In regard to the duty of candour, an adverse outcome is described as one that has, or could, result in more than minimal harm and the provision of healthcare was, or may have been, a factor. The committee is concerned that the estimate of ongoing costs for the new duty of candour reflects the number of incidents classified as moderate. If the definition of 'more than minimal harm' is to reflect a low level of harm, then it's likely, of course, that the cost could be significantly higher. We recommend the Welsh Government prepares a sensitivity analysis to show the impact of changes in the number of incidents on the ongoing costs arising from the introduction of the duty of candour. Once again, I recognise the Minister's earlier statement in that respect.

Now, the RIA quantifies the legal services arising for the duty of candour as £30,000 for NHS bodies, which is based on the existing legal costs for Putting Things Right—the campaign that was used, of course, to launch the new NHS complaint procedure back in 2011. This equates, on average, to an annual cost of £3,000 for each local health board and NHS Trust in Wales. However, the Public Services Ombudsman for Wales has told the Finance Committee on a number of occasions about his concern regarding the volume of health complaints that are made to his office. Therefore, we have concerns that the legal costs could be significantly higher and recommend the Welsh Government undertakes further work, including a sensitivity analysis once again, to demonstrate a range of costs.

Finally, the majority of the total cost of the Bill, £6.1 million, is associated with establishing and running costs of the new citizen voice body, including, of course, significant information and communications technology transitional costs. The citizen voice body will replace the seven community health councils in Wales and will be set up to represent the interests of the public in health and social care.

The ICT cost estimate in the RIA is reflected in the net cost of the Bill, and that's £2.13 million. However, the supporting information includes costs that range from £2.13 million up to £3.12 million. Whilst we acknowledge that ICT can enable and facilitate flexible working practices, the RIA doesn't set out sufficient evidence to demonstrate this. Therefore, we don't support the use of the low cost estimates in the assessment of the financial implications. We recommend the regulatory impact assessment should reflect the potential range of ICT costs rather than the low cost estimate. As I said, I acknowledge the Minister's intention to provide much of the additional information—financial information—that we have requested as a committee, and we look forward to seeing that in due course.

I'll briefly conclude my comments in my capacity as an Assembly Member for North Wales, because the Minister will know that there is strong support for the North Wales Community Health Council. It's been a strong and effective advocate for patients and citizens in north Wales over the years. It's been at the forefront of the debates on the Tawel Fan scandal; on the special measures debacle; and on the loss of the special care baby units, which eventually came back, subsequently, after quite a long campaign. It made 500 unannounced visits to wards across north Wales last year, helping to hold the health board and the Welsh Government to account and ensuring that patients in north Wales get the services that they deserve. 

This Bill, as we know, proposes to scrap the North Wales Community Health Council. It'll diminish the voice of north Wales's patients and it'll centralise that important scrutiny function to a, potentially, far away and more remote body, no doubt based in Cardiff. If there is going to be a new body, I, for one, would like to see it based in north Wales. So, I urge you, Minister, to scrap your proposal, to retain the North Wales Community Health Council and to ensure that patients and citizens in north Wales have the strong and independent voice and advocate that we all deserve.