The Royal College of Pathologists welcomes Lord Carter’s review as a contribution to the discussions about how NHS services can be transformed in the best interests of patients. Minimising extreme and unjustified variations in the cost and quality of care should be supported.

However, the experience of attempts by the NHS to transform pathology services in recent years suggests that many of the proposals are unrealistic and are not based on sufficiently accurate cost and activity data.

Pathology is a clinical analytic and advisory service that works across hospitals and community services, helping to manage the demand for investigations and to ensure that the quality of the results of these investigations is maintained.

There are risks that commissioners and providers of NHS services will assume that one solution applies to all, whereas the reality is that service complexity needs to be understood before making changes. Clinical teams are in the ideal position to provide this advice in the best interests of patients.

The experience of service transformation in pathology is that accurate data reflecting the complexity of service activity and costs is essential. Competition can drive quality down as well as up, the cheapest service is not necessarily the best, and consolidation not always the answer.

In a longer response, the College has made several considered recommendations to enhance the ability of NHS England and the Department of Health to achieve the standardised quality and cost they are seeking. The College is keen to be involved in finding workable solutions for the challenges that face the NHS and the specialty.