healthcare update - issue eight


‘Health tourism’ – the next step


Draft amendments to the NHS Act 2006 have now been prepared which will allow patients to potentially recover the cost of private treatment abroad. The new framework is set out in a Statutory Instrument. It is prepared in anticipation of the implementation of a European Directive requiring EU states to have a system in place to reimburse patients who travel abroad to receive treatment which they cannot receive under the NHS without "undue delay". It seems likely that implementation of the Directive could be some considerable time away and so the Department of Health have sought to begin to ‘plug the gap’ to support the NHS in making decisions pending the final Directive.

There has been considerable confusion for some years over the regulation of so-called "health tourism" since the European Court of Justice case of Watts v Bedford PCT (2006) decided that Article 49 of the EU Treaty (prohibiting barriers between states on the provision of services) applied to healthcare services. The need for reform is clear - the current position is hopelessly uncertain for both patients and NHS trusts alike.

The draft amendments apply to patients who suffer undue delay waiting for their treatment under the NHS. It applies to surgery, in-patient treatment needing at least one night's stay in hospital and services requiring "specialist and cost intensive medical infrastructure and equipment". If a patient's treatment will not be available because of undue delay then the NHS must reimburse the patient up to the cost of such treatment if it had been done on the NHS. The patient must fund the treatment up-front and will only receive reimbursement if they have obtained pre-authorisation from the Primary Care Trust.

The crucial arguments are likely to focus on whether there will be undue delay in the provision of healthcare services. This is individual to each applying patient and is not judged by, for example, compliance with national or local targets/standards (following the Watts decision). The decision will be based on the patient's pain, disability, medical history and the impact of the ongoing condition on capacity to work. The Statutory Instrument refers to an "objective medical assessment", no doubt to comply with the draft EU Directive's requirement that any system of prior authorisation must be proportionate and aimed at avoiding arbitrary discrimination. Once a patient satisfies the requirement of undue delay then reimbursement is compulsory, there is no discretion to refuse. The cost to be reimbursed is either the sum actually paid by the patient or the cost of equivalent treatment under the NHS, whichever is lower.

The Statutory Instrument only provides the most basic framework. Its purpose is to give effect to the existing case law pending the implementation of the Directive. The Department of Health has drafted more detailed guidance for NHS bodies and this is expected to be finalised by February 2010. There is doubt as the timescale for implementation unfolds. It is clear, however, that the principle of the NHS paying for patients to receive private treatment abroad in the EU if there is undue delay in the NHS is here to stay. PCTs must begin to put robust systems in place to make decisions on patients which both satisfy the new requirements and protect the trust from legal challenges from patients.

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Neil Ward
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The content of this update is provided for the purposes of general interest and information. It contains only brief summaries of aspects of the subject matter and does not provide comprehensive statements of the law. It does not constitute legal advice and does not provide a substitute for it.

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