Full methodology for estimated Non-surgical Procedures Bill compliance costs: FOI release

Information requested

The Business and Regulatory Impact Assessment estimates compliance costs of £7,000 to £340,000 per business.

Please provide the full methodology, assumptions, and data sources underlying this estimate, including the sources for both the low and high figures and the number of businesses to which each figure was applied.

Response

The answer to your question is that the methodology, assumptions, and data sources underlying all the estimates are included in the Business and Regulatory Impact Assessment (BRIA) itself, or the summary of responses to the BRIA survey attached as an Annex to the BRIA.

The BRIA avoided providing a range in relation to compliance costs, and the range you quote was not given in the BRIA itself. The figure of £7,000 is mentioned once, on page 56 of the BRIA (referring to the PDF version) but is not the lowest potential cost quoted in that paper (nor is it intended as an estimated cost of compliance). The context of this figure is clear, it appears in the summary of responses to the BRIA found in the Annex in a section discussing negative impacts for businesses currently not regulated by Healthcare Improvement Scotland. The full sentence reads:

“One respondent suggested it would cost £7,000 (on a one-off basis) to make such changes.”

The figure of £340,000 is not found in the BRIA at all.

The range £7,000 - £340,000 is however quoted in the Equality and Fairer Scotland Duty Impact Assessment (EQFSDIA) on page 9 in discussing the impact on the protected category of sex. The full and preceding sentence reads:
“87% of responses to a consultation for the Business and Regulatory Impact Assessment associated with this policy were from women, which appears to support what we have been told by stakeholders, that this is a female-led sector. Evidence from these responses suggests potential additional costs or annual losses of between £7,000 and £340,000 in order to comply with the proposed regulatory regime, including registration with HIS, alterations to premises, meeting any required training standard, employing a prescribing healthcare professional or reducing the number of procedures which the business can offer.”

The BRIA is available at: Licensing and further regulation of non-surgical procedures: business and regulatory impact assessment - gov.scot

The EQFSDIA is available at: Regulation of non-surgical procedures: equality and Fairer Scotland Duty impact assessment - gov.scot

Under section 25(1) of FOISA, we do not have to give you information which is already reasonably accessible to you. If, however, you do not have internet access to obtain this information from the websites listed, then please contact me again and I will send you a paper copy.

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