Should private consultants fees be published online? Consultants, hospitals and patients all have an opinion on the issue of fee transparency. But despite a legal challenge, the Competitions and Markets Authority (CMA) have ruled that they will be published. And the burden is primarily on consultants to provide fee transparency. In March 2017, the CMA announced that fees will be published online by April 2019. The Private Healthcare Information Network (PHIN) will gather and publish information on consultant fees.
Consultants fee transparency to patients
In addition to the information PHIN will ask for, consultants working at private hospitals must also supply information directly to patients before a consultation, test or treatment. This applies to consultants who refer patients for treatment or tests and those who have practising privileges at a private hospital. Consultants must give details of fees, estimated costs and a list of recognised insurers amongst other information. Private hospitals should provide consultants with a template letter to do this.
It has been compulsory to provide this information before an outpatient consultation since December 31, 2017. From February 28, 2018, consultants must supply the relevant information to patients before further treatment or tests. All of these requirements stem from Article 22 of the Private Healthcare Market Investigation Order 2014.
Investigations into private healthcare
The shakeup of the private healthcare market has been happening for many years, and we can now see the full extent of the additional regulatory requirements for private providers. Both the Office of Fair Trading and the Competition Commission (now part of the Competitions and Markets Authority) have conducted investigations into private healthcare in recent years. Both investigations were led by concerns that private healthcare was not as accountable as the NHS. The British Orthopaedic Association’s briefing for its members provides an excellent background summary.
The Competitions and Markets Authority (CMA) reported that private patients didn’t have sufficient access to information in order to compare quality and cost. Their report in 2014 provided a number of ‘remedies’ which PHIN are putting into practice. All private healthcare providers have to provide PHIN with performance information including lengths of stay, mortality rates and readmission figures. This is all detailed in the Private Healthcare Market Investigation Order 2014.
The impact on private consultants
Whilst private hospitals are responsible for ensuring their consultants provide information to patients, the primary burden falls on consultants. Medical support staff such as medical secretaries should be able to assist with additional paperwork, as they are already familiar with other regulatory tasks.
Designated Medical can provide flexible medical secretary support on a monthly plan or PAYG basis, so let us help!
You spent many years as the Group Medical Director at BUPA before joining PHIN, what attracted you to your current role as Chairman at PHIN?
I retired about 5 years ago from BUPA and then moved on to do non-executive work. One of the areas I was involved in when I was with BUPA was the question of clinical governance, data collection and outcome measurements and for many years I have been talking within the private sector about the need for transparency and for more information to be made available to consumers.
In particular, I was very involved with the whole question of encouraging outcome measurements involving patients directly. I chaired the Department of Health patient reported outcomes group which supported the development of that programme.
Knowing the work I was doing, Matt James, our Chief Executive asked very early on if I could now take on the Chairmanship of PHIN, and I was delighted to do so. This was a continuation of the work that I had been doing for all those years. I was very keen to bring my knowledge and experience particularly around the use of patient reported outcome measurements, and I was delighted to be part of the organisation bringing this important work to life.
The private healthcare sector is well established in the UK but in 2014 the CMA found that the information available to patients considering this option was inadequate, how will PHIN help patients make better informed choices?
In 2014 the CMA started their investigations into the private healthcare sector. They were saying what many of us have been saying for a long time, that patients in the private sector just did not have enough information to make informed decisions about where they could go and who they could see. There is a wealth of this sort of information available in the NHS but the CMA found that similar information was not available in the independent sector. It was absolutely right, and we very much supported what the CMA were saying, it is crucial to have this information. Today patients are much more discerning and demanding and they want to have information before they make their decision, this is often in consultation with their GP and so PHIN absolutely agreed with what the CMA was trying to do.
Now we have a situation where the private sector will submit data to one information body PHIN, and we will work with the private hospitals and NHS PPUs to produce consistently high quality information for patients – the consumers, on the PHIN website. In the past patient experience information was to be found on many, many websites but not in a consistent way, now PHIN is able to publish accurate, robust, and standardised information in a sensitive way that is helpful for patients.
The CMA requires that all hospitals providing privately funded healthcare including NHS hospitals are members of PHIN and that they submit patient episode data, what will you do with this data?
The data submitted to PHIN will be used to produce 11 performance measures (as specified by the CMA), which will be published on the PHIN website – supporting patients with greater information about the range, quality, and safety of care services available to them. Currently there are three performance measures published at hospital site level only – patient numbers, average length of stay, and patient satisfaction, based on the NHS Friends and Family Test (FFT). Next year this will be expanded to include additional measures – such as adverse events and patient reported outcomes (PROMs), and published for both hospitals and individual consultants.
But before publication we give every opportunity to ensure the quality and accuracy of the data. After collecting the data hospitals have the opportunity to check that the data is accurate – it is important that they trust us to get it right.
PHIN will publish consultant performance measures from next April. Consultants will want is to ensure that their data is right and we will be encouraging them to start to engage with the portal and check their data to ensure that their practice is fairly represented. We want to be as fair as we possibly can to everybody and we are doing a lot of work on engaging with the consultants to tell them that this is coming. We are not going to make judgements we are simply the facilitator to enable them to get accurate high quality data onto the PHIN website. We want to help provide clarity around healthcare data and healthcare information specifically around the 11 performance measures outlined by the CMA. The data is aggregated performance measures which provide really helpful information, context and benchmarks from which patients can arm themselves for conversations with their GP’s or referring clinicians.
Our readers will be particularly interested in the data that will be published at consultant level. Can you outline the deadlines?
At the end of April 2018 we will publish performance measures for consultants. Before that we are engaging in a process of communicating much more clearly and openly with consultants, encouraging them to come onboard with our online portal from this summer.
The consultant portal will launch this summer, it is available for hospitals now and they are already using it and we are seeing a lot of benefit for them in terms of checking and improving the accuracy of the data. The consultant portal has been piloted and the feedback from that was positive, the idea is to give the consultants six months to enable them to do their checks before publication.
Traditionally there has been little transparency in the publication of consultant fees. How are you working with doctors to ensure that what is published is valuable to patients and fair to consultants?
Absolutely – transparency in terms of fees (Article 22) is needed, and this is one of the areas the CMA identified in their report. It is a complicated area, one thing we are very sure about is that we are going to be working closely with the medical profession to come up with the best way of doing this. But the important thing is, with the publication of consultant fees now delayed till April 2019, we have been given the time to do this properly.
We have already gone out and piloted the portal once and we have used that feedback to make sure it is user friendly and to tidy it up as much as possible. When it is rolled out to consultants of course it will no longer be in pilot phase, but we are always open to improvements and want to work proactively and productively with consultants. Working with them over the next year we will be introducing them to their data and making sure that that portal is as robust and user friendly and helpful to them as possible. As we progress both for hospitals and consultants, it is very much making sure that they can check their data for accuracy and they can see what the performance measures (Article 21) are going to look like and how that has come to be.
As we move forward there is a real question in there about what other value consultants can get from this data. Consultants are generally very proud of their practice in the private sector and being able to see and publish their data is an important step forward. All doctors now have revalidation and this will be a chance for them to present a complete set of their data to appraisers, that is going to be very helpful.
– Andrew Vallance-Owen
Designated Medical would like to thank Andrew for taking the time to answer our questions.
For more information visit https://www.phin.org.uk/