We were delighted to participate in the International Bar Association (IBA) Healthcare and Life Sciences Law Committee 2025 survey on healthcare financing and reimbursement, the results of which were published last month.

The IBA undertakes a topical survey exercise annually, which often involves lawyers from around 60 jurisdictions providing their feedback on a given topic. This year, selected law firms (including Stevens & Bolton) were asked to provide an overview of the current healthcare economy in their country, covering the regulation of healthcare financing, the differences between the public and private sectors, access to healthcare services, pharmaceuticals and medical devices and respective insurance coverage, and how the price of healthcare is kept economically efficient. 

The result of the survey is the production of a global guide to major topics and trends concerning healthcare financing and reimbursement, which the IBA intends will “provide practitioners and industry professionals with a comprehensive overview of the healthcare financial ecosystem of different countries around the globe, as well as straightforward access to the most relevant rules and regulations.”

Some key points from our UK submission to the survey are:

• Eligibility for free healthcare – Most services provided by the UK’s National Health Service (NHS) are free at the point of use for anyone who is “ordinarily resident” in the UK. This includes people who live in the UK on a lawful and properly settled basis, and people who have been given immigration status with indefinite leave to remain.
• How the NHS is structured – The NHS is less a single entity, and more a collective of organisations that collaborate and contract with one another to provide services to local populations. NHS England is currently divided into 42 different Integrated Care Systems (ICS), one for each geographic region. Each ICS includes an Integrated Care Board to commission services from local primary and secondary healthcare providers.
• Regulation of private insurers – As health insurance is optional in the UK, it is offered by private providers and not financed by the government. Insurance policy premiums are generally determined by market forces and/or regulation, the latter including conduct requirements established by the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA). Over the last decade, the Competition and Markets Authority (CMA) has also intervened to ensure that private healthcare practitioners provide transparent pricing information to prospective patients.
• Selling to the NHS – The NHS’s relationship with its suppliers is closely monitored. Suppliers can sell to NHS organisations through a central supply chain process, and the NHS will generally only purchase drugs which have been recommended by the National Institute for Health and Care Excellence (NICE). Drug suppliers are subject to a statutory or voluntary pricing scheme requiring them to pay rebates to the NHS, which ensures that the NHS can afford to purchase the medicines that are administered to patients free of charge.

The completed questionnaires for each jurisdiction that took part in the survey (including Stevens & Bolton’s answers for the UK) can be found on the IBA’s website here.