NHS Individual Funding Request Denied? How to Appeal an IFR Decision

An NHS Individual Funding Request (IFR) — sometimes called an individual funding request or prior approval application — is the process by which clinicians apply to their Integrated Care Board (ICB) for funding of treatments not routinely commissioned. When an IFR is denied, patients are often left without access to potentially life-changing or life-saving care.

If your IFR has been refused, you have the right to challenge the decision. This guide explains how.

What Is an Individual Funding Request?

IFRs are submitted by your NHS clinician (usually a consultant specialist) on your behalf when a treatment is not covered by the ICB's standard commissioning policies. Common scenarios include:

• A drug approved by NICE but not yet commissioned locally
• An off-label medication your specialist believes is appropriate for your condition
• A treatment that is available for some patients but requires individual clinical justification for others ("exceptional circumstances" funding)
• A procedure not included in the ICB's approved clinical policy

The decision is made by the ICB's IFR panel, which considers clinical evidence and exceptionality.

Why IFRs Are Denied

The most common grounds for IFR denial include:

Not exceptional. ICBs can only fund treatments through the IFR process if a patient's circumstances are genuinely exceptional compared to others with the same condition. If the panel concludes your case is not meaningfully different, they may refuse.

Insufficient clinical evidence. If the supporting evidence submitted by your clinician does not adequately demonstrate clinical need or potential benefit, the panel may decline.

Treatment not considered clinically effective. The ICB may conclude that the evidence base for the treatment is insufficient, even if your specialist disagrees.

Policy conflicts. Some ICBs have explicit policies restricting certain treatments (e.g., bariatric surgery, IVF, gender-affirming care). An IFR that conflicts with a blanket policy is likely to be denied.

Your Rights and the Review Process

An IFR denial is not final. NHS England's guidance gives you the right to request a review. The review process typically involves:

1. Request an IFR Review

Ask your consultant to request a formal review of the IFR decision. The ICB must have a review process in place. The review panel should be independent of the original decision-makers.

2. Submit Additional Clinical Evidence

The review is your opportunity to strengthen the case. Work with your consultant to:

• Provide additional clinical evidence of your exceptional circumstances
• Obtain specialist opinions from other clinicians if necessary
• Reference any updated NICE guidance, clinical trial data, or published evidence supporting the treatment
• Document how your case is clinically distinct from the typical patient with your condition

3. Make a Formal Complaint to the ICB

If the review process does not resolve the matter, you can submit a formal complaint to the ICB under the NHS Complaints Regulations 2009. The ICB must acknowledge your complaint within three working days and issue a response within 40 working days (or explain any delay).

4. Escalate to the Parliamentary and Health Service Ombudsman (PHSO)

If the ICB's complaint response is unsatisfactory, you can escalate to the Parliamentary and Health Service Ombudsman (PHSO). The PHSO investigates complaints about NHS services in England and can:

• Order the ICB to reconsider the IFR decision
• Require the ICB to apologise and take remedial action
• Make recommendations about ICB policy and process

5. Consider Judicial Review

In cases where an IFR panel has acted unlawfully — for example, by applying a blanket policy that excludes individual consideration — judicial review is possible. This is a legal process and requires specialist legal advice. NHS legal aid may be available in certain circumstances.

Key Points About Exceptionality

The concept of "exceptionality" is the most contested aspect of IFR decisions. You do not need to be unique — but you do need to demonstrate that your clinical circumstances are significantly different from others with the same condition. Evidence that supports exceptionality includes:

• Failure to respond to standard treatments
• Unusual comorbidities that make standard treatment inappropriate
• Specific clinical factors that make your case atypical
• A particularly severe presentation of a condition

NHS Continuing Healthcare vs IFR

Note that IFR funding for active medical treatment is distinct from NHS Continuing Healthcare (CHC), which funds ongoing care needs (see our separate guide on CHC appeals). If your denial relates to long-term care funding rather than a specific treatment, the CHC appeal process applies.

Fight Back With ClaimBack

ClaimBack helps patients and carers build structured challenges to NHS funding decisions, including IFR reviews and formal complaints. We help you frame your clinical evidence, identify procedural errors in the ICB's decision-making, and prepare compelling written submissions.

Start your NHS funding appeal with ClaimBack

Related Reading

• How to Write an Insurance Appeal Letter
• Common Reasons Insurance Claims Are Denied
• Internal vs External Insurance Appeal: What's the Difference?