Independent healthcare fees: consultation analysis report - SG response
Scottish Government response to our public consultation on proposals to increase the maximum fees that Healthcare Improvement Scotland may charge and published an analysis of the responses we received. After consideration of this analysis, we are amending our proposals.
Frequently Asked Questions
There were a number of common questions raised by respondents to the consultation. We have collated and provided a response to the most frequently asked ones:
Fees
Why are you doubling the fees?
The registration and continuation fees are not doubling. In previous years, you will have observed an incremental increase to your fees, typically reflective of inflation rates. The amendment to the maximum cap will give HIS the flexibility to address unforeseen circumstances or exceptional changes in the economic landscape.
The proposed increase is setting the maximum amount HIS can raise its fees to in the future. Fee adjustments will still take the form of an annual increase.
How were the proposed fees calculated?
HIS modelled the proposed fees in line with historical inflation rates.
Can you not base fees on the size of the business?
Certain sector fees are based on the size of the business, such as independent hospitals. The calculation of fees includes consideration of the risk each sector poses. The fee is set to reflect the amount of time needed, type of service, and resource HIS anticipate they will spend regulating each sector.
Inspections
Why do HIS hire third parties to inspect, when surely it would be cheaper to employ full time inspectors?
HIS employ subject matter experts to review specific clinical specialties. There is not sufficient work to justify employing dentists or medical consultants for each specialty on a permanent, full time basis. HIS keep staff costs under constant review to ensure best value for money.
Each inspector seem to have different criteria, are there no standardised inspection requirements?
Inspections are carried out in line with HIS’ independent healthcare inspection methodology. The methodology outlines the important principles that guide the inspection process and how HIS ensures that people who use registered independent healthcare services are at the heart of this process. The inspection process is informed by:
i. assessing compliance with relevant legislation
ii. evaluating how well providers have applied Healthcare Improvement Scotland’s Quality Assurance Framework in their service
iii. assessing providers’ self-evaluations, annual returns and notifications, and
iv. involving people who use services.
If I only have one inspection a year, and it lasts an hour, why are costs so high?
As part of the registration process, you will receive a registration visit. This is to ensure that the premises is suitable to provide an independent healthcare service.
The Service Risk Assessment (SRA) is the operational planning tool used to plan inspection frequency. It provides a framework for monitoring services on an ongoing basis, so that the inspection approach is risk-based and proportionate. Doing this helps HIS to target resources so that they reduce inspections of services performing well and increase inspections of services with poorer performance.
Once your service is registered, an initial SRA score is calculated, which determines when the first inspection of your service will be carried out. This will usually be 18 to 24 months following your registration date, or sooner if deemed appropriate.
Following each inspection, your SRA score will be updated, which determines when the next inspection of your service will take place. Dependent on your SRA score, the next inspection will take place between 3 months and 5 years.
Dependent on the size of your service, an inspection will take between 0.5 day to 2 days.
Regulated Services
Why are you not regulating aesthetic/cosmetic services provided by non-medical professionals?
We are actively engaged with stakeholders and the Scottish Cosmetic Interventions Expert Group (SCIEG) on this issue. They have recommended a phased approach to the regulation of non‑surgical cosmetic procedures and the second phase involves considering procedures that pierce or penetrate the skin and are provided by people who are not qualified healthcare professionals and who work from non‑regulated premises.
Why are you not regulating independent pharmacists?
the Scottish Government is laying legislation in April to amend the definition of independent clinic and independent medical agency to include pharmacists and pharmacy technicians. They will be subject to regulation by HIS.
Why am I being regulated by HIS as well as my professional body (GMC, GPhC, etc)?
The professional body regulates the individual. HIS regulates the business.
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