We asked you whether further regulation of independent health care services in Scotland is needed. Additional information was asked about whether independent health care services offered by pharmacists and pharmacy technicians, which are not provided from a registered pharmacy or under the terms of an NHS contract, should be regulated by Healthcare Improvement Scotland (HIS). We also asked whether independent medical agencies where services are provided by a medical practitioner, dental practitioner, registered nurse, registered midwife, dental care professional, pharmacist or pharmacy technician, along with unregulated independent medical agencies that are headquartered in Scotland and operate entirely online, should be regulated by Healthcare Improvement Scotland (HIS). We also asked you, should HIS be able to cancel the registration of any independent health care service that fails to pay its continuation fees after a certain period of time.
After the removal or reconciliation of duplicate responses, we received a total of 67 responses to the consultation. 47 responses were from individuals and 20 from organisations. The responses showed strong public support for further regulation of independent health care services in Scotland, as well as for independent healthcare services provided by pharmacists and pharmacy technicians, which are not provided from a registered pharmacy or under the terms of an NHS contract, to be regulated by Healthcare Improvement Scotland, and for independent medical agencies, including those that are headquartered in Scotland and operate entirely online, to be regulated by HIS in the same way as other independent healthcare services. There was also a consensus of support towards HIS being able to cancel the registration of any independent health care service that fails to pay its continuation fees after a certain period of time.
We have published all non-confidential responses to our consultation and the analysis of these responses. Direct links to these publications can be found below.
View submitted responses where consent has been given to publish the response.
The providers of independent health care in Scotland and the UK are many and varied, and the complexity of this area of health care provision continues to increase. The Scottish Government wants all health care provided to people in Scotland to be safe, appropriate and carried out by those with the right qualifications.
To achieve this vision, we need to ensure that independent health care services provided in Scotland are effectively regulated. We want the regulation of independent health care in Scotland to reflect the current landscape of provision, which includes an increasing number of services provided online. It is also important that this regulation is self-funding.
We ran a consultation in 2020, which focused on non-surgical cosmetic procedures which pierce or penetrate the skin, such as lip enhancements and dermal fillers. This consultation also asked whether services provided by pharmacists who undertake independent health care practices (including non-surgical cosmetic procedures), outwith the terms of an NHS contract should be regulated by Healthcare Improvement Scotland.
As the independent health care landscape in Scotland continues to change, we believe this may mean that the way independent health care is regulated needs to be updated. We are taking this opportunity to run a new consultation to seek views as to whether further change is needed and how it should happen.
We are proposing to make three changes to the way independent health care in Scotland is regulated:
1. Enable Healthcare Improvement Scotland to regulate independent health care services provided by pharmacists and pharmacy technicians which are not provided under the terms of an NHS contract or from non-General Pharmaceutical Council (GPhC) registered premises;
2. Enable Healthcare Improvement Scotland to regulate independent medical agencies providing health care services which consist of or include the provision of services by a medical practitioner, dental practitioner, registered nurse, registered midwife, dental care professional, pharmacist, or pharmacy technician. This would include independent medical agencies operating entirely online. However, services provided by either a pharmacist or pharmacy technician in pharmacy premises registered with the GPhC or a nurse agency regulated by the Care Inspectorate (officially known as Social Care and Social Work Improvement Scotland) would be exempt; and
3. Enable Healthcare Improvement Scotland to cancel the registration of any independent health care service where there has been a failure to pay continuation fees.
As the independent health care landscape in Scotland evolves, we believe the way independent health care is regulated may need to be updated.
We are running this consultation to seek views as to whether further change is needed and how it should happen.
Where respondents have given permission for their response to be made public, and after we have checked that they contain no potentially defamatory material, responses will be made available to the public at http://consult.gov.scot. If you use the consultation hub to respond, you will receive a copy of your response via email.
Following the closing date, all responses will be analysed and considered along with any other available evidence to help us. Responses will be published where we have been given permission to do so. An analysis report will also be made available.
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