As the Health and Social Care Bill for England moves back to the House of Commons today (September 6) for its report stage and third reading, doctors' leaders have told MPs that the government's planned reforms still present an "unacceptably high risk to the NHS."

They threaten the Service's "ability to operate effectively and equitably, now and in the future," Dr Hamish Meldrum, chairman of council at the British Medical Association (BMA), has written in a letter sent to all MPs. 

While acknowledging the government's efforts to address some of the concerns expressed about the Bill to date, the BMA still believes it should be withdrawn or, at the very least, be subject to further substantial amendments. There "continues to be an inappropriate and misguided reliance on 'market forces' to shape services," with the Bill embedding "a more central role for choice without a full considerate of the consequences," which include the "potential to destabilise local health economies," Dr Meldrum writes.

Moreover, he adds that "insufficient thought has been applied to the unintended knock-on effects and long-term consequences of proposals in the Bill," such as those concerning medical education and training and regarding public health, and he also warns of "excessive complexity and bureaucracy."

Dr Meldrum's letter to MPs highlights specific areas of concern within the Bill, including:

- the removal of the cap on how much income Foundation Trusts (FTs) can generate from private patients - the BMA says this could lead to reduced access for NHS patients as FTs seek to increase their income by focusing more on private care;

- the proposed "Quality Premium" for commissioners - the BMA insists that this must be judged against well-defined quality measures and not financial performance, that it must remain separate from GP practice income and that it should only be used to improve patient care;

- forcing all NHS Trusts to become FTs, with the financial stringency this requires - the BMA believes this could compromise patient safety and quality of care;

- that the Bill should reflect an intention that any increase in patients' choice of providers should not be given a higher priority than tackling health inequalities and promoting integrated care;

- ensuring there is a robust and transparent process which has the full confidence of the profession when it comes to how "failing" FTs are dealt with, in order to protect the interests of patients and the public; and

- the lack of satisfactory assurance that the Secretary of State for Health will have ultimate responsibility for the provision of a comprehensive health service, while also allowing other bodies, including the new NHS Board and clinical commissioning groups, day-to-day operational independence.

Dr Meldrum's letter also notes the impact which the government's reforms are having on an NHS charged with finding an unprecedented £20 billion in efficiency savings.

"The focus on the changes already flowing from the reforms is creating a noticeable distraction to efforts to ensure and improve the quality of care," he writes. "The risks are high, not least because the long-term effects of the legislation are likely to be extensive. Meaningful, sustainable reform needs to have the full confidence of patients and those working in the health service," he tells the MPs.