Compliance with CMA Order 2014

In October 2014, the Competition and Markets Authority (the "CMA") published the Private Healthcare Market Investigation Order 2014 (the "Order") following its investigation into the private healthcare industry. The Order imposed requirements on private hospital operators to disclose certain information in relation to referring clinicians (as defined by the Order) for the benefit of patients. Full details about the investigation and the Order can be found on the CMA web page. The information provided by Spire Healthcare below is required by the Order.

"Higher value" services

The services provided at Spire Bristol Hospital to referring clinicians and the amounts charged by Spire for those services are set out below:

  • Use of consulting rooms: £20 per hour
  • Medical secretarial services: £26.77 per hour
  • Office rental: £50 + VAT per week 

“Low value” services

The following “low-value” services are also provided to referring clinicians with practising privileges at this hospital: 

  • General services to ensure clinical safety (eg in-house training, chaperones) 
  • Operational services such as patient bookings/admissions (including online booking and payment for consultations), access to a virtual consultation solution, administrative services and billing, and insurance/indemnity cover in respect of NHS patients 
  • General marketing support, including production of consultant directories, promotional activities, web profiles etc
  • Basic workplace amenities such as teas/coffees/refreshments, subsidised meals, car parking, stationery

Corporate hospitality events for referring clinicians

Spire group Medical Advisory Committee (MAC) Chairs conferences

Spire group Medical Advisory Committee (MAC) Chairs conferences are held twice a year, focusing on clinical safety and governance issues. MAC Chairs from all of Spire’s hospitals are invited to attend, with their partners, and are joined by members of Spire’s senior management.

  • In 2017, the conferences were held in Berlin and Aylesbury and the total cost of the events was approximately £85,000 and £25,000 respectively.
  • In 2018, a conference was held in Berlin and the total cost of the event was approximately £88,000.
  • In 2019, the conferences were held in Lisbon and Aylesbury and the total cost of the events was approximately £95,000 and £28,400. MAC Chairs were also invited to attend the Spire Healthcare Senior Management Conference in Birmingham in June 2019 (8 MAC Chairs attended at a cost of £845 per head).
  • No conferences were held in 2020.
  • In 2021, conferences were held virtually via Zoom as well as face to face in Aylesbury. The total cost of the events in 2021 was approximately £2,120 and £19,300 respectively. 
  • In 2022, the conferences were held in May at Spire’s head office in London and in November at Oulten Hall, Leeds. The total cost of the events in 2022 were approximately £6,463 and £20,338 respectively.
  • In 2023, the conferences were held in June at M Restaurant in London and in November at The Midland Hotel, Manchester. The total cost of the events in 2023 were approximately £2,931 and £20,389 respectively.

In 2019, Spire Healthcare held a series of 5 dinners with 70 consultants from across 5 Spire hospitals for the purpose of meeting various members of the Spire Executive team and listening to and engaging with consultants. The cost of the dinners ranged from £60 to £80 per head. No dinners were held in 2020, 2021, 2022 and 2023.

Corporate hospitality events held by the hospital at no charge to referring clinicians are set out below, together with the cost of providing such events:

2018: Rugby Autumn International tickets at £160/head (Wales vs Scotland), £145/head (Wales vs Australia) and £165/head (Wales vs South Africa). Spire Bristol Hospital Staff and Consultant Christmas Party estimated cost of £37,500.

2019: Rugby International tickets at £347/head (Wales vs England) and Cheltenham Gold Cup VIP tickets at £436.25/head. Spire Bristol Hospital Staff and Consultant Christmas Party estimated cost of £36,500.

2022: MAC dinner at £56/head (total cost £840), Spire Bristol Hospital Staff and Consultant Christmas Party £20/head, 236 tickets sold.

2023: Consultant dinner at £157 / head (total cost £628) Spire Bristol Hospital Staff and Consultant Christmas Party £20/head, 280 tickets sold. 

Clinician financial interests in Spire Healthcare

Private hospital operators are required to disclose details of referring clinicians practising at their facilities, who have a share or financial interest in those facilities or any equipment used there. Some clinicians may own shares in Spire Healthcare Group plc, which were acquired either at the admission price or through trading on the main market of the London Stock Exchange. Where a referring clinician has an individual web page profile on this hospital website, relevant shares and/or financial interests are disclosed there. For referring clinicians who do not have an individual profile, their shares and/or financial interests are shown below:

  • Dr Ladli Chandratreya holds less than 0.1% of the shares in Spire Healthcare Group plc
  • Dr Judith Nolan holds less than 0.1% of the shares in Spire Healthcare Group plc
  • Dr David Cottrell holds less than 0.1% of the shares in Spire Healthcare Group plc
  • Mrs Uma Gordon uses her own Ultrasound machine in the Outpatient Department
  • Dr Sabine Klepsch uses own Nerve conduction studies machine in the Outpatient Department
  • Mr William Neary uses his own Veinwave machine in the Outpatient Department

Clinician advisory services to Spire Healthcare

Private hospital operators are required to disclose details of certain paid services provided by referring clinicians to private hospitals operators in addition to exercising practising privileges at that hospital. This information can be found on the referring clinician’s individual web page profile on this hospital website.

  • Dr Ben Walton is Chair of the Medical Advisory Committee at Spire Bristol Hospital. Their role is to provide senior professional advice to the Hospital Director and Director of Clinical Services in order to support effective medical governance and oversight. They are paid £14,000 per annum for this role and are also entitled to receive the following fees for the provision of additional ad hoc services: (i) £750 for chairing a Professional Review Committee; (ii) £200 per hour for attendance at regulatory or other national body meeting (capped at £500); (iii) £500 for each annual medical appraisal undertaken for a doctor designating to Spire for the purposes of revalidation; (iv) £1,000 per annum for undertaking the role of governance lead in addition to MAC Chair; and (v) £200 per hour for the preparation of an independent report (up to a maximum of £500 per report unless otherwise agreed due to complexity) upon request by the Medical Director or Chief Medical Officer.
  • Dr Simon Lewis has been appointed as a pre-operative lead anaesthetist to run and improve pre-assessment clinics at the hospital. Duties include the establishment of anaesthetic clinics to support preoperative assessment services (POA), the development of local guidelines for use in POA and the implementation of out of area pathways. Dr Simon Lewis is paid £12,000 per annum to provide these services to the hospital.
  • Dr Ben Walton has been appointed as Lead Intensivist at the hospital. Duties include mapping admissions into ITU, organising Consultant cover for ITU patients; supporting the training and development of local ITU staff competencies; providing Consultant Leadership for ITU and providing interface to the Medical Advisory Committee for all ITU needs. Dr Ben Walton is paid £12,000 per annum to provide these services to the hospital.
  • Dr Priyanka Mehta is Spire Healthcare’s Haematology Advisor specialising in haematological malignancies and Dr Mehta is paid £200 per hour on an ad-hoc basis (undertaking approximately 25 hours per year) to act in this role. The role includes providing a professional clinical opinion as required to support the development of Haematology treatment protocols within Spire Healthcare.
  • Dr Amit Bahl is a national cancer consultant advisor for Spire and provides support to the National Oncology Pharmacists within the Governance team and support for the Spire iQemo Library of Chemotherapy treatment protocols for a payment of £40,000 per annum.