Independent healthcare fees: consultation analysis report

Analysis of responses

The Scottish Government’s public consultation ‘Healthcare Improvement Scotland: independent healthcare fees’ ran from 16 October to 11 December 2023. It asked four questions, three of which required a straightforward yes/no response, and one of which was free text.

The consultation received 105 responses, of which 83 (79%) were from individuals and 22 (21%) 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. 12 responses were anonymous, while 62 (59%) did not want their name published alongside their response and 17 respondents (16%) did not wish their responses to be published at all. All responses have been considered in this analysis, irrespective of whether or not they have been published. See Annex B for a list of organisations that responded.

Question 1: Do you agree that the regulation of independent healthcare services should continue to be funded through fees charged by HIS to private providers?

Question 2: Do you agree with the proposed maximum fees that HIS can charge for the commencement of the regulation of independent medical agencies?

Question 3: Given the increasing costs required to regulate independent healthcare, do you agree that the proposed maximum fees Healthcare Improvement Scotland can charge, as outlined in the background information, is required?

Question 4: If you do not agree with the proposed maximum fee adjustment:

a. What alternative approaches or strategies do you believe would be fair and effective?

There were 88 responses to this question (more details below).

b. How would you suggest HIS address the challenges of the rising costs they incur while regulating independent healthcare services due to inflation, while minimising the impact on their stakeholders?

There were 84 responses to this question.

A range of comments were made in response to both parts of Question 4a and 4b, which it would be easiest to consider together as topics overlapped.

44 respondents (50%) suggested that non-healthcare professionals should also be registered. 30 respondents (34%) felt that fees should be based on the size of the business.

Other comments made include:

• Respondents could not understand the rationale behind the increase
• All cosmetic services should be regulated
• Fees should be based on the services the business provides
• Regulation should be centrally funded from government
• There are too many regulations
• HIS should review their own spending and overheads and should publish their own financial records.