An internal Department of Health report on health inequalities warned about barriers to migrants accessing care, only a month before the government announced it would extend charges for them, it has emerged.

NHS England has also raised concerns with the DH about the issue, HSJ understands.

The report for the DH health inclusion board, on barriers to primary care for vulnerable groups, has not been published. However, it was discussed at that committee’s June meeting.

The minutes of the meeting said: “Despite improvements [in GP registration among vulnerable groups], homeless people, asylum seekers and other transient groups are still frequently being refused registration by GP practices.

“Information suggests registration is a particular barrier for migrants or those with perceived ‘irregular’ immigration status.

“There is a continued misunderstanding about immigration status and entitlement and confusion about whether proof of address is a requirement.”

In July the DH began consulting on plans to extend charges for migrants, including fees for primary care. While some vulnerable groups would be exempt from the proposed changes, they would mean some are eligible for charges, as well as more complex checks and requirements.

The health inclusion board has not responded to the consultation. Its chair Steve Field, who is also Care Quality Commission chief inspector of primary care, told HSJ the issue of migrant charges was complex, and he did not have an overall view.

However, he said: “We need to make sure GPs are not dissuaded from looking after the most vulnerable, and we don’t put up barriers which keep people away [from GPs].”

The DH proposals say that “needs and interests of vulnerable or disadvantaged patients including the homeless, travellers and those who are lawfully resident but may not have documentation should be protected and not be charged”.

However, a consultation response by homelessness charity St Mungo’s, which sits on the inclusion board, says exempting groups would “prove extremely challenging” in practice.

St Mungo’s opposes the proposals and said they “will result in higher costs to health services as treatment is only sought when health problems have progressed to the extent that expensive accident and emergency services are required”.

Meanwhile, HSJ understands NHS England has also raised concern about vulnerable people being put off accessing care. It has highlighted the potential cost of implementing charges, and said these should be kept low.

The DH has not estimated the cost of implementing the policy. However a 2012 DH review said: “The NHS is not currently set up structurally, operationally or culturally [for] identifying a small subset of patients and charging them for their NHS treatment. Only a fundamentally different system and supporting processes would enable significant new revenue to be realised.”