Healthcare Improvement Scotland - independent healthcare fees: consultation

Proposals for reform

In 2023-2024, HIS reached the statutory maximum registration fees of £3500 and £5000 that it is able to charge to regulate independent clinics and independent hospitals respectively. HIS is also approaching the maximum statutory continuation fees that it is able to charge to regulate services. Details of the current fees is available on the HIS website.

The statutory maximum fee that HIS can charge for the variation or removal of a condition of registration or the cancellation of independent healthcare services is currently £100. However, in the past it has not routinely charged for these to help reduce costs for service providers. In many cases variations to individual independent healthcare services are relatively minor but HIS is now seeing an increasing number of significant and often speculative variations which require greater input and resources from HIS and the costs to HIS far exceed the £100 statutory maximum fee limit. For example a change to add general dental services to a service requires input from dental practice inspectors or changes to mental health services may require input from a psychiatrist. Where clinical specialties are not available in house, HIS has to pay commercial rates for this expertise. We propose to increase the maximum fees for variation to services to £1000 to give HIS scope to address the more complex changes to independent healthcare services. As with other fees, it is envisaged that HIS will charge for variations on a scale which is representative of the cost of the work, or look to bill for each variation based on the actual cost, up to the maximum.

For the cancellation of independent healthcare services, the current maximum statutory fee for the cancellation of a service is £100 and we do not propose to increase this.

In addition to the fees set in regulations for independent hospitals and independent clinics, we will need to amend the fees regulations to prescribe maximum fees that HIS will be able to charge in relation to independent medical agencies (a new type of service being regulated).

The following tables list the current statutory maximum fees and proposed new maximum fees.

*per bed

* per bed

While we are proposing an increase in maximum fees, it’s important to note that any annual fee adjustment will take the form of a minor incremental increase, typically reflective of inflation rates.

HIS’ intention is to ensure that their services remain affordable while allowing them to cover rising operational costs. We understand the significance of financial stability for both independent healthcare providers and HIS, and the aim is to strike a balance that maintains fairness and quality.

The proposed increase in maximum fees is a precautionary measure, giving HIS the flexibility to address unforeseen circumstances or exceptional changes in the economic landscape. However, the primary focus remains on gradual and predictable adjustments that keep pace with the cost of living and/or the costs of regulating these services. The costs should reflect the amount of time, type of service and resource HIS spends regulating the sector.

In HIS’ ongoing commitment to upholding the highest standards and ensuring an effective regulatory framework, it is essential to address the changing landscape of HIS’ operational costs. Over the years, HIS has diligently overseen the safety and compliance of services, while supporting improvements through regulation and therefore contributing to the independent healthcare landscape integrity. As HIS’ responsibilities and remit continue to adapt to this evolving healthcare environment, there needs to be a necessary adjustment to the fees they are permitted to charge.

As the complexities of regulation increase, so do the costs associated with maintaining a proficient team, sophisticated technology, and streamlined processes. The decision to revise HIS’ fees is in direct response to the escalating costs of running the organisation, enabling them to sustain the quality expected by the public.

The Scottish Government and HIS remain committed to transparency and accountability. The revised fees reflect a balanced approach that considers the growing expenses while ensuring fairness to all regulated independent healthcare providers.

We understand that changes in fees can raise questions and possibly concerns, and we want to provide you with a transparent understanding of the reasons behind this proposal.

The independent healthcare sector is wide and varied and the landscape has evolved significantly in the recent years. The Scottish Government and HIS’ commitment to ensuring the highest quality of service remains unwavering, and it is therefore now necessary to consider making adjustments to HIS’ fee structure.

It is important fees reflect the increasing costs in order to maintain the standard of excellence across the independent healthcare landscape in Scotland. We invite you to share any thoughts or questions you may have regarding this fee adjustment through this consultation. Your feedback is incredibly important to us, and we are here to address any concerns or clarify any points you'd like to discuss.