Where the duties come from
The Competition and Markets Authority investigated the private healthcare market and made the Private Healthcare Market Investigation Order 2014. Among other things, the Order includes measures to increase the information available to patients about consultant fees and about the performance of consultants and private hospitals. The CMA varied the Order in 2017 after a remedy review[1].
The Private Healthcare Information Network, PHIN, is the information organisation that publishes this data. Hospitals submit performance data and consultants submit fee data to PHIN for publication on its website[2].
This guide summarises the duties for clinic owners and practice managers. Consultants should check the detail with PHIN, their hospitals and their own advisers.
What consultants must provide
Hempsons' summary of the consultant fees remedy sets out three duties, each with a start date[3]:
| Duty | From | What it involves |
|---|---|---|
| Outpatient information letters | 31 December 2017 | Before an outpatient consultation, the estimated cost, the consultant's relevant financial interests, the insurers that recognise them, a reminder for insured patients to check outpatient cover, and standard wording about PHIN |
| Pre-treatment information | 28 February 2018 | Before further tests or treatment, the reason for them, an estimate of the cumulative cost of the recommended pathway, what the estimate excludes, and standard wording about PHIN |
| Fee reporting to PHIN | 31 December 2018 | Outpatient fees, standard fees for the most frequently performed procedures, and standard terms and conditions, for PHIN to publish |
PHIN described the publication requirement in January 2019 as a legal requirement for consultants offering private treatment or consultations to publish the typical fees they charge self-paying patients, with consultants able to enter a range to cover those typical fees[4].
Where compliance stands now
Compliance took years to build. In October 2025, the CMA wrote to PHIN marking a "silver" milestone and reported that 96 per cent of consultants published their consultation fees for self-paying patients, and 82 per cent of private hospitals were submitting volume, length of stay, adverse events and patient feedback data[5]. In July 2026, the CMA published a letter welcoming PHIN and the industry reaching the "gold" milestone of full compliance with the Order[2].
For patients, this means consultant fee information is increasingly available on PHIN. For clinics, it means a consultant's fees on your website can be compared directly with what PHIN shows.
What this means for your clinic website
The Order's fee duties run through PHIN and through letters to patients. This guide does not claim that the Order requires a clinic to publish consultant fees on its own website. But if your website shows consultant fees, they should be consistent with what the consultant has reported to PHIN and with what patients receive in their outpatient letters. Different figures in different places erode trust and invite complaints.
A practical approach for consultant-led clinics:
- On each consultant's profile, link to their PHIN profile so patients can see the published fee and performance information.
- Show consultation fees on the website, using the same figures or ranges as PHIN.
- For procedures, explain what a typical package includes and excludes, and say that a written estimate is provided before treatment.
- Set a review date to check website fees against PHIN whenever fees change.
If a consultant's fees differ between the hospitals or clinics where they practise, say which fee applies at your site rather than giving a single figure that may not match what the patient is later quoted.
Our clinician profile pages include a field for the PHIN link and a reminder in the handover guide to keep fees in step.
Presenting fees clearly
Fee pages work best when they answer the obvious follow-up questions before a patient has to phone:
- What the fee covers: consultation length, any tests included, the written report.
- What costs extra: follow-up appointments, tests, hospital fees, anaesthetist fees.
- Whether insured patients pay anything directly, and that they should check their cover.
- How and when payment is taken, and the cancellation terms.
Avoid phrases like "from" prices that only apply in rare cases. If a fee varies, give the typical range and explain what moves it.
Fees and advertising rules
Fee information is still marketing, so the general advertising rules apply. One specific limit matters for some clinics: prescription-only medicines may not be advertised to the public[6], and the ASA's guidance on Botox says that includes price lists[7]. Consultation fees can be shown; prices for prescription-only medicines should not be.
Insured patients and fee information
Many private patients are insured, and they need different information from self-paying patients. The outpatient letter duty includes a list of the insurers that recognise the consultant and a reminder for insured patients to check their policy's outpatient cover[3]. A clinic website can support that by saying, on each consultant's profile, which insurers recognise them, and by explaining on the fees page that insured patients should check their cover and any excess before booking.
Insurer recognition changes, so it belongs in a field your practice manager can update, not in a paragraph buried in a profile.
A consultant profile checklist
- Name, specialty and Specialist Register entry, linked to the GMC register.
- Link to the consultant's PHIN profile.
- Consultation fee for self-paying patients, matching PHIN.
- Insurers that recognise the consultant.
- Procedures carried out at your clinic, linked to the treatment pages.
- Where and when the consultant sees patients.
- A note that a written estimate is provided before any further tests or treatment.
Explaining fees for procedures and packages
Procedure prices are where patients are most likely to be surprised. A package price for a procedure may or may not include the hospital stay, the anaesthetist, follow-up appointments, physiotherapy or the treatment of complications. The pre-treatment information duty requires consultants to give an estimate of the cumulative cost of the recommended pathway and list what the estimate excludes[3]. A clinic website can help by explaining, in general terms, what a typical package covers, what it does not, and that every patient receives a written estimate before treatment. Avoid presenting a package price as all-inclusive unless it is.
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Questions clinics ask
Does the Order apply to GPs and therapists?
The duties described here apply to consultants offering private treatment and consultations, as PHIN and the CMA describe them. If you are unsure whether they apply to a particular clinician, PHIN can confirm. Clear fee information is good practice for every clinician either way.
Should we copy PHIN data onto our website?
Linking to the consultant's PHIN profile is simpler and keeps the data current. If you show fees on your own site, make sure they match.
What if a consultant's PHIN profile is incomplete?
That is for the consultant to resolve with PHIN. In the meantime, avoid linking to a profile that shows missing or outdated information.
Sources
Checked on 29 October 2026.
- Competition and Markets Authority: Private Healthcare Market Investigation Order 2014 (regulator)
- Competition and Markets Authority: CMA letter to PHIN welcoming achievement of gold compliance milestone, 2 July 2026 (regulator)
- Hempsons: Newsflash: New competition law requirements for the private healthcare sector including NHS private patient units (secondary source)
- Private Healthcare Information Network: New legal requirement on consultants to publish their private healthcare fees, 15 January 2019 (information body)
- Competition and Markets Authority: Private Healthcare Market Investigation Order 2014: Silver milestone (letter to PHIN), 10 October 2025 (regulator)
- Committee of Advertising Practice: The CAP Code: Section 12, Medicines, medical devices, health-related products and beauty products (regulator)
- CAP News: A fine line - the dos and don'ts of advertising Botox, 17 October 2019 (regulator)
