The Royal College of Physicians has produced their own risk assessment of the health and social care bill. The government has been told by the information commissioner's office to publish their own internal risk assessment, but despite losing a FOI appeal, have so far refused to do so.
Who are the Royal College of Physicians?
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The Royal College of Physicians of London is a British professional body of doctors of general medicine and its subspecialties. It was founded in 1518 as the College of Physicians and received the royal charter in 1674 from King Henry VIII, the first medical institution in England to become a Royal College.
So, not a bunch of unionised trots.
Here is the report. It's exactly as bad as you're imagining.
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Risks
A detailed list of potential risks inherent in the Bill, referenced where appropriate, can be found at Appendix A; but these can be summarised into four overarching concerns:
1. Loss of a comprehensive National Health Service
Clause 1 repeals the Secretary of State's legal duty to provide or secure the provision of a comprehensive health service, and replaces it with a duty to “promote” a comprehensive health service. Clause 12 confers on Clinical Commissioning Groups (CCGs) the power to determine what care is necessary to “meet all reasonable requirements” of the population for which they are responsible (with the exception of emergency care which is mandated). As such, it is possible for CCGs to cease to commission services which are currently available through the NHS if they do not consider them to meet a reasonable requirement. Access to such services in the future might be available only through private healthcare.
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2. Increased costs
The development of more overt market mechanisms, and the greater role for the independent sector in the provision of healthcare is likely to increase the overall cost of providing healthcare. Increased costs will arise from the need for greater regulation of both market mechanisms and the quality of care commissioned and delivered by an increased number of providers and commissioners.
The market environment will increase transaction costs and lead to the loss of economies of scale as large providers could be broken up. Market incentives will lead to supplier induced demand where hospitals perform unnecessary and potentially harmful treatments to generate income.
Management costs will also increase as the new GP groups (CCGs) will need to buy in legal and procurement expertise to support them in fulfilling their new commissioning responsibilities.
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3. Reduced quality of care
In a competitive market there is no incentive for providers to collaborate to provide integrated pathways of care. Indeed, such collaboration may be seen as anti-competitive and incur substantial financial penalties. Integration is essential to enhancing the quality of care for patients, particularly for those with conditions such as cancer and chronic illnesses who will receive care from a wide range of organisations and sectors.
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4. Widening Health inequalities
It is likely that the most vulnerable who already suffer the worst health outcomes will be disadvantaged as a result of the enactment of the Bill. Operation of choice in an environment of multiple providers will disadvantage those who are less educated, have reduced access to resources such as the internet, or for other reasons are less able to navigate the healthcare market.
Of particular concern are the risks identified around safeguarding children from abuse and neglect. The loss of designated professionals and weaknesses in information sharing between organisations poses an increased risk to the safety of children
It goes on to describe those risks in greater detail and why the bill might lead to them.
How closely does this match the civil service's own risk assessment? Will we know before the bill becomes law?