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 Bushey Hospital, Spire Bushey Diagnostic Centre and Elstree Cancer Centre to referring clinicians and the amounts charged by Spire for those services are set out below:

  • Use of consulting rooms £20.50 per hour
  • Medical secretarial services £19.20 per hour
  • Use of consulting rooms at Elstree Cancer Centre £20.50 per hour

“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 Oulton Hall, Leeds. The total cost of the events in 2022 were approximately £6,463 and £20,338 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 and 2022.

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:

Corporate Hospitality Event

Cost (£) per head

2 February 2017 – AGM 93 attendees


4 February 2017 - England V France Rugby x 10


21 April 2017 – Battlefield tour – France x15


15 September 2017 – Micky Flannigan Comedy x 20


1 February 2018 – AGM/ Launch event – 83 attendees


17 March 2018 - England V Ireland Rugby x 10


24 April 2018 - Cardiac specialty meeting x 13 


17 May 2018 - Jason Manford Comedy x 17


20 June 2018 - Retirement dinner x 17


10 November 2018 - England V New Zealand Rugby x 8


15 December 2018 - Consultant and staff party x 208


6 July 2019 - Festival of speed x 8 


3 October 2019 - AGM - 53 attendees


14 December 2019 - Consultant and staff party x 207 


4 December 2021 - Watford FC hospitality x 6 


26 February 2022 - Rugby x 7


October 2022 - MAC Chair meeting


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 Ruby Sharma holds less than 0.1% of the shares in Spire Healthcare Group plc
  • Dr Mogera Chandra holds less than 0.1% of the shares in Spire Healthcare Group plc

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.

Consultants providing advisory services to the Hospital under part-time positions are paid at the rate of £2,000 per day. Details of part-time positions held are set out in relevant consultants’ web profiles on this hospital's website.

  • Mr Tim Waters is Chair of the Medical Advisory Committee at Spire Bushey 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 Pushparaj Shetty and Dr Savita Marathe have been appointed as pre-operative lead anaesthetists (and Dr Shetty is also specialist for bariatric patients) to run and improve pre-operative assessment clinics at the hospital. Duties include supporting POA service with signing competencies, teaching sessions for staff, reviewing patient notes, liaising with the anaesthetist and consultant surgeon ahead of theatre procedure. In addition they assess patients face to face if considered to be high risk, to ensure their suitability for surgery. They are both paid £210 per session to provide these services to the hospital.