The controversial digital first provider, which has now registered more than 60,000 patients living or working in London and Birmingham, is predicting 'significant further expansion'.
In its response to a consultation on digital services in the NHS, the provider said it had already registered more than 1,000 patients from 18 of London's CCGs - and more than 2,000 from 13 of them.
It predicted that 'it will not be long before almost all London CCGs have over 1,000 residents registered with Babylon GP at Hand'.
Digital first GPs
Under proposals set out by NHS England in the consultation document, digital first providers could be forced to set up physical premises in any CCG area from which they recruit more than a threshold number of patients - potentially 1,000 to 2,000 patients.
The plans could also introduce a mechanism that would award a separate APMS GP practice contract once this threshold was passed, separating patients from this area into a new patient list.
This could see Babylon GP at Hand forced to set up practices in dozens of CCG areas as its service expands - a move backed by GPs in a recent GPonline opinion poll.
But the provider has argued that setting up clinics with a patient list of 1,000 patients would not be sustainable.
'For the principle to be manageable for digital first providers operationally and financially,' its consultation response said, 'the geographical unit of classification would need to change'. It called for new physical premises to be required not at CCG level, but at the far larger strategic health partnership (STP) or integrated care system (ICS) level.
The provider argues that this would limit the number of new APMS contracts awarded and allow new digital first services to operate on a larger scale.
Babylon has also called for the out-of-area patient registration mechanism that has allowed its list to grow rapidly to be retained - despite calls from the BMA for it to be scrapped.
The service has also objected to proposals from NHS England that an additional payment awarded to practices when they register a new patient should only be paid if they remain registered for a defined period. GPonline revealed earlier this year that one in four patients who signed up with Babylon GP at Hand between November 2017 and January 2019 subsequently quit the service.
This was later confirmed in a report by Ipsos Mori on the service - which also found that the service had attracted predominantly young, wealthy patients who were above-average users of healthcare services despite being relatively healthy.
The BMA has called for more support for all practices to improve their digital offering, a move it says would 'mean there was no need to create new practices' operating on a digital first model.
The BMA has also warned that any attempt to use digital first providers to plug gaps in services in underdoctored areas threatens to create a two-tier NHS service.
Babylon, however, calls in its consultation response for incentives to 'encourage digital first providers to bring additional capacity' to underdoctored areas. It proposes a 'capacity and quality premium for providers able to demonstrate that they have brought additional capacity to underdoctored areas, improved access and been shown to reduce overall costs to the NHS'.