The Health Committee inquiry
The Independent Healthcare Association (IHA)
and its members welcome the Health Committee's inquiry. The Association
hopes that this inquiry will stimulate legislative reforms to
give UK healthcare a coherent and effective system of regulation.
The Association's members believe in the quality
of care and quality of service they deliver. The right new regulatory
system could help providers to ensure that patient's can be confident
in independent healthcare providers.
The independent sector is a major provider of
healthcare in the UK, a large employer, and a vital part of the
UK's strategic healthcare cluster.
The evidence covers acute medical/surgical hospitals,
mental health hospitals, and gaps in the regulation provided by
the Registered Homes Act 1984.
Acute medical/surgical hospitals
There are nearly 11,000 independent acute medical/surgical
beds in the UK. Of the 850,000 patients operated on per year,
70 per cent is funded by medical insurance, 20 per cent is privately
self-paid and 5 per cent is NHS funded.
Typically, independent hospitals grant practising
privileges to self-employed consultants. There are some exceptions
where a hospital directly employs consultants.
The Independent Healthcare Association has a
raft of initiatives to build a coherent system of clinical governance
for the independent sector. This includes quality assurance, clinical
governance and audit frameworks, and complaints handling and independent
The vast majority of Independent Healthcare
Association member hospitals already have independently certified
quality assurance schemes. The remainder will have by the end
of 1999. More independent hospitals have achieved King's Fund
Health Quality Service Full Accreditation than NHS hospitals.
The revised and strengthened Independent Healthcare
Association Code of Practice on Patient Complaints is currently
out for consultation with consumer and patient groups. IHA is
implementing a mechanism for the independent review of unresolved
There are many influences on independent hospitals
that encourage them to deliver a high standard of care, of which
regulation is but one. At present the Registered Homes Act 1984
is not making a significant positive contribution to quality of
care. There are serious flaws with the structure and operation
of the regulatory system of the Act.
Mental health hospitals
There are nearly 2,500 independent acute psychiatric
and substance misuse beds in the UK. A substantial proportion
of their services are supplied under contract to the public sector
as "ECRs" or longer-term arrangements. These units often
directly employ consultant psychiatrists.
Psychiatric and substance misuse providers are
registered under the Registered Homes Act 1984, and also may come
under the Mental Health Act 1983. The Mental Health Act system
is integrated across the NHS and the independent sector and appears
to work well.
Medical insurers and NHS purchasers also exercise
oversight. Mental health members of the Independent Healthcare
Association are committed to independent quality assurance systems
and are signed up to a Code of Practice.
Services outside direct regulation
The current healthcare regulatory system has
gaps, which include NHS private patient facilities, some cosmetic
surgery, other minor surgery in unregulated premises, isolated
professional practice (including complementary medicine), some
substance misuse clinics registered as residential homes, and
The regulatory system should cover all independent
healthcare providers, unless there are clear and defined reasons
to the contrary.
New regulationsprinciples and options
Some of the principles for a new regulatory
system should include:
Fitness for purposeprotecting
patients and enhancing their rights
Full coverage of the healthcare sector
Culturally oriented towards healthcare
Regulate organisations and people
Integration for quality standards
and good practice
Differentiation of management and
The Independent Healthcare Association supports
the extension of the Health Service Commissioner's remit to cover
not just NHS commissioned independent care but all independent
healthcare. There are some technical difficulties with such a
proposal but they could be overcome. This would provide an extra
layer of review over the independent sector's own complaints handling
and independent review systems.
The Independent Healthcare Association's preferred
option would be NICE and CHI being implemented for both the NHS
and the independent sector. Alternatively, there should be a new
national regulatory or self-regulatory body for independent healthcare.
Independent healthcare providers are demonstrably
committed to delivering the highest quality of care, and would
welcome moves to create a regulatory system that did more to support
that goal. IHA very much hopes this Inquiry will help that to