Guide
Publishing consultant fees, and what PHIN requires
What PHIN is, where its authority comes from, and why a from-price on your website is worth publishing.
The short answer: the Private Healthcare Information Network, PHIN, is the body that collects and publishes information about private healthcare in the UK under an order made by the Competition and Markets Authority. Consultants and private hospitals have obligations to submit data to it, and there are obligations around being transparent with private patients about fees. The precise wording of those obligations is set out in the CMA Order and in PHIN’s own guidance, and that is where you should check it.
What is PHIN?
PHIN is an independent, not-for-profit organisation that publishes information to help patients compare private healthcare. It collects data from private hospitals and from consultants about the activity they carry out for private patients, and it publishes what it collects on its website in a form that patients can search. The purpose, as set by the CMA, is to give private patients the information they need to make an informed choice, which the CMA found they were not getting.
Where does PHIN’s authority come from?
From the CMA’s Private Healthcare Market Investigation Order 2014. The CMA investigated the private healthcare market and found that patients lacked information about consultants, hospitals and fees. The Order was one of the remedies. It set up a role for an information organisation, which is the role PHIN fills, and it placed obligations on hospitals and consultants to supply that organisation with data. The Order is a legal instrument, not a voluntary scheme.
What do consultants and hospitals have to submit?
At the level of principle, hospitals submit data about the private activity that takes place on their premises, and consultants are required to supply information that PHIN needs in order to publish a profile of them, including information about their fees. PHIN publishes guidance for consultants on what it needs and how to supply it, and it operates a portal for doing so. The scope of the data, the timing and the format are matters for PHIN’s current guidance rather than for a summary here.
What does the Order say about fees?
The Order places obligations on consultants about telling private patients what they will be charged, and about supplying fee information for publication. The principle is that a patient should know, before committing to a consultation or a procedure, what the consultant’s fees are, and that fee information should be available for comparison. The exact obligation, including what must be provided, when and in what form, is set out in the Order and in PHIN’s guidance. Check the current versions of both, because the CMA has reviewed the Order since it was made and the guidance is updated.
Why publish a from-price on your website?
Because it answers the question a patient is asking before they ask it. A patient looking for a private consultation wants to know roughly what it costs before they pick up the phone. If the website says nothing, some will phone and take up practice time on a question that could have been answered on the page, and others will go to a site that does answer it. A from-price, clearly labelled as a starting figure with what it does and does not include, serves the patient and cuts the wasted enquiries. It also aligns with the direction the CMA has set, which is towards transparency.
What does a from-price need to say to be honest?
- What the figure covers, for example an initial consultation, and what it does not
- That the figure is a starting point and that a written quote follows assessment
- Whether hospital charges, anaesthetist fees and follow-up are separate
- The date the figure was last checked
How does this interact with insurers?
Insured patients often do not pay the consultant directly, but they still want to know whether the consultant is recognised by their insurer, and whether any shortfall might arise. A fees page that states insurer recognition alongside self-pay pricing answers both patient groups on one page and reduces the back-and-forth with the practice.
Where should you check the precise obligation?
With PHIN, which publishes guidance for consultants on data submission and fee information, and with the CMA, which publishes the Order and the material that accompanies it. This guide states the principle. The obligation itself, and any change to it, is in those documents.
This is general information rather than regulatory advice. Meeting the obligations under the CMA Order rests with you as the regulated party, and the current PHIN and CMA guidance is the authority on what they are.
Source: Competition and Markets Authority, Private Healthcare Market Investigation Order 2014, and PHIN, guidance for consultants, read 11 September 2026.
Common questions
Is submitting data to PHIN voluntary?
No. The obligations on consultants and hospitals come from the CMA’s Private Healthcare Market Investigation Order 2014, which is a legal instrument. Check PHIN’s guidance for what applies to you.
Do I have to publish my fees on my own website?
The obligations in the Order concern telling patients about fees and supplying fee information for publication. Whether and how to publish on your own site is a separate decision, and a clearly labelled from-price is a reasonable one.
Where do I find the exact requirement?
In the CMA Order and in PHIN’s current guidance for consultants. Both are published and both are updated, so read the current version rather than a summary.
Want the checklist as a document?
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