The man making competition work
In an exclusive interview, Dr Ian Gargan, chief executive of the Private Healthcare Information Network (PHIN), answers some of the big questions on many a consultant’s mind.
How concerned are you that many consultants in private practice don’t know what PHIN is?
The Private Healthcare Information Network (PHIN) is a government-mandated, not-for-profit, organisation that exists to help make the private healthcare sector more transparent, serving patients by making their healthcare decisions easier to make.
We want every consultant to be aware of PHIN and participate with us, as this is a legal requirement under the Competition and Markets Authority’s (CMA) Private Healthcare Order. They should also be making patients aware of us.
As part of this work supporting stakeholders, we have been contacting consultants to let them know about the CMA Order since 2017 and an ever-increasing number are not only aware of us but are engaging with us to supply information about their fees.
Why should I bother with PHIN? How many consultants are engaging so far, how many aren’t and what is your target for mid-2023 and ultimately?
Engaging with PHIN isn’t an option, it is a legal requirement, and the CMA is already looking at enforcement action against consultants who have made no effort to work with us.
On the other hand, those consultants who supply us with full information for their profiles on our website see higher page views and direct contacts from potential patients, so have another avenue to help build their practice.
We are aiming to work more closely with consultants to inform them about PHIN, but also to get their feedback about how we can help and support them.
We already have over 9,000 consultants on our website and our aim is to have all consultants in private practice on the website before the middle of 2026.
How many potential patients use the PHIN website? 12k a month has been mentioned. How many should it be when you consider how many people are seeking private doctors?
Website traffic has been increasing steadily since we redesigned and relaunched the site in summer 2021. We now receive an average of 34k visitors per month and also see significant numbers choosing to make direct contact with consultants and hospitals. There were over 7,000 contacts last September for instance.
With over 800k to a million private procedures taking place each year, there is considerable scope to grow this number, and that is what we aim to do, with the support of consultants and others in the sector.
Most visitors to our website who complete our short questionnaire say they can find the information they are looking for. If they have a complaint, it’s mostly around missing consultant information.
We would encourage all consultants to create a profile so information about them and their practice is always available to patients. This is good for consultants and avoids patients being disappointed if they cannot find information about their chosen consultant
Why have I received a letter from PHIN? What do I need to do and why?
We regularly write to consultants who have either not supplied their fee information or who have done so but have not quite completed the process to allow us to publish that information.
We have also recently been contacting consultants to let them know that the CMA is investigating enforcement action and we want to avoid them being on any escalation list.
We encourage consultants to review the data that is submitted to PHIN from the private hospitals where they work. There are processes to approve data about the volume of procedures that they perform and the length of stay for those procedures.
Consultants can also notify hospitals if they want to review or raise a query about data that has been submitted to PHIN.
Am I obliged to send out information about PHIN?
Yes, under the Order, consultants are required to provide patients with information about their consultations and any investigations. They must provide additional information if a patient requires a procedure.
In many cases, hospitals where the consultant practises have taken on the role of producing the relevant letters on behalf of consultants, not least because they have a responsibility to ensure the information is provided.
How can PHIN help me? What do I get out of it?
PHIN is here to help consultants comply with the Order. We don’t want to see anyone undergoing enforcement action and we support consultants to ensure the process is as straightforward and painless as possible.
We have a dedicated consultant support team and consultants can also ask questions through our consultant portal: https://portal.phin.org.uk/
In terms of value for consultants, our website analytics show that doctors with complete information receive many times more clicks to their practice than those who don’t provide the data.
Tell me more about the PHIN portal – how to log onto the portal, how to submit fees or related issues to fee submission and how to create a profile or related issues to profile?
The PHIN portal is the website where hospitals and consultants can submit data and access information about their performance.
When a consultant first visits the portal, they will need to sign into their account. There is a button to this at the top of the page.
They then add their email address and request a security code and create a password. We’ve tried to make the process easy, but we are happy to talk consultants through it if they have any issues and offer ‘virtual session’ where we can answer any questions.
As well as consultant details, we also publish other information that is of relevance to the sector, including around measures.
I have concerns about my information in the portal.
PHIN provides consultants with a view of the data it has received from independent hospitals and private patient services in the NHS. We also provide a view of data received from NHS Digital covering NHS-funded care. We don’t modify the data.
We are aware of the potential for data errors – for example, around different procedures which have been performed – and there is a process to raise queries and have errors corrected on the privately funded data.
We are happy to work with any consultants who have concerns to review and verify the information that is submitted about their practice before it is published online.
This is a really important task for ensuring that PHIN and private hospitals can publish information in line with the CMA Order and support greater transparency for patients considering private healthcare.
Any consultants who do not engage in, or have ceased to engage in, private practice or who have retired can have their profiles removed on request.
Consultant fees are a small proportion of package prices. Is this made clear to patients?
We know that cost is a primary factor for patients, particularly for those patients who are paying for their treatment themselves. We make clear that the fees are the consultant fees only.
Where consultants tell us that they have a package price arrangement in place with their hospitals, we present that information to patients and advise them to contact the hospital so that they have a complete understanding of the full costs of a particular procedure/course of treatment.
We will continue our dialogue with hospitals on how we can make it easier for patients to access package prices.
Is PHIN’s published fee information only for self-payers?
The fees published for consultants are those for self-pay patients. We have worked with stakeholders to identify an approach on insured fee arrangements and are looking to launch that in the PHIN portal in mid-2023.
How long would it take for an average full-time private practice general surgeon, for example, to submit every-thing you want and keep it up to date throughout the year?
We estimate that a consultant can submit fees, review and verify their practice information and complete a profile in approximately an hour.
To help with the process, we would always suggest that consultants join one of our virtual sessions so that we can take them through the portal and each of the processes that we ask you to
complete.
Having set the information up, we will contact consultants to let them know when new data is available to review. This is usually episode data for a three-month period.
We will formally contact consultants a minimum of once each year to ask that they review their fees to ensure that these are reflective of current charging practice.
We will also let consultants know when they have received sufficient feedback information to have a score on PHIN’s website. Consult-ants are free to review and update their information any time.
Can PHIN provide any training for PAs/secretaries to load up the information on consultants’ behalf?
We hope to provide secretaries with direct access to the portal during the next year. In the interim, we are happy to welcome PA/medical secretaries to our virtual sessions so that they can become familiar with the processes on PHIN’s portal.
How are you going to ensure the public know about PHIN and see the advantages of using it? Aren’t there now other websites providing consultant and hospital fee information and so on?
There are other websites that provide some information to help patients. Generally, they are websites that promote patient reviews and comments.
PHIN is the only government- mandated, not-for-profit source for private healthcare data in the UK and, as such, our data can be trusted. We are tasked with publishing a wide range of objective performance information about consultants.
That doesn’t mean we are in competition with other sites and will be looking at information partnerships in the future.
In the meantime, consultants, hospitals and private medical insurers all have a duty to inform their patients and customers about PHIN, so that is an important way to inform the public.
PHIN doesn’t have a marketing budget and relies on optimising our website and information to be search engine-friendly.
Do you think the CMA’s threat to get tough on consultants with fines and naming and shaming is serious and should be taken so by consultants? How have hospitals reacted to the threat? How many hospitals are you still chasing to engage?
The CMA is serious about ensuring hospitals and consultants comply with the obligations set out in the Order. We are in regular contact with them on the topic.
We will always work with consultants and the hospitals to avoid escalation and the CMA commencing enforcement action where we can.
However, if consultants fail to participate, they should be under no illusion, the CMA will press ahead with enforcement measures as it does in many other sectors.
The majority of hospitals are engaged in the process, but we continue to work with the small number that do not yet, in the same way as we are for consultants.
Do you really think PHIN stands any chance of fulfilling its duties to the CMA?
In summer 2022, we agreed a sector-wide strategy and roadmap to deliver the Order, and we are very confident that, by working together, the sector will be able to fulfil its duties and patients will see the benefit of a more transparent sector.
How many people does PHIN employ?
At the beginning of the Order being laid, PHIN had no more than six or seven employees. That has grown as the scope of what was required grew, including consultant fees submission and as we were ready to tackle more complex measures and challenges.
We are currently around 40-45 staff and in total there will be just under 50 full-time equivalent (FTE) staff at PHIN in 2022-23. These are divided between our functional teams:
Informatics – the ‘engine room’ of PHIN, responsible for the analysis of data and data quality, and preparation and maintenance of performance measures information for publication.
Technology – the development team responsible for development and maintenance of our databases, consumer website and member portal, and the Information Security and Services team, responsible for maintaining the day-to-day systems and security, including ISO 27001 compliance.
Engagement – is led by the member services director and comprises PHIN’s hospital and consultant engagement teams, engagement with other stakeholders and patients, our communication team that is responsible for the design and development of our website and portal products.
Corporate – this function comprises the chief executive, chief financial officer and the director of people and process (corporate secretary).
This team is supported by an office manager and the project management office team, as well as outsourced data protection officers, HR, admin, legal and finance and accounting functions.
How much does it cost to run?
As a not-for-profit organisation, PHIN is always keen to provide transparency in how it spends its members’ funds, and details are published in the Financial Statements and Annual Report each December and available from our website.
Based on the audited cost base in 2021-22, the bulk of PHIN’s expenditure is on people and staffing costs which comprises around75% of our cost base.
Income for the year was 2021-22 was £4.6m.
Where does the money come from? How much do individual hospitals have to pay?
PHIN’s costs are covered by the hospitals providing treatment for private patients.
The method is set out in the CMA Order and is a fee for each patient record submitted. Therefore, the large hospital groups provide the majority of our budget.
How reliable is the data you are publishing? If you have any concerns about that, then how can it be more accurate?
We run numerous validation checks on the data we receive and give the hospitals and consultants submitting it the opportunity to review it before we publish, to ensure high levels of accuracy.
While we can check for validity and completeness, only the consultant and hospital know what treatment was actually provided. We have a process that allows consultants to raise queries with the relevant hospitals so that any issue can be reviewed and corrected.
How ridiculous is it that consultants are banned by the CMA for agreeing fees together, yet they can now go to the website to see what rivals charge?
The CMA Order is designed to promote transparency across the sector and encourage increased competition which should result in better patient care.
Our role at PHIN is to help consultants and hospitals make that happen by collecting and publishing the information for patients to help their choices and for all stakeholders to improve care.
At the recent BMA private practice conference, a consultant looked at the PHIN website to see info about some of his medical chums – he told the meeting they were not doing what was recorded there. What would you say to him?
We rely on the data supplied by hospitals and verified by consultants. There are also circumstances where consultants will verify their private episode data, but the activity that they undertake in the NHS may not be shown.
We take our responsibility to protect the identity of patients very seriously, so we will not show the number of a procedure performed where the volume is seven or fewer.
If anyone is aware of any errors or misattribution, then we would encourage them to visit the PHIN portal and make the necessary amends or to contact our consultant team.