Memorandum submitted by HSA Group Ltd
1.1 The HSA Group Limited is a mutual organisation
based in Andover, Hampshire. The HSA Group also includes Leeds-based
health plan provider LHF (The Leeds Hospital Fund), Manchester
based HealthSure and Bristol-based BCWA. As its early name (Hospital
Saving Association) implies, HSA was originally established in
1922 to help save hospitals from closure in the pre-NHS days.
1.2 The HSA Group provides health cash plan
insurance, known as Health Cash Plans (HCP), which in essence
provides cash benefits to cover the cost of health care treatment,
expenses associated with hospital treatment and post operative
care. Our plans aim to meet the cost of everyday healthcare, with
cash benefits covering a broad spectrum of treatments such as
optical, dental, osteopathy, chiropractic, complementary therapies,
consultation, health screening, chiropody, physiotherapy and hospital
in-patient stay. Today we are the largest mutual HCP provider,
covering in excess of 1.1 million policyholders, providing health
cover for more than two million people across the UK.
1.3 In 2004 we paid claims to the value
of approximately £166 million, projected to rise to over
£200 million in 2005, to our members, of which a very substantial
amount related to the accessing of NHS provided healthcare. The
HSA Group therefore welcomes a new inquiry into co-payments and
charges in the NHS.
1.4 Any evidence submitted or recommendations
for action are based on most accurate and up to date information
available to us, as well as information received from members.
2 THE HEALTH
2.1 Equitable and appropriate charges
2.1.1 Our main areas of activity, relating
to the co-payment and charges in the NHS referred to in the terms
of reference of the inquiry, are treatments (day surgery and hospital
in patient stay), dentistry and optical services. These items
of benefit (as referred to in HCP terms) form the common denominators
of most packages of benefit offered across the HCP market. These
items of benefit achieve a combined figure of 73% of the total
value of benefits paid across the HCP market, representing a substantial
proportion of member activity. (Laing & Buisson UK Health
& Care Cover 2005.)
2.1.2 The number of lives covered in the
UK by HCP and Private Medical Insurance (PMI) would lead us to
conclude that significant proportion of the general public is
able and willing to take appropriate measures in order to reduce
the impact on their personal cash flow of the NHS charges or co-payments
2.1.3 Such charges can only be regarded
as equitable and fair in an environment where the service user
perceives the cost incurred as affordable and proportionate in
relation to the service received and the level of personal responsibility
2.1.4 We would encourage fair and equitable
charges, consistently applied. A possible example of such an instance
is the proposed dental patient charges (as set out in the Consultation
of the draft National Health Service (Dental Charges) Regulations
2006) which would appear to be a step in the right direction for
the patient, as it attempts to simplify and introduce a fair and
equitable charging system, as well as defining the instances of
exemption from charges.
2.1.5 As the NHS is subject to rising costs
due to a number of well-documented reasons and the demand for
access to a widening range of services are increasing year on
year, it is felt that the charges are broadly speaking not inappropriate.
It is appreciated that organisations representing specific interest
groups may highlight areas of inequity or inappropriate charging.
2.2 Optimal level of charges
2.2.1 It would not be considered appropriate
for the HSA Group to speculate as to the optimal level individual
charges should be set at, as this does not lie within our remit
to do so.
2.3 Transparency of system of charges
2.3.1 Based on our experience (tens of thousands
of customer interactions on a daily basis) we would suggest that
not all charges are sufficiently transparent to the general public.
An example would be the current system of dental patient charging,
which has been recognised as lacking in transparency.
2.3.2 A question of transparency to the
service user also arises in the event of private sector involvement
in the provision of a service. In this instance a concise, plain
language communication of what is "covered" or chargeable
by the NHS will aid tremendously to the publics understanding
and ability to exercise choice.
2.3.3 Transparency is only achievable as
a consequence of openness, consistency and education. We would
encourage these principals to be applied to all areas of charging
and co-payments throughout the NHS.
2.4 Criteria for payment and exemption
2.4.1 Affordable shared responsibility are
the criteria we would propose for the determination of payments.
Payments should be affordable to all and payments should be applied
to all, as this is a fair and equitable way of encouraging publicly
shared responsibility. Government intervention is suggested in
the instances of disaster and an element of means testing or exemption
should be applied for the elements of society unable to contribute.
2.5 Awareness of eligibility of exemption
2.5.1 The Financial Services industry is
regulated by the Financial Services Authority, who places regulatory
requirements on financially regulated organisations, in order
to protect the interest of customers. As co-payments and charges
in the NHS may impact on people who could be perceived to be more
vulnerable than they normally would be, at the moment of interaction
with a NHS service, a code of self regulation, in reference to
the fair treatment and transparency of co-payments and charges,
subscribed to by all providers of NHS services (as described in
the terms of reference to the new inquiry) is suggested.
2.6 Abolishment of charges
2.6.1 The abolishment of charges could place
a greater burden on the NHS and would not encourage the acceptance
of personal responsibility for being able to access healthcare.
3.1 A broadening of charges or the establishment
of an affordable shared responsibility premise based charge, with
Government intervention in cases of disaster or "means tested
need" is recommended.
HSA Group Ltd