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Retrospective NHS Continuing Healthcare claims and PUPoC reviews

A Previously Unassessed Period of Care (PUPoC) is a route for asking the NHS to consider a past period when a person should have been considered for NHS Continuing Healthcare but was not, and they funded their care in full or in part.

Written and reviewed by Paris Theodorou, Solicitor & Principal. Christodoulos Ltd is authorised and regulated by the Solicitors Regulation Authority (SRA 809508). Updated 16 September 2026.

When can a PUPoC request be relevant?

The route is aimed at a past period where there is evidence the person should have been considered for CHC eligibility but was not considered at the time, and the person paid for the care wholly or partly. It is different from appealing a CHC decision that was actually made after a full assessment.

The request is normally made to the Integrated Care Board responsible for the person for the relevant period. The ICB first considers whether it is the responsible commissioner and whether the request falls within the PUPoC process.

How the process works

1. Request and authority

The ICB will need sufficient information to identify the period and the person. If a third party is acting, authority to act and information-sharing requirements also need to be addressed. Where the person has died, the evidence of authority will be different from a case where they are alive.

2. Gathering historic evidence

The ICB should gather available health and care records for the period. Historic evidence can include care-home records, GP and hospital records, community nursing notes, medication records, risk assessments and other documents showing what the person's needs were at the time.

3. Needs portrayal

The current national guidance provides a needs portrayal process to build a chronological picture of the person's needs across the relevant care domains. The applicant should have an opportunity to comment and provide additional evidence.

4. Eligibility assessment and decision

The evidence is used to consider whether the person had a primary health need during the period in question. If the applicant disagrees with the resulting eligibility decision, the guidance provides a review route beginning with local resolution, followed where necessary by independent review and then the Parliamentary and Health Service Ombudsman.

The evidence problem in retrospective claims

The older the period, the more important it is to identify records early. The strongest cases usually reconstruct the pattern of needs over time rather than relying on a diagnosis or a short snapshot.

care plans, daily notes and dependency assessments;

GP and hospital records;

medication and treatment records;

falls, behaviour, nutrition, skin and continence records where relevant;

invoices and evidence of fees paid;

family diaries, correspondence and contemporaneous notes; and

evidence of who had authority to act for the person or estate.

Do not confuse a PUPoC with a late appeal

A PUPoC is for a previously unassessed period. If there was already a CHC eligibility decision for the period, the correct route may instead be the review or appeal process attached to that decision. The documents and dates need to be checked before choosing the route.

How long should it take?

The national PUPoC guidance says ICBs should set reasonable and proportionate timescales and keep applicants updated. As an example of best practice, for a care period of one year or less it identifies completion within six months of receipt of satisfactorily completed application and consent forms. Longer or record-heavy periods may take more time.