The Five Case Model: How an NHS Training Business Case Is Judged

Training proposals in the NHS fail for a predictable reason: they are written as a description of a course and read as a request for money. The people who approve spending are not assessing whether the training is good. They are assessing whether the document in front of them satisfies five separate tests, each of which can sink it on its own.

The five cases, and what each one actually asks

HM Treasury's five case model is the required structure for public sector business cases. The five cases are not headings to be filled in. Each is a distinct question with a distinct failure mode.

• Strategic. Does the proposal demonstrate "business synergy and strategic fit"? A training proposal that cannot be traced to a stated organisational objective fails here, however well evidenced the need.
• Economic. Does it optimise public value? This is where options have to be compared, including the option of doing nothing. A single-option proposal is not an economic case.
• Commercial. Is there a "viable procurement and well structured Deal"? This is the case most training proposals omit entirely, and the one that determines whether the preferred supplier can lawfully be used.
• Financial. Is the deal "fundable and affordable"? Fundable and affordable are two tests, not one. A proposal can be affordable in-year and unfundable across the life of the contract.
• Management. Is it "capable of being delivered successfully"? Named accountability, a delivery plan and benefits realisation arrangements sit here.

Note what is missing from that list: nothing asks whether the training content is high quality. Quality enters through the economic and management cases as evidence supporting a claimed benefit, which is a different burden of proof than most suppliers and most internal sponsors expect.

The three stages, and why the second one is where proposals die

The model runs through three documents, not one. The Strategic Outline Case establishes the case for change and the shortlist. The Outline Business Case is the document that "optimises value for money" — it is where the preferred option is selected and justified. The Full Business Case confirms the "most economically advantageous offer" after procurement.

The practical consequence is sequencing. A supplier cannot be named at Strategic Outline Case stage without prejudicing the economic case, and cannot be changed at Full Business Case stage without reopening the commercial case. Internal sponsors who have already decided which provider they want routinely get this wrong, and the correction costs months.

It is binding, not advisory, for capital in the NHS

NHS England's capital guidance adopts the five case model directly, which converts a Treasury methodology into an approval requirement. The delegated limits matter for anyone trying to work out who signs:

• Trusts in financial distress have a delegated limit of £25 million.
• Foundation trusts not in distress have a delegated limit of £50 million.
• Anything at or above £50 million requires HM Treasury approval.

Those thresholds are high relative to any realistic training spend, which is the point most training business cases miss in the other direction: a workforce development proposal is almost never going to hit a delegated limit, so the gating factor is not the approval tier. It is whether the proposal survives the revenue budget, where there is far less room than the capital figures suggest. We set out how that revenue envelope is constructed in our guide to how a care budget is actually built.

Writing the economic case for training without inventing numbers

The economic case requires options appraisal, and this is where training proposals tend to fabricate. The honest version uses costs that are already published and already in the organisation's own accounts rather than modelled returns on investment that nobody believes.

The strongest available comparator is usually the cost of not doing it, expressed through temporary staffing. Agency and bank spend is measurable, already reported, and under an explicit reduction target. A proposal that connects a training intervention to a reduction in agency reliance is making an economic argument against a line the finance director already watches — and the price mechanics of that line are specific, as we explain in what the NHS agency price caps actually say.

The second strongest is turnover. Replacement cost is a real, incurred, documented cost rather than a projected benefit, which makes it admissible in a way that productivity estimates generally are not.

What does not work: asserting a percentage efficiency saving. There is no published provider-level efficiency target that a training business case can borrow. The 2025/26 framework sets a general efficiency requirement of 2.0% across the system, which is not the same thing as a licence to claim a 2% saving from a specific intervention, and reviewers know the difference.

The commercial case is a procurement question, not a preference

Because health care services sit under the Provider Selection Regime rather than the general procurement rules, the commercial case for a clinical or care service follows one set of processes, while training, goods and equipment follow another. Getting this wrong invalidates the case rather than weakening it. The distinction is worth understanding before the commercial section is drafted, not after.

The management case needs a staffing model that exists

Benefits realisation for a workforce proposal almost always rests on an assumption about who will be released to attend. That assumption has to be reconcilable with the rota, and the rota is built against a staffing requirement that no regulator expresses as a number — a gap we examine in rostering economics. A management case that assumes backfill capacity which the roster cannot produce will be delivered late, and the benefits will not materialise on the timetable claimed.

A short checklist

Before submitting anything: can you name the organisational objective the proposal serves; have you appraised at least one real alternative plus do-nothing; do you know which procurement regime applies; is the proposal fundable across its full life rather than only affordable this year; and is there a named owner with a delivery plan? Five yeses is a business case. Fewer is a description of a course.

One caution on sources. The five cases are defined in HM Treasury's business case guidance for projects and programmes, not in the Green Book itself — the Green Book's own landing page does not set them out. Cite the guidance that actually contains the definitions.