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Transport services, triage and medical advice provided remotely

Categories:
  • Organisations we regulate

This regulated activity covers two main service types:

  • transport (ambulance) services
  • remote medical advice

Types of service that should be registered for this regulated activity

If you plan to provide any of the following types of service then it is highly likely you will need to register for this regulated activity:

  • ambulance service
  • remote clinical advice service

You may need to register for this regulated activity if you plan to provide any of the following types of service:

  • acute service
  • hospital for substance misuse
  • community mental health service

Transport services

Services are captured by this regulated activity where they involve a vehicle that was designed for the primary purpose of transporting people who require treatment. Transport services provided in vehicles that have a different primary purpose (such as taxis, volunteers using their private cars, or mortuary vehicles and Dial-A-Ride vehicles) are not captured in this regulated activity, even though they may be registered with the Driver and Vehicle Licensing Agency as ambulances. Search and rescue transport services are also currently exempt because the service is provided under arrangements made on people’s behalf by a government department.

Because it is the nature of the vehicles used that determines the need to register, transport services provided in ambulances operated by hospital providers will require registration, as well as transport services provided by ambulance only providers. The term 'designed for' will apply to vehicles used to transport people who require treatment not only where this was the manufacturer's original design, but where a vehicle has been made suitable for this purpose (e.g. modification, livery, etc). Air ambulances and water ambulances are also included in this regulated activity. However, providers of air ambulances services are exempt from the activity where the aircraft used is registered with the Civil Aviation Authority and that same provider is not carrying out treatment to a patient. Air ambulance providers are also exempt if the transport is not carried out in England or if it is carried out under travel insurance arrangements. Refer back to section 2 of this document and in particular ‘third party exemptions’ for further detail. 

This regulated activity relates to transport, but will not cover other activities that may be provided in or from a vehicle, such as 'treatment of disease, disorder or injury' or ‘diagnostic and screening procedures’.

Our view is that this regulated activity will normally cover routine, planned patient transport related to treatment.

The transport activity will not apply where a provider only uses a vehicle to transport a person within the confines of an event site. As an example, if a person attending or participating in a sporting event requires treatment, and as such, is carried in a vehicle from one part of the event ground to another, then registration for that transport is exempt. However, if the same situation arose and the person was carried from the event ground to hospital, then registration will be required.

We will take a proportionate and reasonable approach if emergency, unplanned treatment in this context includes some aspects of other regulated activities on an exceptional basis (such as 'diagnostic and screening procedures', 'surgical procedures' or 'maternity and midwifery services'). We will also take a proportionate and reasonable approach if, in exceptional circumstances, a provider transports a patient outside an event ground and ordinarily would not consider or plan to do this.

Some ambulance providers may also need to register for the regulated activity of 'treatment of disease, disorder or injury'. For example, where they employ health care professionals and ordinarily carry out treatment.

Where procedures are carried out, such as emergency tracheotomy, insertion of a chest drain or intubation, for the purpose of registration these would be considered as treatment for disease, disorder or injury, not as the regulated activity of 'surgical procedures'.

Where procedures that require specialist surgical training and equipment are an expected part of the service, for example, thoracotomy or amputation, we regard these as constituting the regulated activity of ‘surgical procedures’. Therefore providers that are equipped, and expect to carry out such procedures must register for that activity. However, if a provider carries out emergency procedures unexpectedly, we would be proportionate and would not regard this as committing an offence where they are not separately registered for 'surgical procedures'.

Providers registering for this activity will not have to additionally register for the regulated activity of 'diagnostics and screening procedures' if they only carry out the following diagnostic procedures along with transport:

  • 12-lead ECG
  • use of an AED
  • pulse oximetry
  • use of a sphygmomanometer
  • analysis of urine or stool samples by means of dip stick or other reagent
  • taking blood, urine samples or swab specimens

Remote advice

Remote advice is a regulated activity when all of the following apply:

  • the advice is medical
  • it constitutes triage or is responsive (for immediate attention or action as opposed to, for example, a service in which a person electronically submits questions to a provider who provides responses at some later time, or when a person seeks general health care or lifestyle advice)
  • it is provided over the telephone or by electronic mail
  • it is provided by a body established for that purpose (as opposed to, for example, the occasional provision of advice by a body such as a hospital or university on an informal basis)

The second consideration above means that:

  • NHS Direct and any other organisation established for the purpose of providing telephone or internet-based medical advice where immediate action or attention is needed or triage provided will be covered
  • ambulance control centres will be covered where they provide triage by means of telephony services
Last updated:
15 May 2019