The Lancet has released a paper analysing the affects of the different Brexit scenarios upon the UK’s National Health Service (NHS). This updates their previous analysis outlined in a 2017 paper, which was necessarily limited by uncertain political signals.
The paper outlines the different conditions under which Brexit could occur; namely:
- Withdrawal Agreement, with a transition period until December 2020
- Northern Ireland backstop, if no agreement has been reached by the end of the transition period
- No Deal, leaving the EU on 29th March 2019 with no agreement in place
Recruitment of health professionals
Brexit under the Withdrawal Agreement would be the preferred option as EU nationals will continue to benefit from residency and employment rights, freedom of movement and mutual recognition of qualifications until the end of the transition period. In other scenarios, only Irish citizens’ freedom of movement will remain active. EU-based employment rights such as the Working Time Directive will only apply if the UK has mirrored these in domestic legislation.
Brexit under the Withdrawal Agreement would ameliorate the worst of the anticipated impacts of Brexit. Under this agreement reciprocal healthcare agreements (such as the EHIC) would continue, funding from the European Investment Bank would continue until existing projects are completed, and it is likely that funding from the UK government would be higher as the UK economy will remain more stable.
“Many analyses predict a much slower rate of growth than if the UK remained in the EU, with the impact increasing as the UK–EU relationship becomes more disconnected.”
In all other scenarios, the only right guaranteed to remain in force is the reciprocal healthcare agreement with Ireland, which is protected by the Common Travel Area. All other reciprocal agreements will end on 29th March 2019 in the event of a no-deal scenario, and in December 2020 in the event that the withdrawal agreement and subsequent transition period do not result in a long-term agreement.
All Brexit scenarios involve the UK losing membership of the European Medicines Agency, thus the UK will be unable to input into important decisions regarding licensing using the centralised procedure. However, the UK-based Medicines and Healthcare Regulatory Agency (MHRA) will continue to make licensing decisions regarding the decentralised procedure, and there will be mutual recognition with the EU in this area.
In the event of a no-deal Brexit, or the failure to agree upon an agreement to take effect after the transition period, the UK would become a third country and the ensuing lack of clear regulatory frameworks could make the UK a less attractive place to launch new medicines. There are concerns that some pharmaceutical companies may not have transferred their licenses to EEA-based entities by this time, whether that be 29th March 2019 or December 2020.
Under the Withdrawal Agreement the EU and UK would continue to share information in important areas such as disease surveillance, cross-border clinical trials and the safety monitoring of medical products. However the Northern Ireland backstop would only maintain information-sharing on medical products of human origin, and a no deal Brexit would end all information sharing.
For further information regarding these measures, including the impact upon decision-making within EU institutions, please read the original Lancet report here.