Select Committee on Health Minutes of Evidence

Memorandum by Independent Healthcare Association



  1.  The Independent Healthcare Association welcomes the Health Select Committee's inquiry into the regulation of independent healthcare. The Association hopes that this inquiry will help form government policy, and deliver regulatory reforms that IHA has long campaigned for and our members long desired.

  2.  The mainstream independent healthcare providers are committed to delivering the highest standards of care, and to demonstrating that they deliver the highest standards of care. A good regulatory system should support this commitment and help to spread best practice across the entire UK healthcare sector. A good regulatory system would also ensure that should any provider in whatever part of the UK healthcare system not be delivering high standards of care they improve or cease to operate.

  3.  IHA members are proud of the service they provide and the quality of care they deliver. The right regulatory system would help all providers to continuously improve and ensure that patients are confident that they will receive the care they need and deserve.

  4.  In this evidence, the IHA sets out:

    —  Steps IHA members have taken to ensure quality of care and good complaints handling;

    —  The Association's experiences of the current regulatory system;

    —  The principles and options that our experience suggests should apply to a new system;

    —  Areas of provision overlooked by the current regulatory regime.

  IHA's evidence was developed with the assistance of a steering group, to ensure that the evidence presented is representative of the views and experiences of IHA's members. The steering group membership is listed in Annex 1[1].

  5.  The evidence looks at the issues specific to different types of providers as well as considering the general issues common to all.

  6.  Some factual background information on the Association, the independent healthcare sector, and the current regulatory system is included in annexes to this memorandum, for the Health Committee's further information.

What is the Independent Healthcare Association?

  7.  The Independent Healthcare Association (IHA or the Association) is the representative association of independent health and social care providers. Its members include acute hospitals, psychiatric hospitals, nursing homes, and residential care homes.

  8.  The IHA was formed in 1987 by the merger of two earlier associations. It is a registered charity (296103), incorporated under the Companies Acts (2082270), being a company limited by guarantee not having a share capital.

  9.  The principal activities of the Association are to promote and protect standards of healthcare in the independent sector. In addition, the Association acts as a forum for discussions among independent health and social care organisations.

  10.  The Association maintains consultation with Government and other bodies on the provision of medical, nursing and social care within the United Kingdom; analyses and disseminates information to members; promotes knowledge of the independent sector to the general public and encourages the right of individuals to choose independent care.

  11.  Independent hospitals, mental health hospitals and care homes are already a major part of the nation's health and care services. Rather than work in isolation from the public sector, the IHA and its members believe the future lies in partnership. Agreements between the public and independent sectors already offer purchasers access to a wide range of high quality, best value services not available elsewhere.

Who are the IHA's members?

  12.  IHA's membership ranges from services run by trade unions, friendly societies and charities, to services provided by—large and small—commercial organisations. IHA represents health and care providers who, in total, operate over 80,000 beds and have an annual turnover of almost £3 billion.

  13.  There are three main groups of IHA members:

    —  Acute Hospitals: representing over 9,000 acute beds in 175 hospitals, the IHA Acute group includes all the main independent hospital operators and in total about 90 per cent of the UK's independent acute hospital provision. IHA members provide a full range of elective hospital services, from the simple to the complex. Independent acute hospitals treat millions of people and perform nearly1 million surgical procedures each year, mostly privately funded.

    —  Mental Health: representing over 1,600 beds in acute psychiatric hospitals and substance misuse units. These 24 units comprise two thirds of the total independent acute mental health provision. Independent mental health providers are major suppliers to the NHS. For some types of service, the independent sector supplies the majority of the NHS's requirements.

    —  Community Care: representing over 70,000 nursing home and residential care home beds, IHA is the largest association of care homes in the UK. IHA represents the major corporate and not-for-profit groups, along side smaller homes. The majority of care in independent homes is publicly funded via local authority social services departments, the NHS and social security benefits.

  14.  The IHA membership also includes providers of home care services, pathology laboratories, screening units and a host of other associated health and care companies. The Association's main member organisations are listed in Annex 2.

  15.  Overall the entire independent health and social care sector, including acute and mental health hospitals, home care and nursing and residential care homes employs more than 750,000 people. Beyond that, independent provision is as much a vital part of the UK's successful healthcare strategic cluster as are the NHS or pharmaceuticals companies. The UK is a world centre of excellence in healthcare and the independent sector is an integral part of that.

The scope of the Health Committee inquiry

  16.  In considering its evidence, IHA concluded that the potential range of services covered was so great that the Association would have to make some assumptions about the areas of interest to the Committee. The areas on which this memorandum focuses are:

    —  Mainstream independent acute medical/surgical hospitals.

    —  Mainstream independent mental health services.

    —  Acute healthcare services that can fall outside current regulations, such as cosmetic surgery, NHS private patients units, private ambulances, and professional consultations.

  17.  IHA uses the term "independent healthcare" to encompass all non-public sector healthcare provision. None of the other terms have sufficient or agreed scope. The term "private" is inadequate to the task: the NHS supplies some private healthcare, and the independent sector provides NHS services under contract. Further, some independent providers do not consider themselves to be "private sector". IHA uses "private healthcare" to refer to the commercial supply of healthcare to paying clients.

  18.  IHA understands that there is a small amount of non-NHS public sector healthcare, such as Ministry of Defence hyperbaric services, but this is outside our experience and this evidence.

  19.  IHA estimates that the total turnover of a broadly defined UK independent health and social care sector is nearly £17 billion (see Exhibit 1, compiled from various sources). With all the complexities of the health and social care sector this figure can only be a rough estimate, but it represents about 25 per cent of all UK health and social care spending.

£m£m £m£m

Acute medical/surgical1,250 Dentistry230
Acute mental health94 Ophthalmics790
Other81 Private GP services315

Independent hospital revenue 1,425Complementary medicine 570
Specialist fees631631 Pharmaceuticals etc.3,120

Total acute healthcare 2,056Total other direct healthcare 5,025
Nursing and care homes6,917 6,917Independent medical research 2,5002,500

Total independent health and social care 16,498

  20.  Nursing homes are covered by clear Government initiatives, outlined in the White Paper, Modernising Social Services, which moves in the direction IHA has long sought. Other initiatives include National Required Standards, Best Value, the Long-term care charter, and the Royal Commission on long-term Care. IHA understands that nursing homes are not the main focus of the Committee's interest in this inquiry. Some background on nursing homes and new social services regulatory proposals is presented in Annex 3.

  21.  Should the Committee choose to look into nursing homes in detail the IHA has a similar wealth of experience in that area. The same is true of most other aspects of independent care provison, or issues related to it, although the Association would need the opportunity to consult with members and collate information.

  22.  Exhibit 2 shows some of the range of services that comprise "healthcare outside the NHS". The most basic division for the purposes of this memorandum is between those services where the standard of care and service is directly regulated and those where it is not. There are of course many indirect regulatory mechanisms, such as professional registration.


Directly RegulatedNot Directly Regulated

Acute Medical/Surgical
Independent hospitals, covering full range of services including:
  —  cardiac surgery
  —  neurosurgery
  —  oncology and radiotherapy
  —  reconstructive plastic surgery
  —  orthopaedics and general surgery
  —  ITU and HDU
Lasers of class 3B or 4
Termination of pregnancy
IVF and other HFEA regulated
Minor surgery in professional premises (eg minor cosmetic services, GP practices, and dental surgeries)
NHS paybeds and private patient wings within NHS hospitals
Lasers of class 1, 2 and 3A (when outside independent hospitals)
Free-standing clinical support services, eg pathology, MRI, CAT scans etc
Health Screening outside of hospitals
Independent consulting practice by healthcare professionals
Mental Health
Independent mental health homes
and hospitals, including:
  —  acute mental illness
  —  medium secure
  —  learning disabilities
  —  brain injury rehabilitation
  —  substance misuse rehabilitation
  —  eating disorders
  —  elderly mentally ill
Substance misuse clinics registered only as residential homes
Nursing Care
Nursing Homes, including:
  —  care of the elderly
  —  physically disabled
  —  palliative care
  —  degenerative conditions
Dual registered homes
Nursing Agencies
Primary Care and/or community services
Domiciliary care
Day-care centres
Sheltered housing and "housing with care"
Private General Practitioners
Walk-in primary care services
Complementary medicine
Retail pharmacy/chemists
Private ambulance services

1   Annexes not printed. Back

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Prepared 14 May 1999