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Cross-border medical treatment

In a recent ruling the European Court of Justice (ECJ) confirmed that patients can conditionally seek medical treatment in other member states without authorisation. Lourde Soop, UK lawyer and legal advisor with Sweden�s Institute of Medical Law, tells Greg Bousfield why this is significant...

A European Court of Justice (ECJ) ruling (C-385/99) has given more precision to the debate on cross-border medical treatment, and confirmed several earlier ECJ rulings that patients can conditionally seek limited medical treatment in other member states with comparable medical systems without authorisation.

The ECJ ruled that the principle of freedom to provide services precludes Netherlands�s legislation requiring prior authorisation for non-hospital care provided in another member state by a non-contracted provider. In the case of hospital (excluding out-patient) care, by contrast, the requirement for prior authorisation is justified, the court ruled.

"This is a very significant judgment because for the first time, the ECJ has made a distinction between hospital and non-hospital care," comments Lourde Soop, UK lawyer and legal advisor with Sweden�s Institute of Medical Law. "Basically, if you require non-hospital treatment, you can go to a non-contracted provider of your choice without asking permission."

The judgment also follows previous rulings by stipulating � but not defining - the condition that treatment could only be sought offshore if there was �undue delay� domestically. The treatment sought could also not form part of a trend which would undermine the patient�s national health system, or treatment which was not medically recognised.

In the UK, the chief distinction in current NHS policy is between emergency care (chiefly for holiday-makers) and those who seek out treatment. The Department of Health indicated to LegalUpdater, that for short-term treatment arising from an emergency, presumably occurring overseas, the NHS allows that free �or reduced-cost� emergency, largely hospital, treatment is available for UK citizens (Form 111). However, for patients seeking out treatment �for medical care, or if you require ongoing treatment for a pre-existing condition� (Form 112) must write a letter to local UK health authorities explaining the reasons for this together with a letter from their NHS consultant explaining why offshore treatment is necessary. Otherwise, �you will have to pay for the treatment you receive and you will not be able to obtain a refund of the costs.�

Although the latest judgment suggests that UK patients would have to request permission to seek out treatment outlined in Form 112, behind this category lies a further distinction, between cheaper out-patient-style treatment and treatment requiring hospitalisation � and defining where the division lies might be the subject of the next round of ECJ rulings, Soop suggests. "People assumed that previous judgments just related to hospitals of any sort. I think the next area of the court�s focus is likely to be in relation to the actual definition of hospital treatment as opposed to non-hospital treatment. I think that will cause some problems," she predicts.

Given complaints about NHS services, it is possible that the clarification may arise from a UK complaint to the ECJ. "People in the UK are demanding these rights more than in any other country in the EU," she says. A starting point to a complaint is perhaps an obstacle to freedom of movement and services arising from the NHS�s definition of �undue delay�.

Currently only Denmark and the UK routinely send patients overseas for treatment. In Denmark, unless treatment is received within two months, patients are entitled to be treated abroad or to have private treatment in their own country, all paid for by the state. The UK Department of Health says it �aims to reduce the maximum inpatient and day case waiting times to 3 months by 2008� but admits that much longer waiting periods are now experienced.

"The ECJ sought to define undue delay saying that it should be assessed strictly from a medical point of view and not according to the actual waiting time for the treatment requested," she says. "However there is likely to be continued litigation on this point."

Until these matters are better defined, perhaps by the ECJ, "I don�t think the state of play is going to be vastly different in the UK," Soop says. "I don't think that this judgment will change anything with regard to the numbers seeking hospital treatment abroad."

In the longer term, a move towards more comprehensive service provider agreements with contractors abroad is likely to be developed by member state governments to take advantage of the �health tourism� possibilities raised by this and four previous ECJ rulings on cross-border medical provision, she says.(28/05/03)

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