Select Committee on Health Appendices to the Minutes of Evidence


Supplementary memorandum by General Healthcare Group (PS 9A)

  General Healthcare Group (GHG) welcomed the opportunity to provide oral evidence to the Committee to assist with its Inquiry. This note provides some additional thoughts on key areas that were explored in the oral session.


  It is important that the impact of private sector recruitment on staffing levels in the NHS is not misunderstood. GHG firmly believes that private sector recruitment has, at most, only a marginal impact. Yet private sector staff (along with other factors that cumulatively create private sector capacity) can realise significant additional capacity for the NHS.

  The ability of the NHS to treat patients is not simply a factor of staffing levels. However, staff levels are nevertheless an important component in determining NHS capacity. With this in mind, it is crucial to appreciate that the majority of staff leaving the NHS do not join the private sector. They leave healthcare altogether. The staffing needs of the private sector are not a significant reason for NHS staff shortages. Rather, many of the problems of NHS nurse recruitment and retention lie within the NHS itself. However, the private sector should not be complacent. It is important that, where it can, the private sector should bring new capacity to the NHS without constraining existing NHS operations. This should include considering how it can further minimise the impact that it has on nurses leaving the NHS.

  With this in mind the Committee might note that GHG estimates that it could double its capacity to treat NHS patients while relying on existing facilities and without increasing its staffing levels. This would be achieved by the flexible deployment of existing staff resources to maximise GHG's ability to treat patients.

  As staffing concerns are of such significance, GHG is also examining ways that it can increase its recruitment of key clinical staff from other parts of the European Union. It is also looking at the ways in which the Government has sought to encourage nurses who have left the profession to come back into the NHS to see how it might attract these health workers, who otherwise might be lost to the UK healthcare systems altogether, into its employment. We believe that while some nurses might wish to return to the NHS, others may want to rejoin the health economy but not in the public sector. Maximising the opportunities for ex-nursing staff to return to either the public or private sector should help ease staffing pressures in the NHS and over the long-term increase capacity—especially if the private sector is helping the NHS deliver care to patients.


  NHS purchasing of services from the private sector must be accompanied by confidence from both purchasers and patients that demonstrably high standards are employed by non-NHS providers. In the long-term the question of quality standards will be addressed through monitoring by the National Care Standards Commission (NCSC). Nevertheless, there are important areas that need to be considered. These involve monitoring of standards for:

    —  UK providers during the NCSC's transitional period (as it moves to fully assume its monitoring functions from 1 April 2002); and for,

    —  Overseas providers.

  GHG believes that these considerations should be a key priority in developing links between the NHS and the private sector. If effective long-term partnership between the NHS and private sector is to be established, it is vital that these arrangements are based on sound foundations of high quality provision. It would be unfortunate if confidence in the value of co-operation was to be undermined because proper quality assurance systems were not in place in the early stages of the process.

  Although responsibility for monitoring UK providers will shortly be taken on by the NCSC it is clear that the assumption of these powers is the very first step in establishing a more robust regulatory regime. In the first instance providers will simply undertake to meet the standards expected by the NCSC. Until a particular facility has been inspected by the NCSC there cannot be complete confidence that it meets the minimum standards required.

  The NCSC faces a substantial challenge in undertaking its initial assessments. The sheer scale of the task it faces is key in this. It will not only be covering private and voluntary hospitals but also a range of other providers, such as private care homes, children's homes, voluntary adoption agencies and day centres. It will have to inspect many facilities with relatively limited resources. This means that it is unlikely to have inspected all facilities within its remit until some time has elapsed.

  Until the system is fully established GHG recommends that there should be transitional arrangements put in place to help ensure that private providers working for the public sector are working to the standards required by the NHS. A number of approaches could be adopted to ensure this:

    —  Private facilities intending to provide services for the NHS could be designated as priority facilities for NCSC inspection. However, if this is not a viable option, then:

    —  The NCSC should prioritise inspection of those private facilities that have not achieved independent quality standards. It is the case that quality standards vary between private providers (the same is true within the NHS). The pursuit of best practice has led some providers to seek independent accreditation of their facilities. This has included achieving Health Quality Standards (HQS) or ISO accreditation, for instance. Both of these measures are strong and objectively measured indicators of service quality, although in fact General Healthcare Group has secured accreditation for its units under the HQS scheme, under which facilities have to meet 2,500 mandatory and 2,500 best practice quality standards and successfully complete a 3-day independent inspection. There is a very significant overlap between this standard and the regime that will be implemented by the NCSC. Regrettably, this is not the position for all accreditation schemes which are available, and in particular schemes such as HAP where the depth and breadth of coverage of standards is materially less and the survey process must less extensive. Facilities complying with accreditation standards such as HQS are less likely to be vulnerable to quality concerns that those which are not accredited. As it establishes itself the NCSC should focus its attention on providers most likely to have compliance problems with the standards required under the Care Standards Act. It should use compliance with independent assessment regimes as a guide to prioritising the inspection of private facilities providing services to the NHS.

    —  Quality control should also be addressed by the development of guidelines for NHS purchasers. These would focus purchasers' attention in the first instance on whether or not NCSC inspection has been undertaken for the facility they are considering making a purchase from. In the absence of an NCSC inspection it should emphasise the importance of independent quality accreditation (such as HQS and ISO compliance). Failing such assessment there should be guidelines on how purchasers might make their own assessments of quality of services provided.

  (Once the NCSC system is bedded-in GHG would expect the priority of inspecting facilities to be the same. These recommendations are designed to address transitional concerns).

  Quality monitoring for overseas providers is a more difficult issue to resolve. GHG would envisage that NHS purchasers would make independent assessments of the quality of the services available. However, GHG recommends the Department of Health should consider the value of creating a standards registration and inspectorate service for overseas providers wanting to take on NHS work. In the long term this could significantly reduce the costs to individual purchases and make treatment abroad subject to standardised quality control.


  The issue of quality monitoring for private sector providers is an important one that should be a priority for the Department of Health. In particular, it might be an area that the NHS Modernisation Board should consider in more detail.

  GHG would be pleased to provide more information on the points raised in this memorandum if it would be helpful to the Committee.

January 2002

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