Health and Social Care Act 2008 (Regulated Activities) (Amendment) Regulations 2026

Baroness Harding of Winscombe Excerpts

Wednesday 15th April 2026 Grand Committee

[Lord Lansley (Con)]

I shall speak briefly to this statutory instrument and ask a number of questions, if I may, to which I hope the Minister will be able to respond. I think that I understand the structure of what is proposed and the exclusion of first aid so that it is not covered, but when I look at the providers that are likely to be affected, I am trying to work out carefully which are the providers concerned. I am assisted by a friend who is part of the Faculty of Sport and Exercise Medicine and who said that it had undertaken a survey.

It seems to me that many of the people who responded to that as healthcare professionals may well be working in registered providers already, so they may be concerned about the need to register in relation to the services that they provide at events but in fact they do not need to register. However, the event organisers themselves may need to register if they bring healthcare professionals on site in order to provide services that go beyond first aid at their event. I am trying to understand how, when the department went out and identified 89, or whatever the number was, potential providers that were not already registered, it ended up with a figure of 36, which seems very low. It certainly bears no comparison to what those who are working in the sector believe would be the number of presently unregistered providers. We need to understand who these 36 are, the character of those providers that the department has identified and why there is such a discrepancy between that and what others have been saying. I would be grateful if the Minister would tell us much more about that.

As a practical example, are all football clubs, or the major football clubs in the Premier League, the Championship and so on, already registered with the CQC? Clearly, they, as organisations, provide continuing healthcare to their players. Do we not need to worry about any of that? Is an event like one of the big festivals that take place already registered, because it has put a team together in order to provide more than simply first aid? Perhaps we are worrying about a need for registration when actually we do not need to worry so much.

I have only one other question. An essential part of the follow-up to the Manchester Arena inquiry was the preparation of an event healthcare standard. Would the Minister be kind enough to update us on that process? Where does it stand and when might we see its publication for consultation?

[Baroness Harding of Winscombe (Con)]

My Lords, I will also ask a few questions. I declare my interests as the senior steward—namely, the chairman—of the Jockey Club and as the mother of an elite athlete.

I spent last weekend at two quite different sporting events, juggling my time between the Grand National and the Home Internationals lacrosse competition, as my daughter played for England for the first time— I did check with her that I was allowed to mention that in the Grand Committee. I mention them both because while one is really a grass-roots sporting event—it has a small crowd, but none the less there is an ambulance in attendance because it is a potentially dangerous sport—the other, the Grand National, is the second largest attended sport in the country and the second most watched sporting event on television. As I understand it, both are captured by the same changes being proposed today.

I express my condolences to everyone who was affected by the tragedy at Manchester Arena. In no way do I want to suggest that the questions I am posing negate the need to address the recommendations of the public inquiry. It is hugely important that we learn the lessons.

First, I took some time to speak to a former chief medical adviser of the British Horseracing Authority, Dr Jerry Hill, who told me that a clear standard of healthcare for events is an extremely positive move. I put on record that I wholeheartedly support the event healthcare standard. I understand that there has been good consultation on the draft and that, in Dr Hill’s view, it will help event medics fight their corner for resource. He told me that, at the moment, event medics often feel that they are behind Portaloos and security in priority at events. It is important that we recognise that we need that standard.

However, in moving from that standard being guidance to putting it on a statutory footing—I appreciate that this SI does not do that, but it sets us on that path—we need to evaluate formally whether the draft is effective. As I understand it, the DHSC was somewhat swamped by people wanting to participate in evaluating the draft, and that it was perhaps not following the more scientifically robust approach that a number of sports suggested—I think two focus groups were planned to evaluate the draft. Can the Minister assure us that that event healthcare standard will be evaluated to a scientifically robust standard rather than that of a more politically normal focus group? It is very important that we get it right.

Secondly, I also understood that, as my noble friend Lord Lansley says, the CQC’s initial impact assessment had claimed that only 36 healthcare providers would need to register. Horseracing alone thinks that we have 350 individual clinicians who would need to register, even allowing for the fact that each clinician tends to work in three different sports. Potentially, the Faculty of Sport and Exercise Medicine UK’s estimate of 23,000 is an overestimate. Even if it is one-third of that, it is still massively more than the CQC expected.

I also understand that, in November 2024, the CQC said that it had a maximum capacity to register new providers of 1,000 per year. If we are not very careful, with all the best intentions we will be setting up a bureaucratic quagmire, which will mean that events, big and small, will not be able to find suitably registered clinicians to support them. What assurances can the Minister give us that the CQC can cope with the workload? Has the CQC recruited, or does it intend to recruit, anyone from the sports or cultural events sector? In the past, the CQC has had, in maybe more traditional healthcare settings, a bad habit of sending non-specialist inspectors—my noble friend Lord Lansley is laughing at that, but it is serious business. The best example I have is of occupational therapists being sent to inspect ambulance services.

What assurance can the Minister give us that the CQC is going to recruit the suitable expertise to deliver on this important obligation? Where will it sit in the priorities of the CQC which, after all, has an awful lot of important work to do? It currently has an interim chief executive and a chairman who wants to leave, so I am nervous about quite so much going on to the CQC. I support others who have called for pragmatism in the implementation of these regulations to allow time, if the CQC is struggling to put the resource to them that they need.

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[Baroness Harding of Winscombe (Con)]

My Lords, I will be very brief. The Explanatory Notes say that a full impact assessment was not completed because

“no significant impact on the private, voluntary or public sector is foreseen”.

I think it entirely foreseeable that there could be significant cost and complexity, as well as an inability to deliver the healthcare benefits that we all seek, for two important sectors of society that provide important glue as well as economic value. Whether we are talking about grass-roots or world-class sporting and cultural events, if we implement this SI badly, there will be substantial negative consequences.

I am aware that I have asked an awful lot of questions. May I be presumptuous and ask the Minister for a meeting with the department and the CQC so that a number of us can properly understand how this measure will be implemented?

[Baroness Grey-Thompson (CB)]

My Lords, I declare an interest as the chair of Sport Wales; with that, I sit on the board of UK Sport. I am also a board member of Active Travel England.

I reiterate the comments made by others about how horrendous and horrific the Manchester bombing was, as well as how significant an impact it had on so many people. The recommendations are important. I absolutely understand why we want to protect people and improve the system. I am also going to ask a number of questions, so I would be very happy for a follow-up afterwards.

I have spoken to a number of organisations in the wider sport industry. It is fair to say, I think, that there is a level of concern about the statutory instrument that we are debating today and the impact that it could have on the wider sports industry. I understand that the Sport and Recreation Alliance has written to the Minister; I would be interested in the reply and to know what further work has been undertaken.

I know from speaking to a wide group of people who work in the sports industry that they generally feel as though His Majesty’s Government have failed to engage with the sector properly and have not understood the significant, negative effect that this measure may have on the provision of medical care at events. There is a real risk of this preventing some sports events and activities from going ahead, or going ahead without the medical cover that they currently have, in order to avoid the consequences of the proposals.

The noble Baroness, Lady Harding, made some interesting points on registration. Medics often work in a voluntary capacity across a number of events of various sizes. It is important that these people are not registered multiple times. We should try to avoid some of the failings of DBS checks, where people are registered on lots of different systems. That does not solve the problem that we are trying to solve.

The Sport and Recreation Alliance has called for a commitment to create a specific exemption for all treatment provided to athletes, performers and officials. This is also an important area for us to look at. We should include spectators in that as well, because some events have lots of spectators and some have absolutely none. Many believe that this would not be contrary to the recommendations of the Manchester Arena inquiry and could solve many of the issues that the regulations might cause.

Can the Minister explain what further considerations have been given to understanding the impact on sport and sporting events? I wonder if clarification is needed on the definition of different events and the sizes, because they are very different. Also, what is understood by “injury” and “first aid”? People working on the ground might struggle to understand that. I was also wondering whether the Department for Culture, Media and Sport has provided a view on this and on its impact.