The impact of Brexit on the relationship between the Republic of Ireland and the United Kingdom will not become truly apparent until 2020, according to MEP, Ms Mairéad McGuinness, who explained that the European Parliament anticipates but cannot guarantee that things will remain as they are with Britain up until that point.
The Vice President of the European Parliament opened an IMO seminar on the challenges posed by Brexit to health services and healthcare collaboration between the Republic and the United Kingdom.
Following that, a new relationship will have to be established between the UK and Ireland, which she warned may be difficult, as the UK want ‘managed divergence’, expressing concern that because the vote was to leave there may be political pressure on the UK to have a semblance of divergence, to prove that they’ve taken back control.
“The difficulty with that is, in all other areas and particularly in health, you really don’t want divergence, you want regulatory compliance and alignment. Particularly in relation to drugs, medical devices, cross border healthcare, you don’t want divergence”.
She stated that the UK are seeking a “bespoke deal”, commenting: “I don’t get a sense from our side that we’re prepared to draft a particular bespoke deal for the UK that would result in cherry picking. That is the difficulty for us here, on one level, Ireland, because of where we’re placed, want a very close relationship with the UK”.
On of the most immediate challenges that Brexit poses is how patients from the Republic can access health services in Northern Ireland and the UK and vice versa.
Regarding cross-border collaboration, Ms McGuinness commented that uncertainty will “prevail and persist until we know otherwise”.
“If we could put the politics aside and put patient safety and security to the forefront, one would hope that both sides in these negotiations would do the right thing. But it does require some give and take on both sides, I think particularly on the UK’s side because they’re the leaving party” she claimed.
In 2016, 574 patients received high tech treatment in the UK under the treatment abroad scheme, while 700 patients accessed care in Northern Ireland last year under the patients’ right in cross border care directive. The basis under which these patients received treatment in the UK stems from shared membership of the European Union and will need to be re-established when the UK leaves the EU.
Therefore, a new basis will have to be agreed upon to support ongoing and future collaboration in health services and to ensure timely and seamless access to care for patients in the border areas.
The Cooperation and Working Together (CAWT) partnership between health and social care services in Ireland and Northern Ireland has facilitated a number of successful collaborative projects in healthcare in the border regions, managing funding from the EU INTERREG Programme and the Special EU Programmes Body.
Many of these projects have resulted in longer-term service level agreements including agreements for the provision of GP out-of-hour services, shared dermatology clinics, ENT Services and Renal services in the border areas.
New funding arrangements will be need to support future collaboration after 2020.
Other cross-border service level agreements exist as a result of collaboration and capital investment from both sides of the border including Radiation Oncology services and Emergency Cardiology Services at Altnagelvin Hospital, as well as the provision of all-island paediatric cardiac surgery services for children with congenital heart disease at Our Lady’s Children’s Hospital Crumlin, Dublin.
Cross-border cooperation is a source for concern in the area of public health, particularly in the area of health protection, and Mr Leo Kearns, CEO of the Royal College of Physicians in Ireland, emphasised the need for the teasing out of future cooperation in data sharing and emergency planning.
Dr. Denis McCauley, IMO GP Committee member and Donegal Coroner, offered a cautioning word, saying; “There has been increased sophistication in our cross-border health collaboration. It is vitally important that we remain vigilant during the Brexit negotiations and that this collaboration is not threatened.
“Diseases do not recognise borders”, he added.
Brexit may also affect professional mobility and alter the current basis for the mutual recognition of qualifications between the Republic of Ireland and the UK. At the moment, there are 3,196 doctors registered with the General Medical Council in the UK who received their primary medical degree in Ireland and 742 doctors registered with the Medical Council in Ireland who received their primary medical degree in the UK.
Many Irish graduates complete their postgraduate training and/or spend a period of time in the UK before returning to Ireland, meaning that a bi-lateral agreement will be required between Ireland and the UK.
There will also be a level of pressure on Ireland, as the Republic will need to become more competitive in attracting and retaining medical professionals due to the smaller pool of countries from which the NHS will have to recruit from.
“I think when it comes to Northern Ireland, because of the peace project aspect, there is a huge willingness at a European Union level to try and continue the funding and I would gather from the UK side that they would like to see that happen too.
“So again the question is, post 2020, will there be support to continue these types of initiatives in the health area? This is uncertain but we would all hope that it will happen and will work towards trying to make that happen”, Ms McGuinness explained.
An additional challenge could arise relating to access to and the cost of certain medicines where the market is shared with the UK or medicines that are imported through the UK .
Differing regulatory requirements in each jurisdiction may affect the cost of medicines or may deter manufacturers from supplying the Irish market if they consider it too small.
Regarding medical devices, Ms McGuinnes claimed that the pharmaceutical sector and the medical devices sector have been “knocking down our doors in Brussels”, seeking advice because the reality of Brexit has begun to set.
She noted: “There is a question mark over medical device products that will be stored in a UK warehouse. Those products, even from manufacturers across the EU, may not be eligible for sale on the EU market.
The Vice President warned that customs controls coming into place could lead to delays, meaning higher costs, which would be bad for business, as well as for patients; “if you look at medicines and some of the figures 45 million packs are supplied by the UK to the EU of 27 every month and, in reverse, 37 million from the EU 27 to the UK. If there is border and regulatory divergence, it could lead to very significant delays in the pharmaceutical supply chain”.
Dr McCauley called for the prioritisation of clarity over political ‘constructive ambiguity’, stating: “There is no place for ambiguity, we have to be very aware of what could happen, plan for it and try to prevent it.
“We have to have forward thought, we can’t be an after thought, we have to be there and actually doing it”, he concluded.
Ms Rita Purcell, Deputy CEO of the Health Products Regulatory Authority (HPRA) underscored the pertinence of medicines in relation to Brexit due to they’re highly regulated.
She acknowledged the potential challenge for Ireland in that the UK acts as a physical barrier between the Republic and the EU: “65 per cent of the medicines on our market are transiting what they call the ‘road bridge’, which is the UK, between Europe and Ireland. That has huge implications for our products on our market.
However, she also outlined the opportunity that Brexit will create for Ireland: “Ireland is a great county to do business with as a pharmaceutical company; the top 10 companies are here, we’re the seventh largest manufacturer of pharmaceuticals in the world and we have a huge reputation for supporting manufacturing. With Brexit, there will be companies in the UK who will have to find a new home if they want to serve as the big European marketer, so hopefully it will be an opportunity for Ireland to attract new products”.