APPENDIX 17
Supplementary memorandum by General Healthcare
Group (PS 9A)
General Healthcare Group (GHG) welcomed the
opportunity to provide oral evidence to the Committee to assist
with its Inquiry. This note provides some additional thoughts
on key areas that were explored in the oral session.
STAFFING ISSUES
It is important that the impact of private sector
recruitment on staffing levels in the NHS is not misunderstood.
GHG firmly believes that private sector recruitment has, at most,
only a marginal impact. Yet private sector staff (along with other
factors that cumulatively create private sector capacity) can
realise significant additional capacity for the NHS.
The ability of the NHS to treat patients is
not simply a factor of staffing levels. However, staff levels
are nevertheless an important component in determining NHS capacity.
With this in mind, it is crucial to appreciate that the majority
of staff leaving the NHS do not join the private sector. They
leave healthcare altogether. The staffing needs of the private
sector are not a significant reason for NHS staff shortages. Rather,
many of the problems of NHS nurse recruitment and retention lie
within the NHS itself. However, the private sector should not
be complacent. It is important that, where it can, the private
sector should bring new capacity to the NHS without constraining
existing NHS operations. This should include considering how it
can further minimise the impact that it has on nurses leaving
the NHS.
With this in mind the Committee might note that
GHG estimates that it could double its capacity to treat NHS patients
while relying on existing facilities and without increasing its
staffing levels. This would be achieved by the flexible deployment
of existing staff resources to maximise GHG's ability to treat
patients.
As staffing concerns are of such significance,
GHG is also examining ways that it can increase its recruitment
of key clinical staff from other parts of the European Union.
It is also looking at the ways in which the Government has sought
to encourage nurses who have left the profession to come back
into the NHS to see how it might attract these health workers,
who otherwise might be lost to the UK healthcare systems altogether,
into its employment. We believe that while some nurses might wish
to return to the NHS, others may want to rejoin the health economy
but not in the public sector. Maximising the opportunities for
ex-nursing staff to return to either the public or private sector
should help ease staffing pressures in the NHS and over the long-term
increase capacity—especially if the private sector is helping
the NHS deliver care to patients.
PRIVATE SECTOR
QUALITY CONTROL
NHS purchasing of services from the private
sector must be accompanied by confidence from both purchasers
and patients that demonstrably high standards are employed by
non-NHS providers. In the long-term the question of quality standards
will be addressed through monitoring by the National Care Standards
Commission (NCSC). Nevertheless, there are important areas that
need to be considered. These involve monitoring of standards for:
— UK providers during the NCSC's transitional
period (as it moves to fully assume its monitoring functions from
1 April 2002); and for,
GHG believes that these considerations should
be a key priority in developing links between the NHS and the
private sector. If effective long-term partnership between the
NHS and private sector is to be established, it is vital that
these arrangements are based on sound foundations of high quality
provision. It would be unfortunate if confidence in the value
of co-operation was to be undermined because proper quality assurance
systems were not in place in the early stages of the process.
Although responsibility for monitoring UK providers
will shortly be taken on by the NCSC it is clear that the assumption
of these powers is the very first step in establishing a more
robust regulatory regime. In the first instance providers will
simply undertake to meet the standards expected by the NCSC. Until
a particular facility has been inspected by the NCSC there cannot
be complete confidence that it meets the minimum standards required.
The NCSC faces a substantial challenge in undertaking
its initial assessments. The sheer scale of the task it faces
is key in this. It will not only be covering private and voluntary
hospitals but also a range of other providers, such as private
care homes, children's homes, voluntary adoption agencies and
day centres. It will have to inspect many facilities with relatively
limited resources. This means that it is unlikely to have inspected
all facilities within its remit until some time has elapsed.
Until the system is fully established GHG recommends
that there should be transitional arrangements put in place to
help ensure that private providers working for the public sector
are working to the standards required by the NHS. A number of
approaches could be adopted to ensure this:
— Private facilities intending to provide
services for the NHS could be designated as priority facilities
for NCSC inspection. However, if this is not a viable option,
then:
— The NCSC should prioritise inspection
of those private facilities that have not achieved independent
quality standards. It is the case that quality standards vary
between private providers (the same is true within the NHS). The
pursuit of best practice has led some providers to seek independent
accreditation of their facilities. This has included achieving
Health Quality Standards (HQS) or ISO accreditation, for instance.
Both of these measures are strong and objectively measured indicators
of service quality, although in fact General Healthcare Group
has secured accreditation for its units under the HQS scheme,
under which facilities have to meet 2,500 mandatory and 2,500
best practice quality standards and successfully complete a 3-day
independent inspection. There is a very significant overlap between
this standard and the regime that will be implemented by the NCSC.
Regrettably, this is not the position for all accreditation schemes
which are available, and in particular schemes such as HAP where
the depth and breadth of coverage of standards is materially less
and the survey process must less extensive. Facilities complying
with accreditation standards such as HQS are less likely to be
vulnerable to quality concerns that those which are not accredited.
As it establishes itself the NCSC should focus its attention on
providers most likely to have compliance problems with the standards
required under the Care Standards Act. It should use compliance
with independent assessment regimes as a guide to prioritising
the inspection of private facilities providing services to the
NHS.
— Quality control should also be addressed
by the development of guidelines for NHS purchasers. These would
focus purchasers' attention in the first instance on whether or
not NCSC inspection has been undertaken for the facility they
are considering making a purchase from. In the absence of an NCSC
inspection it should emphasise the importance of independent quality
accreditation (such as HQS and ISO compliance). Failing such assessment
there should be guidelines on how purchasers might make their
own assessments of quality of services provided.
(Once the NCSC system is bedded-in GHG would
expect the priority of inspecting facilities to be the same. These
recommendations are designed to address transitional concerns).
Quality monitoring for overseas providers is
a more difficult issue to resolve. GHG would envisage that NHS
purchasers would make independent assessments of the quality of
the services available. However, GHG recommends the Department
of Health should consider the value of creating a standards registration
and inspectorate service for overseas providers wanting to take
on NHS work. In the long term this could significantly reduce
the costs to individual purchases and make treatment abroad subject
to standardised quality control.
CONCLUSION
The issue of quality monitoring for private
sector providers is an important one that should be a priority
for the Department of Health. In particular, it might be an area
that the NHS Modernisation Board should consider in more detail.
GHG would be pleased to provide more information
on the points raised in this memorandum if it would be helpful
to the Committee.
January 2002
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