The Home Office has lead a consultation exercise on this proposal, here is our detailed response by Pathway Medical Director, Dr Nigel Hewett.”
Response ID ANON-S8QC-SU6D-1
Submitted on 2013-08-09 13:05:22.312892
1. What is your name?
Name: Dr Nigel Hewett
2. What is your email address?
Email: info@pathway.org.uk
3. What is your organisation?
Organisation: Pathway Charity
4. Are there any other principles you think we should take into consideration?
Use this box to enter your response:
5. Do you have any evidence of how our proposals may impact disproportionately on any of the protected characteristic groups?
Use this box for your response:
6. Do you have any views on how to improve the ordinary residence qualification?
Use this box for your response:
Past and current government policy has resulted in large numbers of undocumented migrants who have been here for many years. They already have difficulty in accessing health care resulting in more expensive medical emergencies resulting from untreated conditions. People in this situation are already at the extremes of health inequality and any further reduction in access to health is likely to have the unintended consequence of increasing health care costs by increasing the need for emergency care
7 Should access to free NHS services for non-EEA migrants be based on whether they have permanent residence in the UK?
No
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Many UK born homeless people as well as vulnerable migrants are already denied access to primary care because of requirements to prove address and migrant status. Any tightening of the rules will increase the likelihood of discrimination and inevitably lead to more neglected infectious diseases (even with a legal right to treatment for HIV or TB, how are they to access that without a GP, except by presenting in dire and expensive emergency to A&E). Excluding people from medical treatment before it becomes an emergency with inevitably increase demand on emergency services.
8 Do you agree with the principle of exempting those with a long term relationship with the UK (evidenced by National Insurance contributions)? How long should this have been for? Are there any relevant circumstances under which this simple rule will lead to the unfair exclusion of any groups?
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I specialise in health care for homeless people in London Hospitals. We regularly see sick and destitute UK citizens repatriated by Red Cross or other charities who are admitted to hospital from the airport. Often people in this situation have lived on the margins of society in the UK before living in a similar way abroad. They have to be treated on humanitarian grounds and have no means of paying any bills they might be responsible for. Discharge is often delayed by the effect of habitual residency tests restricting access to housing or social care. Restricting access to health care according to ability to prove previous NI contributions will just add another layer of expensive bureaucracy which has no practical prospect of recovering funds from people who are sick, destitute UK citizens with nowhere else to turn.
9 Do you support the principle that all temporary non-EEA migrants, and any dependants who accompany them, should make a direct contribution to the costs of their healthcare?
No
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Although superficially attractive this idea will be entirely unworkable in practice. It is already clear that the majority of migrants make a net positive contribution to the UK economy, and all aspire to work and pay taxes. Trying to extract funds from a small destitute minority will be financially inefficient and is very likely to actually increase costs to the NHS by resulting in more people presenting in extremis requiring emergency in patient treatment.
10. Which would make the most effective means of ensuring temporary migrants make a financial contribution to the health service?
Other – please enter your response in the box below
Other – do you have any other proposals on how the costs of their healthcare could be covered?
Please also use this box for any other related comments:
Ensure that all temporary migrants have the right to work and pay taxes and so pay for any health care costs in the same way as everyone else in the UK
11. If we were to establish a health levy at what level should this be set?
Other amount (please specify below)
Other – please specify an amount and make any related comments in this box:
None – an impractical idea which will cost more in administration than it will gain
12 Should a migrant health levy be set at a fixed level for all temporary migrants? Or vary according to the age of the individual migrant?
Not Answered
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Neither, not a practical idea.
13 Should some or all categories of temporary migrant (Visa Tiers) be granted the flexibility to opt out of paying the migrant levy, for example where they hold medical insurance for privately provided healthcare?
Don’t know
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The problem will be what to do with the sick and destitute people who shouldn’t be here, but never the less are. The UKBA never engages promptly with such people so they inevitably present for emergency care with neglected health problems.
14 Should temporary migrants already in the UK be required to pay any health levy as part of any application to extend their leave?
No
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Those closest to destitution and ill health are least likely to be able to pay any levy.
15 Do you agree that non-EEA visitors should continue to be liable for the full costs of their NHS healthcare? How should these costs be calculated?
Yes
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16. Do you agree we should continue to charge illegal migrants who present for treatment in the same way as we charge non-EEA visitors?
No
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Practically, people in this situation are unable to pay so any administrative effort to identify and charge people in this situation cannot result in net benefit to the NHS
17. Do you agree with the proposed changes to individual exemptions? Are any further specific exemptions required?
No
Are any further specific exemptions required?
Please also use this box for other related comments:
18. Do you agree with the continued right of any person to register for GP services, as long as their registration records their chargeable status?
No
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Expecting GP’s to determine chargeable status and collect fees will impose a huge administrative burden for little practical benefit. In order to effectively address Health Inequalities we need to make access to primary care easier for excluded groups, these proposals will only make it harder.
19. Do you agree with the principle that chargeable temporary migrants should pay for healthcare in all settings, including primary medical care provided by GPs?
No
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Those most in need of treatment will be those least able to pay. By making it even more difficult to access primary care we just increase the numbers of people requiring expensive emergency life saving hospital care. This proposal will increase health inequalities and increase the net costs to the NHS
20. Do you have any comments or ideas on whether, and if so how, the principle of fair contribution can best be extended to the provision of prescribing, ophthalmic or dental services to visitors and other migrants?
Use this box for your response:
Again this is a sledge hammer to crack a walnut. The issue of Health Tourist is very minor in the scale of the NHS and attempting to address this will inevitably be bureaucratic, expensive and counterproductive
21 Should non-EEA visitors and other chargeable migrants be charged for access to emergency treatment in A&E or emergency GP settings?
No
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Discouraging access to emergency care for those who can’t pay will only result in cases presenting late and requiring more expensive treatment
22. What systems and processes would be needed to enable charging in A&E without adversely impacting on patient flow and staff?
Use this box for your response:
This is entirely impractical and will result in a bureaucratic burden that will exceed any potential revenue gains
23. Do you agree we should extend charges to include care outside hospitals and hospital care provided by non-NHS providers?
No
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24. How can charging be applied for treatment provided by all other healthcare providers without expensive administration burden?
Use this box for your response:
This is not possible
25. How else could current hospital processes be improved in advance of more significant rules changes and structural redesign?
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26. How could the outline design proposal be improved? Do you have any alternative ideas? Are there any other challenges and issues that need to be incorporated?
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Bringing this system in for a new arrival sounds sensible, but how do you deal with undocumented migrants who cannot prove when they arrived? People in this situation are destitute and prone to infectious diseases. Even if they theoretically are entitled to free treatment on public health grounds, how are they to access treatment if turned away from primary care and discouraged from presenting to hospital. This will just increase the risk of exposure to untreated TB and HIV for the established UK population.
27. Where should initial NHS registration be located and how should it operate?
Use this box for your response:
Although superficially attractive, practically those most in need of treatment will be destitute and undocumented, so unable to prove who they really are and what their status is.
28. How can charges for primary care services best be applied to those who need to pay in the future? What are the challenges for implementing a system of charging in primary care and how can these be overcome?
Use this box for your response:
Primary care is not set up to charge patients. Health inequalities are already increased by incorrect and arbitrary local “rules” about proving address or immigration status. Any change can only increase health inequalities, increase administrative costs and bureaucracy with no net gain in revenue.
29 Do you agree with the proposal to establish a legal gateway for information sharing to administer the charging regime? What safeguards would be needed in such a gateway?
Don’t know
Use this box for your response:
30 Do you agree that we should stop issuing S1 forms to early retirees and stop refunding co-payments and if not, why?
Yes
Use this box to give reasons for your response: