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 Tunbridge Wells Hospital to referring clinicians and the amounts charged by Spire for those services are set out below:

  • Use of consulting rooms: £17 per hour or any session 2.5-3.5 hours is charged at a flat rate of £38
  • Medical secretarial services: £21 per hour (including VAT)
  • Office rental: This is charged at £26 per m² utilised. Office space varies and charges range from £50 to £371 per month.

“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 are held twice a year, focusing on clinical safety and governance issues. MAC Chairs from all of Spire’s 39 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 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.

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:

  • Consultant golf day, held on 7th July 2017 at a cost of £75 per head
  • Consultant golf day, held on 6 July 2018 at a cost of £59 per head
  • Consultant golf day, held on 12th July 2019 at a cost of £88 per head

Clinician Financial Interests in Spire

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:

  • Mr Mark Cynk owns 100% of a holmium laser used at the hospital
  • £115,200 per annum including VAT is paid for the use of the holmium laser.  Payment is made to Kent Mobile Medical Ltd (Company No. 06777027) of which Mr Mark Cynk is a company director. 
  • Mr Neil Rowson and Professor Ejaz Ansari own 100% of the outpatient ophthalmology equipment
  • Dr Paul Reynolds owns 100% of an ECG machine used at the hospital


Clinician Advisory services to Spire

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 Sarah Dudley, Dr Rebecca Smith (started April 2019) and Dr Caroline Sweeney (started July 2019) are employed on a part time basis at an hourly rate between £40-41 per hour providing health assessment services and were paid £33,713, £11,022 and £8,231 in 2019 respectively.
  • Dr Sarah Dudley took unpaid leave in the year
  • Dr Alexandra Seddon left Spire's employment in December 2018 and no payments were made to her in 2019
  • Mr Nicholas Boyle is Chair of the Medical Advisory Committee at Spire Tunbridge Wells 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 £12,000 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) £500 for each annual medical appraisal undertaken for a doctor designating to Spire for the purposes of revalidation; and (iii) £200 per hour for the preparation of an independent report (up to a maximum of £500 per report) upon request by the Medical Director or Chief Medical Officer.