£757K to £49 Million. The Costs They Hide Keep Growing. Delivery Does Not

In April 2026, CareNHS published £8.94 Million on Consultants. Nine Programmes Still Failing — an analysis of 49 consultancy contracts disclosed under FOI/5854154. The published accounts had shown £757,000 in consultancy for a single year. The FOI revealed a multi-year total of nearly £9 million. We wrote at the time: "the £8.94 million is a floor, not a ceiling."

We were right. But the floor was far lower than we thought.

Two further FOI responses — FOI/6695599 and FOI/6695741, both dated 28 April 2026 — reveal a total of £49.1 million in external consultancy and contractor engagements exceeding £50,000. This is DHCW's own register, DHCW's own numbers, from DHCW's own information governance team. And they state in the response that even this is incomplete: "Additional contracts will be provided in due course, once we have verified the accuracy of their information."

The published annual accounts showed £757,000. You have to multiply that figure by 65 to reach what DHCW has now disclosed. And the real number is higher still.

Three Asks. Three Numbers. None of Them Complete.

Every layer of this took a separate act of disclosure. Each number is larger than the last. Each makes the previous answer look like a fraction of the truth.

Layer 1: The published accounts — £757,000

This is what a Senedd member, a journalist, or a member of the public would find in DHCW's 2023/24 annual accounts. One line. One year. £757,000 in consultancy expenditure. A modest sum for an organisation with a £78 million annual budget. Nothing to see.

The FOI requester asked DHCW directly whether the £757,000 "includes all external advisory work, or whether some expenditure is classified under different headings (e.g., programme costs, digital services, or managed service contracts)."

DHCW replied: "we do not split the accounts into the headings provided." They then quoted the Treasury's PES definition of consultancy — which includes "advisory, design & developmental and implementation consultancy services" — and stated that consultancy "as part of an ongoing contracted out service" is excluded because "these costs are reported as part of the cost of the contracted-out service."

In other words: if you call it a "service" rather than "consultancy," it disappears from the consultancy line. That one sentence explains the entire gap.

Layer 2: The first FOI — £8.94 million

FOI/5854154 asked for DHCW's consultancy contracts. The first response was incomplete — DHCW admitted as much only after the requester challenged it and filed a formal complaint. The complete disclosure, provided in May 2025, listed 49 contracts totalling £8,943,015, spanning June 2019 to March 2026.

That was twelve times the published annual figure. We wrote an article about it. We noted that major suppliers were missing. We flagged Kainos, CGI, Mozaic, Tektology. We wrote: "The known missing contracts total at least seven to eight."

We also noted that DHCW stated, in response to the first FOI: "Digital Health and Care Wales have no contracts with CGI Ltd."

Layer 3: Two more FOIs — £49.1 million and counting

FOI/6695599 asked for all consultancy engagements exceeding £50,000 from April 2021. FOI/6695741 asked for contracts with specific named suppliers — Kainos, CGI, Channel 3, and Aire Logic — including work package breakdowns.

The combined response discloses 44 contracts totalling £49,140,922. That is 5.5 times the first FOI disclosure. It is 65 times the published annual accounts figure.

And DHCW states it is still incomplete.

What Emerged

Kainos: £32.4 Million in Contracts. £20.6 Million Actually Paid.

Kainos did not appear once in the 49-contract consultancy register. Not a single entry. The new FOIs disclose three contracts:

But the work package spreadsheets go further. They list every individual work package issued under these contracts — scope, deliverables, value. This is not framework ceiling. This is money spent:

£20.6 million paid to a single supplier. Not framework ceilings. Not maximum authorised values. Actual work packages, with dates and deliverables, totalling more than twice the entire first FOI disclosure.

Every one of the 22 Agile Product Delivery work packages is marked "Direct Award." The framework itself was procured through an Open Procedure — but once the framework was in place, every work package was awarded directly to Kainos without further competition. The framework is the competitive fig leaf. The spending underneath it is directed.

To put this in perspective: DHCW's first consultancy register included a £14,550 Service Desk Institute certification programme. It did not include the £20 million Kainos framework. The £14,550 contract was classified as consultancy. The £20 million framework was not.

KPMG: From £1.28 Million to £4.68 Million

The first FOI showed KPMG at £1.275 million across three contracts. The new disclosure adds a fourth:

• Cloud Migration Support Consultancy — £4,000,000 (April 2026 to April 2028), Open Procedure

Total KPMG: £4,675,000. The new contract alone — for cloud migration consultancy — is larger than KPMG's entire previous disclosed relationship. It started in April 2026 — the same month DHCW was escalated to Level 4.

Channel 3 Consulting: £3 Million — Double the First Disclosure

The first FOI listed Channel 3 at £1,530,460 across 5 contracts. The new FOIs show 7 contracts totalling £3,000,460:

Channel 3 is being paid £980,000 to design the National Health and Care Architecture. This is the architecture programme that DHCW's own board minutes show is struggling. And £490,000 for "Cloud Organisational Change Consultancy" — management consultancy to manage the change that the architecture consultancy is producing. The programmes they advise are under Level 4 government intervention.

SPIRIT Public Sector: £2.4 Million — Never Previously Disclosed

A contract that appeared in neither the first FOI nor any previous disclosure:

• Specialist Resources for DSPP — £2,396,500 (April 2022 to March 2026), via Dynamic Market

This is for programme leadership, communications, engagement, and agile coaching for the NHS Wales App programme — on top of the Kainos contracts that delivered the App itself. A £2.4 million staffing contract for a programme that Nick Wood, Deputy Chief Executive of NHS Wales, described as having been "mired in delay, non-delivery."

Tektology: £400,000 — The Missing Contract, Found

In our first article, we reported that an anonymous tipster had referenced a Tektology contract that did not appear in the FOI register. DHCW did not disclose it.

The new FOI reveals:

• DHCW Escalation Support — £400,000 (June 2025 to June 2026), Further Competition

The scope: "Facilitate Board reflections and awareness raising..." DHCW is paying £400,000 for a consultancy to coach the board through the Level 4 escalation — the very escalation that resulted from the failure of the programmes these consultants were hired to advise on.

Mozaic: Two Contracts — Insider Said Three

In our first article, we reported that an anonymous senior DHCW staff member described three Mozaic engagements commissioned by Sam Lloyd, Executive Director of Operations. DHCW did not disclose any in the first FOI.

The new register discloses two:

• Product Operating Model — £73,500 (January to February 2024)
• Cloud Native Service Design — £102,300 (September 2024 to March 2025)

Two of the three the insider described. Where is the third?

CGI: From "No Contracts" to £249,973

The first FOI response stated: "Digital Health and Care Wales have no contracts with CGI Ltd."

The new disclosure shows:

• Digital Transformation Support — £249,973 (January 2024 to January 2025), G-Cloud 13

So "no contracts" was wrong. There was one. Worth a quarter of a million pounds.

But even this does not match what CareNHS has been told by people who were there. An anonymous submission from a senior DHCW staff member described a team of CGI consultants — approaching ten in number, including the CEO of CGI's healthcare division — embedded at DHCW for several weeks in mid-2024. A £249,973 contract does not cover that scale of engagement.

Three disclosures. Three different answers. "No contracts." Then £249,973. Then insider accounts of a much larger presence.

Armakuni: £676,600 — The Only Single Tender Action

One contract in the new register stands out for its procurement route:

• Covid Platform, eForms for TTP — £676,600 (February 2021 to March 2022), Single Tender Action

This is the only contract across all three FOI disclosures identified as a Single Tender Action — a direct award without competitive procurement. In the separate FOI (6695741), when asked whether any contracts with Kainos, CGI, Channel 3 or Aire Logic had been awarded via direct award, DHCW answered "N/A." The Armakuni contract shows DHCW does use Single Tender Actions. It is notable that the only admitted instance was for a Covid-era emergency.

The Rest

Further contracts not in the original register:

The External Workforce Framework: £10 Million, 2 Bidders, Zero SMEs

Alongside the contract register, the response to FOI/6695741 included a contract award notice for the External Workforce Resources Framework Agreement (reference P812). This is a £10 million, four-year framework awarded on 1 June 2023 — a procurement designed to supply DHCW with project managers, programme managers, developers, testers, architects, and infrastructure engineers.

The award notice reveals:

• Total value: £10,000,000 (excluding VAT)
• Only 2 tenders received for each of the three lots
• Zero tenders from SMEs — not one small or medium enterprise bid
• TPXimpact appears on all three lots — planning, application development, and infrastructure
• Kainos on Lot 2 (application development)
• Trustmarque on Lots 1 and 3

"Expenditure under the Framework is not constrained within a particular Lot." The entire £10 million pot can be directed to any supplier on any lot.

The work package spreadsheet shows £3,535,619 in work packages actually issued under this framework — 20 packages spanning November 2023 to March 2026, covering vaccination programme discovery, Welsh Immunisation System development, e-referrals, integration hub work, and data catalogue delivery.

The Registers Don't Even Match Each Other

There are now three separate FOI disclosures of DHCW's consultancy spending. They do not agree.

Contracts that appeared in the first FOI (5854154) but do not appear in the new register (6695599) include: InForm Solutions (£800,000 commercial advisor), La Fosse (£179,950 digital programmes), Deloitte (£237,680 board development and strategy), Ernst & Young (£135,000 VAT advisory), and over £1 million in Gartner research subscriptions.

These are all over the £50,000 threshold that FOI 6695599 specified. Yet they are absent from the new disclosure. Either DHCW no longer classifies these as consultancy, or the register provided is incomplete — consistent with DHCW's own caveat that "additional contracts will be provided in due course."

When an organisation's own FOI responses contradict each other, the problem is not a single missing contract. It is that no disclosure can be treated as authoritative.

The Categorisation Trick

Here is how DHCW keeps the number small.

DHCW's published accounts report £757,000 in consultancy. When asked how this is defined, they cited the Treasury's PES definition, which covers: General Management Consultancy, Legal, Human Resources, Financial, IT Consultancy, and Property Services — plus anything that "falls into the PES definition of consultancy."

That definition explicitly includes "advisory, design & developmental and implementation consultancy services." By any reading, that covers what Kainos does: design, development, and delivery of digital services.

But DHCW then cited the exclusion at PES paragraph 1.168: consultancy "as part of an ongoing contracted out service whose costs would be bundled into the running costs of the service is out of scope."

That single sentence is the mechanism. Call it a "contracted out service" and it is no longer consultancy. Call Kainos an "Agile Product Delivery Partner" rather than a consultant. Call the workforce framework "External Workforce Resources." The money goes out the door to external suppliers. The annual accounts show £757,000.

The result:

The published accounts capture 1.5% of the known total.

What Is Still Missing

Even after three FOI requests, a formal complaint, and multiple insider submissions, the full picture remains incomplete — by DHCW's own admission.

DHCW's caveat: "The attached spreadsheet contains the majority of these contracts relevant to this request. Additional contracts will be provided in due course, once we have verified the accuracy of their information." This is not CareNHS speculating that contracts are missing. It is DHCW confirming it.

CGI: The £249,973 contract does not explain insider accounts of ~10 consultants on-site for weeks, led by CGI's healthcare division CEO. The work may be routed through subcontracting arrangements or held by another body.

Mozaic: Insider described three engagements. Two disclosed. The third is unaccounted for.

Capacitas: Insider described two to three additional engagements beyond the original register. One additional now disclosed (WPAS Cloud Migration, £87,600). Others remain missing.

Contracts from the first FOI: Major contracts disclosed under FOI/5854154 — including InForm Solutions (£800,000), Deloitte (£237,680), La Fosse (£179,950), and Gartner subscriptions (£1.1 million) — do not appear in the new register. DHCW has not explained the discrepancy.

Actual spend vs. ceilings: The Kainos work packages show £20.6 million in actual spend against a £32.4 million contract ceiling. But actual spend under other contracts — Channel 3, KPMG, SPIRIT, the remaining workforce framework — has not been disclosed.

The Pattern

This is not a single disclosure gap. It is a system of progressive concealment — not necessarily deliberate in every instance, but structural in effect.

Step 1: Publish low consultancy figures in the annual accounts. Use the PES 1.168 exclusion to classify delivery contracts as "contracted out services" rather than consultancy.

Step 2: When asked under FOI for consultancy contracts, provide the register. This captures the smaller contracts — Gartner subscriptions, Deloitte board development, recruitment agency fees — but excludes the multi-million-pound delivery and workforce frameworks. If the first response is challenged, admit it was incomplete and provide a fuller version.

Step 3: When asked specifically about named suppliers, acknowledge them. Each answer is technically accurate. Each answer reveals a number larger than the last. Note that framework ceilings "do not represent a commitment to spend" — pre-emptively downplaying the figures. State that additional contracts will follow "in due course."

Step 4: Produce registers that do not match previous registers. Do not reconcile the discrepancies.

The effect is that no single disclosure ever shows the full picture. A Senedd member who reads the accounts sees £757,000. A journalist who files an FOI sees £8.94 million. A campaigner who files two more FOIs, naming suppliers, sees £49 million. And each of these figures is defensible in isolation — the accounts are compiled to accounting standards, the FOI responses answer the question as asked, the caveats are noted.

But the cumulative effect is that DHCW's true external commercial dependency — tens of millions of pounds flowing to Kainos, Channel 3, KPMG, TPXimpact, Trustmarque, CGI, and others — is invisible to anyone who does not already know which questions to ask.

An organisation whose published accounts show £757,000 in consultancy has paid £20.6 million to a single supplier. The Welsh public was not told this. The Senedd was not told this. You have to file three FOIs, lodge a complaint, name the suppliers yourself, and still be told the answer is incomplete.

What This Means

In our first article, we wrote that DHCW was paying twice — once for 1,200 permanent staff, and again for the consultants brought in to do the work those staff exist to do.

The new FOIs show it is paying three times: once for the staff, once for the consultants it acknowledges, and once for the delivery partners and workforce resources it classifies as something other than consultancy.

Kainos alone has been paid £20.6 million — more than twice the entire original consultancy register. They are the single largest commercial relationship DHCW has. And they were invisible until someone asked the right question in the right way.

Meanwhile, DHCW is paying £400,000 for Tektology to coach the board through the Level 4 escalation that resulted from the failure of the programmes all these consultants were advising on. And £4 million for KPMG to advise on cloud migration — on top of the £1.28 million KPMG has already been paid for NDR benefits realisation and advanced analytics that produced nothing.

Every one of the programmes these suppliers advise, deliver, or staff is now under Level 4 government intervention — the highest level ever applied to a non-health-board NHS body in Wales.

The question is no longer how much DHCW spends on external suppliers. We have been asking that question for a year, and each answer reveals a larger number. The question is why the Senedd, the Welsh Government, and Audit Wales have not asked it — or if they did, why they accepted £757,000 as the answer.

Final thought: the Board that has to pay £400K to external consultants to teach them how to reflect on their own failures is almost certainly beyond redemption.

This article updates and extends £8.94 Million on Consultants. Nine Programmes Still Failing, published 11 April 2026.

Right of Reply: CareNHS welcomes a response from DHCW to the matters raised in this article. No response has been received to date. Contact: carenhs@carenhs.org

Contract data is sourced from DHCW's FOI responses reference FOI/6695599 and FOI/6695741, both dated 28 April 2026, including the accompanying External Workforce Resources Framework Award Notice (WA Ref: 133661) and work package spreadsheets. Previous contract data from FOI/5854154, dated April 2025. Published accounts figure from DHCW Annual Report 2023/24. Where figures represent maximum contract values rather than confirmed expenditure, this is noted. Kainos actual spend figures of £20.6 million are derived from individual work packages listed in DHCW's own spreadsheets, not from framework ceilings. Insider submissions are identified as such and have not been independently verified beyond consistency checks against the public record.

CareNHS is an independent public accountability campaign focused on NHS Wales digital infrastructure. We welcome corrections and responses from DHCW, the Welsh Government, and any individual or organisation named in this article. Contact: carenhs@carenhs.org

Related pages:

• £8.94 Million on Consultants. Nine Programmes Still Failing — the first FOI disclosure
• DHCW Now at Level 4 — They Didn't See It Coming (Again) — the escalation nobody announced
• £600 Million In. £0.5 Million Out — the full funding picture
• £226 Million. 25 Minutes. No Risks to Escalate — how DHCW approved its largest single contract
• Try to Find Who Runs DHCW. You Can't. — the shadow workforce
• £207,100 to Hear the Truth — Then They Buried It — the stakeholder review only 13.3% endorsed