Reimbursement Scheme and introduced a practice-level GP reimbursement scheme that between them are pushing more staff into the physical footprint of general practice. The BMA's 2025 premises survey found that half of practices considered their building unsuitable for current needs, and that 83% said their premises could not accommodate the additional staff the funding schemes are meant to buy.

For a GP-owned practice, that mismatch has two consequences. The first is operational: consulting rooms, shared clinical space and administrative capacity all become bottlenecks. The second is financial: any capital investment that expands the building, subject to NHS England agreement, can be the trigger for a review of the notional rent. Extending, reconfiguring or bringing previously unused rooms into clinical use are all types of premises project the 2024 Directions specifically contemplate, and any of them can pull the review forward from the standard three-year cycle.

What does a District Valuer actually consider?

The DV assessment starts from the notional 15-year lease terms and tests them against comparable evidence in the local commercial property market. The assessor will look at the physical characteristics of the surgery, local rental evidence for equivalent healthcare and Class E premises, planning constraints, and terms specific to the property. Where a lease contains provisions that depart from the assumed terms, whether alienation restrictions beyond the norm, unusual rent review indices, or onerous repair obligations, the DV may adjust the reimbursable figure downwards to reflect the deviation.

That last point matters when leases are signed or renewed without technical input. A lease drafted for a standard commercial letting rather than for a GP surgery can end up eligible for less reimbursement than the property would otherwise attract, because the terms sit outside what the Directions assume. It is worth checking any lease renewal against the reimbursement criteria before signing, not after.

What should partners do this quarter?

Three things. First, confirm the date of the last CMR review. Any practice at three years or beyond is due one, and any practice inside three years but with material change, whether capital works, use change, or an expanded staff footprint, may have grounds to bring the review forward. Second, before commissioning any premises project, get sight of what NHS England has approved and what the funding route is, because the reimbursement consequence depends on the capital arrangement. Third, if the practice is a tenant in premises owned by one or more of the partners, keep the CMR position and the internal partnership property arrangements as separate matters, since they answer to different tests and are muddled easily.

The BMA's own guidance is that where CMR is being reviewed in the leasehold case, contractors are required to provide the area team with a rent review memorandum, and there is a formal appeal route where the assessment produced looks light against the evidence. Neither the review nor the appeal happens on its own. Someone has to ask.

For most practices this is not a large-value piece of work in isolation, but it is easy to defer indefinitely and expensive to leave undone across a whole three-year cycle. If your review has been dormant, our healthcare team can help you gather the evidence needed and decide whether to press for a review, an appeal, or both.

This article has been prepared for information purposes only. Formal professional advice is strongly recommended before making decisions on the topics discussed in this release. No responsibility for any loss to any person acting, or not acting, as a result of this release can be accepted by us, or any person affiliated with us.

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Sources: The National Health Service (General Medical Services – Premises Costs) Directions 2024; NHS Digital, NHS Payments to General Practice, England 2024/25, Management Information, published 26 March 2026; British Medical Association, Rent reimbursement for GP practices guidance (updated 2024); British Medical Association, GP premises survey 2025.

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