Healthcare Improvement Scotland: independent healthcare fees consultation

Closed 11 Dec 2023

Opened 16 Oct 2023

Feedback updated 1 May 2024

We asked

Effective regulation of independent healthcare is an important element in supporting public safety. We asked if you agreed that the regulation of independent healthcare services should continue to be funded through fees charged by HIS to private providers. We also asked if, given the increasing costs required to regulate independent healthcare, you agreed that the proposed maximum fees HIS can charge, as outlined in the consultation, was required. Finally, we asked, If you do not agree with the proposed maximum fee adjustment, what alternative approaches or strategies you believed would be fair and effective, and how should HIS address the challenges of the rising costs while minimising the impact on their stakeholders.

You said

We received 105 responses, of which 83 were from individuals and 22 were from organisations. The majority of respondents identified themselves as being affiliated with an independent healthcare service, either identifying as the owner or working for such businesses. The responses we received showed a fairly even split between those who agreed that the regulation of independent healthcare services should continue to be funded through fees charged by HIS to private providers (46%) and those who did not (53%). 83% of respondents did not agree with the proposed maximum fees that HIS can charge for the commencement of the regulation of independent medical agencies. 87% of respondents did not agree that the increase to proposed maximum fees HIS can charge, as outlined in the consultation, is required given the increasing costs required to regulate independent healthcare. 50% of respondents who elected to add additional information suggested that non-healthcare professionals should also be registered with HIS. 34% of these respondents felt that fees should be based on the size of the business.

We did

We have published all non-confidential responses to our consultation and the analysis of these responses. Direct links to these publications can be found below.

The response to the proposals was considered by Scottish Ministers. It was decided that the proposals are essential to ensure effective regulation of independent healthcare, which ensures public safety. It is vital that HIS has the necessary resources to fund its regulatory responsibilities, but in response to the large majority of respondents who did not agree with the proposals, we are proposing a reduced maximum fee cap in a number of areas. Further information can be found in our government response to the consultation analysis.

Published responses

View submitted responses where consent has been given to publish the response.

Overview

Independent hospitals have been regulated by Healthcare Improvement Scotland (HIS) since 1 April 2011 and from 1 April 2016, independent clinics where services are provided by a medical practitioner, dental practitioner, registered nurse, registered midwife or dental care professional have also been regulated by HIS.

Following a consultation in early 2023 on various aspects of the regulation of independent healthcare services, we intend to amend current regulations in order to:

  1. regulate independent healthcare services provided by pharmacists and pharmacy technicians which are not provided under the terms of an NHS contract or from non-General Pharmaceutical Council (GPhC) registered premises;
  2. regulate independent medical agencies providing healthcare services which consist of or include the provision of services by a medical practitioner, dental practitioner, registered nurse, registered midwife, dental care professional, pharmacist, or pharmacy technician. This would include independent medical agencies operating entirely online. 

Read the Regulation of independent health care amendments: consultation analysis 

This further consultation is required to ensure that the fees required for the effective regulation of independent healthcare services is fairly implemented.

Read the consultation paper. The consultation paper contains full background information for this consultation. You may find it useful to read or refer to while responding.

Useful information about responding to this consultation

As you complete your response, each page will provide the option to 'Save and come back later' at the bottom. This means you can save your progress and return to the consultation at any time before it closes. If you don't use this feature and leave the consultation midway through, your response will be lost.

Once you have submitted your response, you can enter your email address to get a pdf copy of your answers sent to you.

On the 'About You' page at the end of this consultation, organisations will have the opportunity to tell us more about their work and/or how their response was informed.

After the consultation has closed there will be a few months delay before any responses are published. This is because we must check any responses to be published abide by our Terms of Use.

A analysis report will usually be published some months after the consultation has closed. This report will summarise the findings based on all responses submitted. It will be published on the Scottish Government website and you may be notified about it if you choose to share your email address with us. You can also join our consulation mailing list where we regularly list newly published analysis reports (as well as new consultations).

 

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