Paying patients transparency disclosure

An investigation by the Competition and Markets Authority (CMA) in 2014 brought greater focus to the lack of transparency and information available for private patients in the UK.

The CMA investigation found that patients do not have access to sufficient information to make informed choices when considering private healthcare. In response, they published the Private Healthcare Market Investigation Report and subsequent Order, available to view at gov.uk.

The Order imposed a legal duty on hospitals to submit data to a CMA appointed Information Organisation (IO). The Private Healthcare Information Network (PHIN) was approved in this role with a mandate to publish the required 11 performance measures online by hospital and consultant.

The CMA Order legally obliges ‘every operator of a private healthcare facility’ to send data to PHIN. This includes:

• private or independent hospitals and clinics
• cosmetic hospitals and clinics
• NHS hospitals treating private patients (be that in a dedicated unit or otherwise)

There is no minimum number of private patients treated for the Order to apply to a facility.

Facilities that are not covered by the Order include:

• outpatient consultation and diagnostic facilities
• mental health hospitals and clinics
• assisted conception clinics
• pregnancy termination clinics
• physiotherapy facilities

To establish a robust process to deliver the best possible data PHIN has engaged with private providers, NHS trusts, CQC and clinicians. This has resulted in a number of documents and process to ensure the safety of patient information including the PHIN Privacy Notice and Information Governance Policy. As part of this process the Trust is required to provide data on all private patients either trust managed or consultant managed. This in turn has required a number of changes to be made to our standard administration process for paying patients.

Fee Disclosure (Article 22.2 to 22.7)

As part of the new processes all patients should receive a letter from the treating consultant or the trust detailing the consultant and trust fee’s prior to attending the hospital. The trust is required to confirm the receipt of this information with the patient/parent and we will do this either by email or in person if ward attending.

Service Provision (article 16.2; 17.2; 17.3; 19.; 19.2 & 19.3)

Under these articles the hospital needs to disclose if we are providing any direct services or support to the consultants in private practice.

At present the only service being provided is room rental for consultants at a rate of £15 per patient to cover the costs incurred by the trust.

Consultants also have to disclose if they have any financial interests in the private facility but as we are an NHS Trust none of our clinicians have any financial interest in our facilities or equipment.