Public Services Reform (Scotland) Bill Scottish Independent Hospitals Association The following submission is presented to the Health and Sport Committee of the Scottish Government as an outline of the improvements that have been and will continue to be made in independent healthcare service delivery across Scotland. This submission is to demonstrate the credibility and significant contribution of the Scottish independent health care sector to healthcare delivery within the backdrop of a new regulatory regime. Introduction Independent healthcare providers in Scotland play a significant role in delivering healthcare to the Scottish people and are proud of their excellent relationships with the current inspection bodies responsible for regulating its services. Scottish independent healthcare providers consider that it is important for service users to feel that they are receiving the best possible care and treatment and the clinical teams within the sector work significantly hard to keep patients safe and informed. Scottish independent healthcare providers also view the move to Healthcare Improvement Scotland (HIS) as a natural strengthening of the ties and existing integrated working between the independent sector and NHS Scotland as well as working towards the greater sharing of best practice and innovation between sectors. Statutory regulation is viewed positively in terms of the ongoing strive towards excellence in care delivery. As a group, the Scottish independent healthcare providers will continue to work closely with all regulatory and inspection organisations in the future. The establishment of HIS, as a new healthcare scrutiny body, is a fresh opportunity to build on a continuing regulatory process to ensure standards of delivered healthcare are monitored, maintained and improved in a manner that prioritises patient need whilst offering individual healthcare choice. It is also an opportunity to review existing regulatory processes and requirements with a view to reducing administrative burden on providers. INDEPENDENT HEALTHCARE IN SCOTLAND The independent healthcare sector in Scotland makes a fundamental contribution to the provision and delivery of healthcare across Scotland. Scottish independent healthcare providers consist of nine acute hospitals and five mental health hospitals, all of whom work with a wide range of stakeholders including patients, Consultants and their professional associations, General Practitioners, regulatory and inspection bodies, intermediaries, the NHS and Community Health Partnerships and Community Health Services.
Providers are supported by the Scottish Independent Hospitals Association (SIHA) which was set up to assist independent providers to develop and share their knowledge and experiences, whilst providing a reliable and robust source of information about independent healthcare provision in Scotland. Facts and Figures In 2008-09, acute independent sector hospitals treated more than 45,000 inpatient/day-case patients and more than 186,000 outpatients. Scottish independent mental health hospitals treated over 1400 patients during the same period. Number of acute beds There are 313 acute beds across nine hospitals of which 21 are critical care level 2 beds. Number of mental health beds There are 268 mental health beds across five hospitals. Number of acute patients treated The acute hospitals looked after 45,035 admissions (866 per week), 52 % on an inpatient and 48% on a day case basis. Number of Outpatients seen A further 186,396 acute hospital Outpatient appointments (3,585 per week) were attended by patients in 2008-2009. Number of mental health patients treated The mental health hospitals cared for 725 inpatients and 705 day cases. Homecare services The home care services carried out 28,101 patient contact visits (540 per week). With the creation of Healthcare Improvement Scotland, it can be demonstrated that high patient volumes will continue to be provided for within the independent healthcare sector. This is offered with a view to working in partnership with NHS Scotland to complement existing healthcare provision in the public sector. Overall, the above figures represent a considerable percentage of all healthcare delivery in Scotland. If independent sector healthcare was not available in Scotland, such absence would place significant additional burden on acute healthcare and mental health provision within the NHS in Scotland. Patient satisfaction and complaints All independent healthcare provider organisations continue to demonstrate consistently high levels of patient satisfaction and take pride in the care services offered. During the period 2008-09, average satisfaction results for the sector were:
98% of patients surveyed would recommend the hospital / treatment centre to others. 99% of patients rated the service as either excellent, very good or good. 99% rated the cleanliness of the facility as excellent, very good or good. All the Scottish independent healthcare providers who are members of the SIHA have a commitment to quality assurance and improvement as a key part of the delivery of safe and effective healthcare to patients. They have active systems in place to identify the central cause of any issues identified which help to ensure that problems do not recur. As a result of this work, independent providers receive very few complaints. The numbers of complaints received during 2008-09 represent only 0.9% of all inpatient and day case discharges and 0.2% of all attendances. It can be confidently demonstrated to Healthcare Improvement Scotland that patient satisfaction is taken very seriously with robust systems in place to monitor ongoing satisfaction levels. Complaints processes are effective and will continue to be developed under compliance monitoring from a new regulatory organisation. This is viewed positively by independent providers. The SIHA hospitals are signed up to a Code of Practice for Handling Complaints in the Independent Sector consisting of 3 stages. Stages 1 and 2 are both part of the organisations local resolution procedures with stage 1 being the initial complaint and provider response. Stage 2 is a review of the complaint by the CEO, or at director level, when a complainant is dissatisfied with the outcome of stage 2. Following stage 2 a complainant still dissatisfied can access the Independent Adjudication Service provided through the Independent Healthcare Advisory Services. This process has recently been revised and received commendations from regulators. The Code documents also contain specific information about Adjudication and guidance notes for service managers. Monitoring quality Patients in the independent sector receive high standards of clinical care and are treated in high-quality facilities by leading consultants using the latest technology. Such high standards will be maintained with the establishment of Healthcare Improvement Scotland (HIS) as monitoring will continue to be required to provide patients with the assurance that care and treatment are reviewed and changes and improvements made where necessary. The acute hospitals record surgical site infections (SSI) following hip and knee arthroplasty. SIHA members also have stringent measures in place to combat MRSA and other hospital acquired infections. As a result no incidences of MRSA Bacteraemia or Clostridium Difficile were recorded in the hospitals during 2008 2009 represented by a period of 53,489 bed days. The Scottish independent healthcare sector is represented on the National Healthcare Associated Infection Steering Group and Programme Board. It is important that the independent healthcare sector continues to be represented
as it enables the Steering Group to gain an appreciation of the full picture of hospital acquired infections (HAI) infections across Scotland as a whole. The independent healthcare sector in Scotland has been involved in SSI surveillance for a number of years. There is now a formal reporting of Staph aureus bacteraemia and C. Diff on a monthly basis, even when no actual incidence has occurred. The table below shows the success of these measures for the nine acute hospitals. Indicator Rate Number of unplanned re-admissions 0.2% of all inpatient/day cases Number of unplanned returns to the 0.2% of the total number of operating theatre anaesthetic episodes Number of patients transferred to NHS 0.1% of the total number of facilities following surgery inpatient and day patient discharges Cancelled operations 0.5% of which 83.6% for clinical reasons 16.4% for non-clinical reasons Surgical site infections as a Rate percentage of the discharges Following hip arthroplasty 0.4% Following knee arthroplasty 0.4% Scotland s independent sector hospitals, as part of their clinical audit and quality programmes, maintain records on a wide range of data on patient outcomes. The establishment of a new Scottish regulatory body will be a means to monitor and ensure that such data continues to be collected, recorded and used meaningfully. Clinical Indicator and Data Management The Independent Healthcare Advisory Services (IHAS), of which the Scottish Independent Healthcare Association (SIHA) is affiliated, has contractual arrangements in place with Dr Foster Research to provide a secure benchmarking and reporting system of patient level data across the independent healthcare sector as well as the NHS. Key performance indicators such as patient activity volumes, average length of stay, returns to theatre, MRSA and C.Diff will be able to be calculated within Scottish independent sector hospitals to facilitate benchmarking performance. With the establishment of Healthcare Improvement Scotland, this data will be available for regulatory submission to comply with statutory responsibilities. As a result, the process to allow analysis and reporting arrangements will ease the burden on providers. The terms of reference for the NHS QIS Liaison Co-ordinators Network requires a commitment to all the NHS QIS products which will be considered by the sector with a view to confirming agreement to this commitment.
Infection control The health, safety and general wellbeing of patients, staff and visitors is paramount for everyone working within the healthcare arena in Scotland, whether in the independent sector or NHS. The Scottish independent healthcare providers believe that keeping their hospitals clean is the key to avoiding infections such as MRSA. This requires; Information to help patients and visitors understand the precautions used and how they can contribute to help avoid the spread of infection; All members of staff to be effectively trained in hygiene techniques; All members of staff to follow written policies and guidelines; Strict infection control programmes and Collection of patient outcomes data. The structure and design of independent sector hospitals specifically helps to minimise the risk of cross-infection, with most inpatients having their own individual rooms; the majority with private en suite facilities. The hospitals also work to combat possible cross-infection from patient to patient, patient to staff, or from staff to patient, by ensuring effective hand decontamination between every contact with patients. It is also important to stress the role that the housekeeping staff play in ensuring high specifications of hygiene and cleanliness and are accountable to the ward managers. Independent sector hospitals have consultant microbiologists, or specialist infection prevention and control doctors, working as specialist advisors to manage cases of infection along with infection prevention and control nurses to provide staff with day-to-day infection prevention and control advice and guidance. In many cases, patients are screened for MRSA at the time of admission to independent sector hospitals in Scotland. These include patients who fall into specific categories. Healthcare Improvement Scotland can be assured that infection control measures will be applied to the highest possible standards and the actual and potential risks in acquiring an infection will be minimised. Regulation of Healthcare Support Workers As part of their programme of work on patient safety and clinical governance, NHS QIS piloted the model of regulation for healthcare support on behalf of the four countries of the UK. The independent sector in Scotland was represented in the pilot work and was an equal partner to the NHS Boards also taking part. Healthcare Improvement Scotland can be confident that independent sector hospitals in Scotland are equally equipped and resourced to engage Healthcare Support Worker staff to ensure that the most skilled and appropriate healthcare staff are in post to support clinical staff to care for patients and are happy to participate in Employer led regulation.
Revalidation of Medical Practitioners The Scottish Independent Hospitals Association is working with colleagues from the NHS, GMC and Scottish Government, in developing the framework for revalidation of doctors in Scotland. The aim is to ensure that, through whole practice appraisal, a doctor's independent practice takes its rightful place in the evidence they will submit to maintain their license to practice. Work is also in progress to ensure that doctors can be suitably revalidated regardless of the mix of work they do in the NHS and independent sector, or other clinical environment in which they work. The revalidation agenda is the key issue facing the medical profession at the moment and the independent sector is delighted to be able to work with all medical colleagues in Scotland to achieve a successful outcome. Healthcare Improvement Scotland can be confident that medical practitioner arrangements continue to be in place and strengthened between the independent sector and NHS Scotland. Use of Class 3B and Class 4 Laser and Intense Pulsed Light (IPL) equipment The establishment of Healthcare Improvement Scotland is also an opportunity to bring into regulation Class 3B laser, Class 4 laser and IPL providers who provide patient services of a non-surgical cosmetic nature. The present situation in Scotland whereby laser and IPL cosmetic healthcare treatments are being provided and not regulated under the current requirements of the Regulation of Care (Scotland) Act 2001, has significant potential for actual and potential patient risk using powerful cosmetic treatment equipment with no regulatory mechanism to improve provided services. The use of such equipment requires strict administration, environmental and staff training controls. There is a crucial opportunity to commence regulation of this cosmetic healthcare provider group in Scotland either with the establishment of Healthcare Improvement Scotland as a scrutiny body or an alternative model of statutory regulation. The subsequent improvements in commencing regulation will ensure that regular monitoring and assessment of this cosmetic healthcare provider group take place on a regular basis. This is necessary to monitor compliance with expected standards and regulations to provide assurance that laser and IPL treatments are being provided safely through up to date supporting administration control documents, regular attendance at laser/ipl staff training and compliance with strict environmental treatment room controls. Regulatory Burden With the establishment of Healthcare Improvement Scotland, an opportunity is being created to allow a review of current regulatory processes and procedures in relation to the administrative burden placed on the independent sector in Scotland.
There is now a fresh opportunity to review procedures for formal application for service provider registration, varying and amending registration conditions, annual self assessment submission, annual reporting mechanisms, inspection processes and routines, inspector/assessor training and receiving timely inspection report publications within the new Healthcare Improvement Scotland structure. Reducing burden will allow providers to increase focus on patients healthcare needs in order to maintain continuous quality improvement in all aspects of healthcare services. Overall Independent healthcare providers in Scotland are fully committed to supporting and working with the new regulatory body and welcome the opportunity to contribute to any review of the current regulatory process. Providers will continue to strive to improve healthcare services on an ongoing basis. The creation of Healthcare Improvement Scotland will maintain the regulatory momentum to demonstrate to patients that services are of high quality and meet expectations. Sally Taber Secretariat Scottish Independent Hospitals Association 14 th August 2009