NHS England shares guidance on carbon reduction plan requirements

NHS England has published a document entitled ‘Carbon reduction plan requirements for the procurement of NHS goods, services and works’. The document reiterates the requirement for suppliers with an anticipated contract value above £5m per year to publish a carbon reduction plan (CRP) and outlines how this requirement is to be applied in an NHS context.

The document begins by acknowledging the steps outlined in the NHS net zero supplier roadmap for suppliers to adhere to, in order to align with the NHS net zero ambition for 2030.

In order to prepare for future NHS roadmap milestones, suppliers have been encouraged to set a net zero target of 2045, although a target of 2050 will still meet the minimum requirements of CRPs.

With CRPs designed to identify a supplier’s current carbon footprint and their plan to achieve net zero emissions, the NHS will require suppliers to share their CRP information as part of the procurement process, along with ensuring full public visibility of their CRP.

In order to comply with the NHS requirements and to align with the government procurement policy note from June 2021 around CPRs, the CPR must:

  • Confirm the bidding supplier’s commitment to achieve net zero by 2050 or earlier
  • Provide current emissions for the sources included in scope one and two of the Greenhouse Gas (GHG) Protocol must be provided, along with a defined subset of scope three emissions
  • Provide emissions reporting in CO2e (carbon dioxide equivalent) for the seven greenhouse gases covered by the Kyoto Protocol
  • Establish the environmental management measures in effect, including certification scheme or specific carbon reduction measures adopted
  • Be board approved or company director approved if no board is in place
  • Be clearly signposted and published on the supplier’s website
  • Be updated regularly – at least annually

The document states that the CRP should aim to follow the length and structure of government’s PPN 06/21 CRP Carbon Reduction Plan template, however stylistic differences are acceptable.

NHS to NHS contracts

In the case of NHS organisations bidding for contracts with other NHS organisations, a published NHS trust and/or ICB green plan is equally acceptable and considered equivalent to a CRP as long as it meets or exceeds the CRP requirements outlined above.

NHS trusts and ICBs must provide a link to their published green plan and complete the required selection questionnaire as detailed in section ‘CRP reporting mechanism’ of the roadmap.

Public bodies

“Where public bodies who are bidding for NHS contracts, a published carbon reduction plan or a net zero commitment is acceptable and considered equivalent to a CRP where it meets or exceeds the Carbon Reduction Plan requirements as set out above,” the document states.

Public bodies should provide links to their published commitment and complete the required questions found in the CRP reporting mechanism (linked above).

Subcontractors do not need to provide CRP, however they are encouraged to engage with suppliers on the subject of reducing carbon emissions.

SMEs and VCSEs

In exceptional circumstances where suppliers have an “acceptable reason for being unable to gather emissions data”, the plan states they can provide a CRP with the carbon emissions they have available alongside an explanation as to why they have been unable to gather further information.

For example, SMEs (small and medium-sized enterprises) or VCSEs (voluntary, community and social enterprises) with acceptable reasons may use this provision where appropriate.

“A supplier’s explanation will be assessed on a case-by-case basis by the relevant NHS organisation,” the document states. “Suppliers are also required to provide the steps they will take to improve the collection of such data.”

CRPs within the procurement process

The document goes on to summarise how CRPs should be incorporated into the procurement process, starting with assessment methodology.

During the selection stage of the procurement process, the CRP will be assessed in the form of a pass/fail check. The assessment is designed to ensure that the CRP meets the minimum requirements and will be included as a pre-qualification criteria for for all individual frameworks or procurements.

Suppliers whose CRPs do not meet the minimum expectations will not be able to proceed with the process, the document states, and CRPs will not be “scored or compared against each other.”

Moving onto guidance for frameworks and dynamic purchasing systems, the document reiterates that the new framework agreements and new dynamic purchasing systems only apply where it is anticipated that the individual value of any contract awarded will be greater than £5m per year (excluding VAT).

The guidance advises that framework owners should assess whether the new framework is likely to have “call off contracts with an annual value of £5 million or more, in which case, the provisions of PPN 06/21 should be applied at the selection stage when establishing the framework.

Due care should be taken by framework owners to ensure suppliers are ready to comply with all future requirements outlined in the NHS net zero supplier roadmap in the development of their framework.”

NHS England is currently working with wider public sector framework providers to ensure NHS requirements are thoroughly and consistently applied no later than April 2023 for all buying routes.

To read the guidance in full, please click here.