Regulation of healthcare providers

The healthcare sector is heavily regulated and governed by legislation as diverse as that regulating administration of drugs, competition between healthcare providers, complaints about treatment given by the National Health Service (NHS), data protection, freedom of information requests, food hygiene, mental capacity of patients in consenting to treatment, procurement in supplies and regulation of professional standards of individual practitioners. There are also a number of guidelines such as National Institute of Clinical Excellence (NICE) and supervisory bodies appointed to have oversight of different aspects of healthcare provision that providers are expected to adhere to. See Practice Note: NICE Guidance.

Regulation relating to public healthcare in England is primarily governed by the Health and Care Act 2022 (HCA 2022); Health and Social Care Act 2012 (HSCA 2012), both of which made substantial amendments to the National Health Service Act 2006 (NHSA 2006) and other NHS legislation. HSCA 2012 is the product of a number of initiatives that seeks to put patients first, improve healthcare outcomes and change the structure of commissioning powers.

Regulation of healthcare (both public and private) can be divided

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When time is critical—the balance of convenience (International SOS Assistance UK Ltd v Secretary of State for Defence)

Public Law analysis: This case concerns a successful application submitted by the contracting authority under regulation 96 of the Public Contracts Regulations 2015 (PCR 2015), SI 2015/102, to lift the automatic suspension imposed by regulation 95(1), alongside the refusal of a request for an expedited trial by International SOS Assistance UK Ltd (the claimant). The judgment highlights the court’s careful consideration of urgency surrounding the implementation of new arrangements, in this case, the provision of medical services to military personnel overseas. The case provides useful clarification on the factors considered when determining whether to lift an automatic suspension. It highlights the court’s approach in weighing the potential advantages to the contracting authority of lifting the suspension against the interests of the claimant and the wider public in maintaining it, particularly where lifting the suspension could enable the award of a contract offering additional benefits beyond those currently in place. The judgment places a spotlight on the inherent difficulties in assessing damages, noting that such calculations require consideration of complex and uncertain hypothetical scenarios. As a result, the court concluded that damages could not be regarded as an adequate remedy for either the claimant or the contracting authority in this case. Considering then the balance of convenience, Mr Justice Eyre determined that the public interest in implementing the new arrangements promptly, particularly given consideration to the operational readiness and national security concerns, outweighed the claimant’s risk of uncompensated loss, such that the suspension was lifted and the request for expedition refused. Written by Sam Pringle, senior associate and Charlotte Jones, trainee solicitor at DWF Law LLP.

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