Memorandum by Independent Healthcare Association
THE REGULATION OF PRIVATE AND OTHER INDEPENDENT
SECTION 1: OVERVIEW
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
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.
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
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 bylarge and smallcommercial organisations.
IHA represents health and care providers who, in total, operate
over 80,000 beds and have an annual turnover of almost £3
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
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
Mainstream independent acute medical/surgical
Mainstream independent mental health
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.
EXHIBIT 1: TOTAL UK INDEPENDENT HEALTH AND SOCIAL
CARE SUPPLIED, 1997-98
|Acute mental health||94
||Private GP services||315||
|Independent hospital revenue||
|Total acute healthcare||
||2,056||Total other direct healthcare
|Nursing and care homes||6,917
||6,917||Independent medical research
|Total independent health and social care
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
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.
EXHIBIT 2: DIRECTLY REGULATED AND UNREGULATED HEALTH SERVICES
|Directly Regulated||Not Directly Regulated
Independent hospitals, covering full range of services including:
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
Independent mental health homes
and hospitals, including:
acute mental illness
brain injury rehabilitation
substance misuse rehabilitation
elderly mentally ill
Substance misuse clinics registered only as residential homes
Nursing Homes, including:
care of the elderly
Dual registered homes
Primary Care and/or community services
Sheltered housing and "housing with care"
|Private General Practitioners|
Walk-in primary care services
Private ambulance services
Annexes not printed. Back