When is a medical tourism facilitator a medical travel agent?According to our Medical Tourism Survey in 2008, around a third of UK medical tourists make their arrangements through a medical tourism facilitator. In some countries, such facilitators account for an even greater share of the market, and their influence is growing. The concern of many is the uncontrolled growth of the sector and the lack of regulation within it.
Let's say that I want to start a medical tourism facilitation business. How easy is it?
What do I need?
- I need a name. I'll call my business "Magical Medical Travels".
- I need a telephone. I've got one of those.
- I need an internet connection. I've got one of those.
- I need a web site to generate some patients. I can create something that will do the job, using a cheap package such as 1&1 web hosting.
- I need some hospitals and clinics overseas that are prepared to pay me a commission, if I send patients to them. I'm sure that I can find a few of those.
- I suppose I need to find someone in the destination country who can look after the patients while they are there.
- ....and maybe some documents that I can get the patient to sign.
- Oh, and it might be a good idea to invent a few patient testimonials...
- Do I need to be medically qualified? Well, I'm known as Dr Pollard on several internet forums, and I have some drpollard@ email addresses, so that should be fine.
- Cash flow. Well, if I take money up front from patients, and then pay the treatment providers late, that's not a problem. I'll buy some online advertising, and leave it a few months before paying the bill.
- I'll pay a few hundred pounds to join one of the medical travel associations; that will give me some credibility.
Which brings me back to the title of this blog: "When is a medical tourism facilitator a medical travel agent?"
In the UK and Europe, that's actually quite an important question. Let's expand the question...
"What's the difference between a medical tourism facilitator who sells a consumer a package of accommodation, travel and treatment and a regular travel agent who sells a consumer a package of accommodation, travel and related holiday activities?".
In the UK, the activities of travel agents are highly regulated. For example, the "Package Travel, Package Holidays and Package Tours Regulations" were introduced to protect consumers from unscrupulous travel agents. A package is defined as the "pre-arranged combination of at least two of the following components - transport, accommodation, other tourist services".
So, is a medical tourism facilitator a travel agent? Some would say...yes!
And if that's the case, the Package Travel Regulations come into force and my new facilitation company, Magical Medical Travels might have some problems. It means my company will be subject to controls over:
- What I can say in my brochure or web site.
- The nature of any contracts I make.
- The information I provide to the consumer.
- Changes in price.
- Security in the event of insolvency. ie. I will need to be bonded.
With regard to the latter, when someone books a holiday in the UK, many will look to see if the travel company is ABTA (Association of British Travel Agents) bonded. Which means that the company has placed a bond with an authorised institution, based on their turnover. The minimum bond is £20,000.
Even if you pay the bond, you can't join ABTA, unless you comply with their Code of Conduct, and submit to random inspection.
Let's compare this to the medical travel business, a sector that was once described last year by Avery Comarow, as the "The Wild West of Medical Care Abroad".
- Anyone can set up as a medical travel agent/facilitator.
- There's no regulation.
- There's no compulsory code of conduct.
- Anyone can join one of the associations such as MTA or IMTA.
- There's no bond required.
So what's the industry been doing to fix the problem?
- IMTA launched a Patients' Bill of Rights some while back.
- Treatment Abroad has encouraged better business practices into the market, by introducing the Treatment Abroad Code of Practice for Medical Tourism. We now have eight providers who have signed up to the Code and have been externally assessed
- MTA launched an accreditation programme in July 2008 , then hastily renamed it a certification programme, but still hasn't certified anyone (according to their web site).
- The Council on the Global Integration of Healthcare shows promise with its current development of a Medical Travel Facilitator Certification programme and its work on the Medical Tourism Facilitation Standards in the area of oncology.
In the perfect world, we need an ABTA of the medical travel world - properly funded, run by a truly representative Board of Directors, that is answerable to its membership, that publishes an annual report and financial statements, that only accepts members who meet clearly defined criteria, that inspects member premises at random, and that requires all members to place a significant bond for the protection of medical travellers.
Likely?
I doubt it.
What is more likely....
As medical travel grows, especially in a background of government driven initiatives such as the European Directive on Cross Border Healthcare, governments will begin to regulate medical travel facilitators and agents. Bodies such as ABTA in the UK and similar organisations in other countries would probably favour and support this.
"What makes a medical travel agent any different and exempt from regulation?", they would say.