Practice Assurance Response

Automated Request Management Solutions (ARMS)

Addressing the NHS England Policy Statement on Virtual (AI) Receptionist Solutions

Your Assurance at a Glance

A summary of QuantumLoopAI's position on each area of concern raised in the NHS England policy statement.

This document has three parts. This page provides a short summary of our assurance position on every point raised by NHS England. If you need the headline answers quickly, this page is designed to give you confidence in sixty seconds.

The introduction letter that follows provides context on how AI reception fits into the primary care landscape and why this document exists.

The full Practice Assurance Response (Sections 1 to 8) provides the detailed evidence, legal references, and recommended practice actions behind each summary point. You may wish to share the full response with your IG lead, Caldicott Guardian, or ICB as part of your governance record.

A Message to Our Practice Partners

From QuantumLoop Technologies Ltd

March 2026

Dear Practice Partners,

You may have recently received a policy statement from NHS England regarding Virtual (AI) Receptionist Solutions. We welcome the conversation it opens, and we take the questions it raises seriously. This document is our formal response, prepared to give you full transparency, clear answers, and the confidence to make informed decisions about patient access at your practice.

Before you read our detailed, point-by-point assurance response, we want to share some important context. The story of how we arrived at this moment matters, because it is ultimately a story about whether the NHS can embrace innovation that genuinely improves patient care, or whether legacy commercial interests will be allowed to stand in the way.

The Journey So Far: From Engaged Tones to AI Reception

Over the past decade, primary care telephony has undergone a significant transformation. The move from analogue to cloud-based VoIP telephony was well intentioned. The objective was clear: eliminate engaged tones, provide unlimited lines, and give practices the infrastructure to handle patient demand. The £240 million investment in the Advanced Telephony programme reflected genuine ambition to improve access.

The intention was admirable. The execution, however, delivered only half the solution.

Unlimited lines and IVR menus meant patients no longer heard engaged tones. Instead, they heard hold music. Instead of being unable to get through, they waited in queues, pressed buttons, and eventually reached the same one, two, or three receptionists who were already stretched beyond capacity. The bottleneck did not disappear; it simply moved further downstream.

The human cost of this is well understood by every practice in the country. Receptionists remain at the sharp end of patient frustration: managing the 8am rush, absorbing the stress of patients who are unwell and have been kept waiting, navigating complex triage decisions, all while being measured against metrics that were designed to quantify failure. Missed calls. Abandoned calls. Average hold times. Callbacks requested. These metrics exist because the system was not working. They measured the gap between what patients needed and what the infrastructure could deliver.

That gap is precisely what EMMA was built to close.

What EMMA Actually Does

EMMA is an Automated Request Management Solution. It answers every patient call within seconds, conducts a structured conversation, documents the patient’s request, and submits it directly into your practice workflow for triage by your clinical and administrative team. It is, in functional terms, the telephone equivalent of an online consultation tool such as Accurx, eConsult, or Anima. The input channel is different; the output is the same: a structured patient request, ready for your team to act on.

The results speak for themselves. Practices using EMMA report a 100% call answer rate with near-zero wait times. The 8am rush is eliminated. Every patient receives immediate attention. Every request is documented consistently. And the metrics that were built to measure failure are, at EMMA practices, becoming redundant, because the failure they were designed to capture no longer exists.

Crucially, EMMA does not replace your receptionist team. It handles the repetitive, high-volume call intake that consumes the majority of their time, freeing them to do the work that requires human judgement, empathy, and skill. Any caller can request to speak to a member of staff at any point and will be connected to the practice. Approximately 22% of all calls are transferred to a human operator. Your team remains central to patient care; EMMA simply ensures they are no longer overwhelmed.

A New Category, Not a Telephony Replacement

It is essential to be clear about what EMMA is and what it is not.

EMMA is not a telephony service. QuantumLoopAI is not a telephony provider. We do not supply cloud-based telephony infrastructure, IVR systems, internal extensions, call routing between staff, or any of the capabilities described in the Better Purchasing Framework (BPf) national specification. NHS England itself has confirmed that QuantumLoopAI is not considered a telephony provider.

When your practice implements EMMA, your BPf telephony contract remains in place. Your BPf provider continues to deliver your internal telephony, your outbound calling, and your business continuity failover. You are not breaking your contract. You are not replacing your telephony provider. You are adding a new service, in a new category, that works alongside your existing infrastructure.

This distinction is not a technicality. It is fundamental to understanding why the concerns raised in the NHS England policy statement, while understandable on their face, do not apply to EMMA in the way the statement implies. We address each concern in precise detail in the assurance response that follows this introduction.

National Data Reporting: Full Compliance, Greater Transparency

One of the central concerns raised in the NHS England statement relates to national data reporting. This is a valid and important question, and the answer is straightforward.

QuantumLoopAI reports all eight national Cloud Based Telephony (CBT) metrics through our management dashboard, in the format required by NHS England. We have engaged directly with NHS England on the mechanism for providing this data nationally, and we report via the Secure Electronic File Transfer (SEFT) system. The practice simply needs to confirm its preference, and we handle the reporting on your behalf.

In practice, this means your reporting obligations under the GP contract are maintained in full. In many cases, practices using EMMA have greater visibility of their call performance than they had before, because our real-time dashboard provides immediate, granular insight into every call, every request, and every outcome.

An Uncomfortable Truth

We had hoped that the arrival of AI reception would be welcomed across the system as the breakthrough it represents. We had hoped that the organisations responsible for supporting GP practices would recognise the potential and work constructively to help practices access it. We had hoped that telephony providers would see an opportunity to collaborate, not a threat to resist.

Unfortunately, that has not been our experience.

Over the past twelve months, we have encountered a pattern of conduct from certain telephony providers and from elements within the National Commercial and Procurement Hub that we believe does not serve the interests of practices, patients, or the taxpayer. We share this with you not to be adversarial, but because transparency demands it.

Practices have reported to us that their telephony providers have imposed new and previously uncontracted charges when practices have sought to implement EMMA. Charges that did not exist in the original contract, for services that were never discussed at the point of sale, have appeared without warning. In some cases, these charges have run into tens of thousands of pounds. We have seen early termination fees demanded for simple number porting requests, despite porting being a statutory right under Ofcom regulations. We have seen technical objections raised that do not withstand scrutiny. We have seen practices told, incorrectly, that implementing EMMA would put them in breach of their GP contract.

None of these assertions are accurate. They serve one purpose: to deter practices from accessing a service that would benefit their patients, in order to protect the commercial interests of incumbent providers.

We say this plainly because you deserve to know. Several of these same telephony providers are now developing their own AI products. We welcome competition on merit. What we do not welcome, and what we will not accept, is the use of contractual intimidation, fabricated charges, and regulatory misdirection to prevent practices from making free and informed choices about the tools they use to serve their patients.

What We Believe Practices Deserve

Every GP practice in England should have the freedom to choose the tools and services that best serve its patients, provided those tools meet the required standards for safety, data protection, and clinical governance. EMMA meets every one of those standards. Our full compliance credentials are set out in detail in the assurance response that follows.

No practice should be made to feel that it cannot innovate. No practice should face financial penalties for exercising a statutory right. No practice should be given incomplete or misleading information about its contractual obligations by parties with a commercial interest in the outcome.

We have been working behind the scenes for many months, engaging with the Procurement Hub, corresponding with telephony providers, and advocating on behalf of practices to ensure fair treatment. We will continue to do so. We are pursuing every available avenue, including regulatory complaints and formal legal action where necessary, to ensure that the rights of practices and patients are protected.

Your Assurance

The document that follows provides a comprehensive, point-by-point response to every concern raised in the NHS England policy statement. For each concern, we set out our position, the evidence that supports it, and the actions we recommend you take to ensure your governance records are complete.

In summary:

You are not breaking your BPf telephony contract. Your BPf provider remains in place for internal telephony and failover. EMMA is a separate service in a separate category.

Your national reporting obligations are fully met. QuantumLoopAI reports all eight CBT metrics and submits national data via the SEFT system.

EMMA meets every required safety and governance standard. DTAC completed. DCB0129 compliant. MHRA registered. Cyber Essentials PLUS certified. DSPT completed. ISO 27001 accredited systems. ICO registered. Full DPIA in place.

EMMA is the only AI reception service approved by multiple ICBs and listed on the Crown Commercial Service RM6200 AI framework. It is a proven, operational service with over two years of live deployment in NHS GP surgeries.

Business continuity is built in. If EMMA is ever unavailable, calls automatically revert to your BPf telephony provider with no manual intervention required.

Patients always have access to a human. Any caller can request to speak to a member of staff at any point and will be connected to the practice.

EMMA complements your existing access channels. It does not replace your online consultation tool, your in-person access, or your BPf telephony. It adds capacity; it removes nothing.

Looking Ahead

QuantumLoopAI exists for one reason: to improve patient access in primary care. We take care of millions of patients across the country. We are proud to work alongside practices that share our commitment to innovation, safety, and putting patients first.

We hope that, in time, the Procurement Hub and the telephony providers will recognise that AI reception is not a threat to their work but a complement to it. We hope they will choose to collaborate rather than obstruct. We hope they will put the interests of practices, patients, and the taxpayer where they belong: at the centre of every decision.

Until that day, we will continue to stand with our practice partners. We will continue to advocate for your right to choose. And we will continue to deliver a service that transforms patient access for the communities you serve.

We hope you find the assurance response that follows helpful and comprehensive. If you have any questions, or if you would like to discuss any aspect of this document with us, please do not hesitate to get in touch. We are here for you.

QuantumLoop Technologies Ltd

What follows is our Practice Assurance Response, addressing the NHS England policy statement on Virtual (AI) Receptionist Solutions in full detail.

1. Purpose of This Document

The sections that follow contain the detailed evidence, regulatory references, and recommended practice actions that support the summary provided in Your Assurance at a Glance. Each section can be read independently or shared with advisers as needed

NHS England has issued a policy statement and advice to practices regarding Virtual (AI) Receptionist Solutions. This document provides a formal, point-by-point response from QuantumLoop Technologies Ltd to assist GP practices in understanding how QuantumLoopAI’s Automated Request Management Solutions (ARMS) service addresses each of the concerns raised.

This document is intended to be read alongside:

• QuantumLoopAI’s Data Protection Impact Assessment (DPIA)
• QuantumLoopAI’s Digital Technology Assessment Criteria (DTAC) submission
• QuantumLoopAI’s Clinical Safety Case Report and Hazard Log (DCB0129)
• The practice’s own controller DPIA for the ARMS service
• The Data Processing Agreement between the practice and QuantumLoop Technologies Ltd

This document should be placed on file by the practice as part of its governance record for the ARMS service. It may be shared with the practice’s ICB, IG lead, Caldicott Guardian, or NHS England on request.

2. Service Classification

2.1 QuantumLoopAI is not a telephony provider

NHS England has confirmed that QuantumLoopAI is not considered a telephony provider and is therefore not required to comply with the Better Purchasing Framework (BPf) telephony requirements. This confirmation is consistent with the nature of the service: QuantumLoopAI provides an automated request management service, not a telephony infrastructure platform.

The ARMS service, including its voice interface EMMA, is functionally equivalent to an online consultation tool such as Accurx, eConsult or Anima. The difference is the input channel: where online consultation tools accept patient requests via a web form, EMMA accepts patient requests via a telephone conversation. In both cases, the output is a structured patient request submitted to the practice for triage and follow-up by clinical and administrative staff.

EMMA does not provide the practice’s telephone system. It does not deliver cloud-based telephony infrastructure, IVR, internal extensions, call routing between practice staff, click-todial, or any of the other capabilities specified in the BPf national specification. The practice continues to require a BPf telephony solution for its internal telephony needs.

QuantumLoop Technologies Ltd is satisfied, having considered the regulatory framework, the GP contract requirements, and the nature of the ARMS service, that the implementation of EMMA does not place a practice in breach of the GP contract. The ARMS service operates in a service category that is not covered by the BPf telephony specification. The practice retains its BPf telephony contract, the BPf provider’s infrastructure remains operational, and the practice continues to meet all of its contractual obligations in respect of telephony.

QuantumLoopAI is the only AI-powered reception service to have been assessed and approved for deployment by multiple Integrated Care Boards across England. These approvals followed independent governance review by each ICB, including assessment of clinical safety, data protection, service resilience, and patient access standards. QuantumLoopAI is also listed on the Crown Commercial Service RM6200 framework for Artificial Intelligence, providing an additional layer of procurement assurance and governance for NHS and public sector organisations. Practices implementing the ARMS service are adopting a solution that has passed independent scrutiny at both local and national level.

AI-powered reception is a new service category in NHS primary care. It did not exist when the Better Purchasing Framework was designed, and it is not addressed by the current BPf telephony specification. As adoption of AI reception continues to accelerate across the NHS, it is expected that procurement frameworks, contractual structures, and reporting methodologies will be updated to reflect this new category alongside, rather than within, the existing telephony specification. QuantumLoopAI is actively engaged with NHS England and with Integrated Care Boards to support this process. In the interim, practices can be confident that QuantumLoopAI has taken every available step to ensure compliance with existing requirements, including voluntary national data reporting via SEFT, while operating in a service category that the current frameworks do not yet formally address.

2.2 Relationship with the practice’s BPf telephony provider

When a practice implements EMMA, the practice telephone number is ported to an Ofcomregulated UK tier one telecommunications carrier that provides resilience at the highest level, often superior to that provided by current practice telephony providers. This tier one carrier provides the underlying carrier service that delivers inbound calls to QuantumLoopAI's platform. The carrier is not a BPf supplier; it is a regulated carrier providing connectivity to the ARMS service. The tier one carrier is QuantumLoopAI's partner carrier for the delivery of the ARMS service.

The practice telephone number is ported to QuantumLoopAI's tier one carrier partner for the purpose of delivering the ARMS service. The practice retains full ownership of the telephone number at all times. Number portability is a statutory right regulated by Ofcom under General Conditions B3 and C7 of the Communications Act 2003. Ofcom’s regulatory authority over number portability operates at a statutory level and is not overridden or displaced by any procurement framework, including the BPf.

Calls that require human handling, for example, where a caller requests to speak to a member of practice staff, are forwarded by the ARMS service to the practice. The practice’s BPf telephony provider continues to operate and is used for internal telephony, outbound calls, and as the automatic failover route if the ARMS service is unavailable.

The practice retains its contract with its BPf telephony provider. The BPf provider’s infrastructure remains live and operational at all times.

3. Point-by-Point Response to the NHSE Policy Statement

The following sections address each concern raised in the NHSE letter in the order presented.

3.1 Better Purchasing Framework procurement

3.2 National data reporting

3.3 Porting of the practice telephone number

3.4 Call forwarding charges

3.5 Clinical safety, information governance and cyber security

3.6 Service standards and uptime

3.7 Business continuity

3.8 Alternative access for vulnerable patients

3.9 Complementing, not replacing, access to care

4. Summary of Assurance

The following table summarises the assurance position for each area of concern raised in the NHSE policy statement.

5. Documentation Available to Practices

QuantumLoopAI can provide the following documentation to any practice on request, to support the practice’s own governance and assurance processes:

6. Recommended Practice Actions

To demonstrate that the practice has given due consideration to the NHSE policy statement and has taken appropriate action, we recommend the following:

1. Place this document on file as part of the practice’s governance record for the ARMS service.

2. Complete (or update) the practice’s controller DPIA for the ARMS service. QuantumLoopAI provides a substantially pre-populated template and full support for this process.

3. Complete (or update) the practice’s DCB0160 deploying organisation clinical risk assessment. QuantumLoopAI provides its DCB0129 documentation to support this.

4. Confirm with the practice’s BPf telephony provider that the BPf contract remains in place and that the BPf infrastructure is available as the failover route.

5. Confirm the CBT national reporting mechanism. QuantumLoopAI reports all eight metrics via its dashboard. The practice should confirm how these are submitted to NHS England through the CQRS process.

6.  Test the business continuity failover arrangement during or shortly after implementation.
7. Ensure the practice’s privacy notice is updated to reflect the use of the ARMS service and the processing of patient data by QuantumLoopAI as a data processor.
8. Ensure that alternative access channels (online consultation tool, in-person, and BPf telephony as failover) remain available and are communicated to patients.
9. Document the practice’s decision and rationale for implementing EMMA, referencing this assurance document, the controller DPIA, and the DCB0160 assessment.

7. Contact

For any questions regarding this document or to request any of the assurance documentation listed in Section 5, please contact:

QuantumLoop Technologies Ltd

Email: support@quantumloopai.com

We are committed to supporting every practice through the assurance process and welcome engagement from practice IG leads, Caldicott Guardians, ICBs, and NHS England assurance teams.

8. Document Control