FIPO’s reaction to competition watchdog’s easing of rules
The Federation of Independent Practitioner Organisations (FIPO) has welcomed the Private Healthcare Information Network’s (PHIN’s) recommendations to limit the publication of consultant level metrics until more valid information can be made available.
It gave the following responses to earlier proposals below:
Recommendation: Publication should initially focus on information related to admitted privately-funded care only.
While whole-practice information is a worthy aim, the nature of NHS patient episode attribution and the manner in which NHS-funded care in the private sector is at variance with the exclusively consultant-led practice for privately funded patients. For that reason, we endorse PHIN’s reticence in pursuing this at the moment.
FIPO supports this recommendation.
Recommendation: Information for all measures should be published in the PHIN portal for hospitals and consultants as a first step, as increasing transparency and openness in the sector is an important mechanism for addressing the AEC (Adverse Effects on Competition).
FIPO has repeatedly stated that the metrics as defined by the Competition and Markets Authority (CMA) are not necessarily indicators of consultant quality and valid comparisons based on these data are not possible.
FIPO is pleased that PHIN recognises the lack of statistical robustness and their limited value to patients.
However, restricted access to these metrics can reasonably allow their use as a governance tool to drive improvement. FIPO has always believed that metrics should be used to drive improvements and not for judgement.
FIPO supports this recommendation.
Recommendation: Information should be published to show information about procedures at a national level, as this will help inform consumer/patient choice.
FIPO believes that publication of national procedure volumes, with the added benefit of patient segmentation, will be useful for system-level resource allocation. FIPO would be wary of its use by private sector stakeholders with a vested interest and does not believe that it would inform patient choice of private provider
FIPO gives limited support for this recommendation.
Recommendation: There should be an increased focus on publishing information about compliance with the CMA’s Order.
FIPO knows that many consultants have tried unsuccessfully to engage with this process for a number of reasons. We believe that compliance with the order should be transparent at a hospital provider level. This would allow consultants to see which providers are able to support their efforts to engage.
FIPO gives limited support for this recommendation.
Recommendation: PHIN should provide more contextual and explanatory material to patients and consumers.
FIPO believes that this is a very sensible approach and one which is likely to provide the greatest benefit in educating patients to allow independent decision-making.
FIPO supports this recommendation.
Recommendation: Publication will not include complex case mix models at present, but PHIN should include more segmentation of the data to help accommodate measure variation related to differences in patient type.
FIPO believes that the unique nature of doctor-patient intervention is unlikely to allow meaningful individual assessments. As an educational tool, it may have some limited benefit.
FIPO gives limited support for this recommendation.
Recommendation: PHIN should review its procedure groupings; recognising the potentially competing requirements of the need for simplicity to help aid patient understanding and engagement, and granularity to ensure clinical meaningfulness when used for measure comparison.
FIPO believes that the only way forward is for universal adoption of a uniform clinical coding – i.e. OPCS – and a move away from CCSD coding.
FIPO believes this is a work in progress.
Recommendation: PHIN should work with providers to improve the quality of its inbound data, as it is the foundation of everything we publish.
FIPO fully endorses that meaningful decisions can only be based on consistently high-quality accurate uniformly coded data.
Recommendation: PHIN should continue to work with other national agencies where this can help with delivery of the CMA Order.
FIPO agrees with this recommendation, but would suggest that PHIN’s resources, which are funded by the private hospitals for a specific purpose, should not be stretched by any unnecessary activities. FIPO believes that PHIN’s board should regular and explicitly check for this.
Conclusion
FIPO believes that PHIN has now reached a level of understanding which recognises the limitations of the original order in allowing meaningful choice. FIPO very much hopes that the anti-competitive actions of the private medical insurers can now be examined and ultimately addressed.
- See our page one story in our April digital issue, also here