CMF on Facebook CMF on Twitter CMF on YouTube RSS Get in Touch with CMF
menu advocacy


<< back to submissions

Submission from Christian Medical Fellowship (and in particular members in Scotland) to the public consultation on: Palliative Care (Scotland) Bill - August 2010

Published: 31st August 2010


The Christian Medical Fellowship (CMF) is an interdenominational organisation in the UK with over 4,000 doctor members and around 1,000 medical student members. Of these, more than 400 doctors and 80 students are members in Scotland. All are Christians who desire their professional and personal lives to be governed by the Christian faith as revealed in the Bible. Members practise in all branches of the profession, and through the International Christian Medical and Dental Association are linked with like-minded colleagues in over 100 other countries.

CMF regularly makes submissions on ethical matters to Government committees. CMF Scotland submitted evidence to the Scottish Parliament in 2005 concerning Jeremy Purvis MSP's Dying with Dignity consultation paper; in 2009 to Margo MacDonald MSP's consultation on the Proposed End of Life Choices (Scotland) Bill; and in 2010 to The End of Life Assistance (Scotland) Bill. All submissions are available on our website at We are grateful for the opportunity to give evidence and respond briefly to each question of the consultation.

Do you agree or disagree with the general principles of the Bill?
The modern hospice and palliative care movement was pioneered by Christians, and Christian faith continues to be well represented in the field. CMF Scotland warmly endorses the comprehensive provision of palliative care as needed, not least because its holistic aspect includes spiritual considerations at the end of life. On the ethical principle of justice, such care should be available equitably across Scotland.

Do you believe there should be a specific duty on the provision of palliative care in the NHS (Scotland) Act 1978, over and above the general duty of "providing a comprehensive and integrated health service"?
Notwithstanding this warm endorsement, CMF Scotland nevertheless acknowledges the opposing arguments outlined in the Policy Memorandum. On the one hand, creating a specific duty would emphasise the core importance of palliative care, and we support this; on the other, we understand that there are no corresponding statutory duties regarding other health conditions and needs, and can appreciate that establishing such a precedent in one area might lead to relative neglect of other needs, and have wider political and financial implications.

Do you have any comments on the provisions concerning reporting and indicators contained in the Bill?
Clearly reliable data should be gathered, but this process must not become so onerous as to generate a 'box-ticking' approach that would obviate the real patient- and family-centred priorities of palliative care.

From our medical experience, we would be particularly concerned about the point in time at which the duty to provide palliative care would be triggered. If any statutory duty were to be invoked at too early a point after diagnosis, then given the known difficulties and uncertainties of prognosis, services could be swamped by an excess of cases, some of which would be inappropriate. (For this reason we favour the concept of 'life-limiting' rather than 'life-threatening' – see below.) As the Policy Memorandum says at 45: 'Defining what conditions attract palliative care for the purposes of the Bill is crucial in the application of the legislation'.

Are you content with the definitions contained in the Bill, particularly that of "palliative care"?
We accept the 2002 World Health Organization definition, and its subsequent 9-point supplementation, particularly welcoming the statements that palliative care 'intends neither to hasten or postpone death' and that it 'integrates the psychological and spiritual aspects of patient care'. We agree the Bill's use of 'life-limiting' rather than the WHO's 'life-threatening' and agree the Policy Memorandum's definition of life-limiting as 'encompass[ing] any person with a condition, illness or disease which (a) is progressive and fatal; and (b) the progress of which cannot be reversed by treatment'.

Do you have any comment on the costs identified in the Financial Memorandum?
We take this opportunity to emphasise that palliative care is a core concept that should feature throughout all health care, so that much of it will (unquantifiably) be delivered in primary care and general hospital care. We note the rigorous application of such data as is available, and also the important acknowledgement of 'margins of uncertainty'.

It is our belief that if society's taboo on discussing death could progressively be broken in the context of knowing that good palliative care was reliably available, then many more patients might decline expensive and sometimes fruitless procedures towards the end of life. Thus, cost savings greater than the costs of providing palliative care according to the Bill's intentions might ultimately be achieved.

For further information:

Philippa Taylor (CMF Head of Public Policy) 020 7234 9664
Steven Fouch (CMF Head of Communications) 020 7234 9668

Media Enquiries:

Alistair Thompson on 07970 162 225

About CMF:

Christian Medical Fellowship (CMF) was founded in 1949 and is an interdenominational organisation with over 4,000 British doctor members in all branches of medicine. A registered charity, it is linked to about 65 similar bodies in other countries throughout the world.

CMF exists to unite Christian doctors to pursue the highest ethical standards in Christian and professional life and to increase faith in Christ and acceptance of his ethical teaching.

Christian Medical Fellowship:
uniting & equipping Christian doctors & nurses
Contact Phone020 7234 9660
Contact Address6 Marshalsea Road, London SE1 1HL
© 2019 Christian Medical Fellowship. A company limited by guarantee.
Registered in England no. 6949436. Registered Charity no. 1131658.
Design: S2 Design & Advertising Ltd   
Technical: ctrlcube