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QUESTION: So the Department agreed to set up a hepatitis C compensation tribunal, and that became a statutory tribunal under the Hepatitis C Compensation Tribunal Act of 1997. If we just look briefly at that. WITN7418010. So we've got the arrangement of the Act there. If we go, please, to page 4, we can see, bottom ...
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QUESTION: But there was still no acceptance of legal liability by the Government? ANSWER: That's correct. And in fact it's worth, I think, reiterating that the compensation tribunal -- that the first payments under the compensation tribunal were made a year before the Lindsay Tribunal terms of reference were even -- ...
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QUESTION: And if we go over to page 6, we've got Section 4 of the Act, and that tells us who could claim, initially, to the Tribunal? ANSWER: Yes.
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QUESTION: So those diagnosed positive for hepatitis C resulting from anti-D, those diagnosed with positive for hepatitis C as a result of receiving a blood transfusion or blood product, and then we have children and spouses, carers, and dependants. If we just go to the next page, just to pick up something, it's in sub...
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QUESTION: That's how we understand -- the reference to section 5, subsection (3) there, is a reference to -- if we go to the bottom of the next page, it's the third paragraph from the bottom: "An award in respect of aggravated or exemplary damages may be made by the Tribunal where a claimant establishes a legal entit...
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QUESTION: So if a claimant wanted aggravated or exemplary damages, they had to establish that there was a basis for it that was a basis recognised in law. But is this right, they could opt then, instead, for 28a 20 per cent uplift to their compensation? ANSWER: That's correct. Any individual who felt that they ...
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QUESTION: And that came from something called the Reparation Fund? ANSWER: Yes.
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QUESTION: What was that? ANSWER: It was basically a fund that topped up the awards by 20 per cent, in lieu of aggravated or exemplary damages.
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QUESTION: But essentially a fund from the same source, from Government? ANSWER: Yes. Absolutely, yes.
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QUESTION: I don't know whether you know the answer to this because obviously your focus will have been those with haemophilia, but we have heard evidence in relation to the United Kingdom of claims being made to the funds established here for -- by those infected through transfusion being difficult to establish becaus...
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QUESTION: Then is it right to understand that the claimant making the claim to the compensation tribunal could elect for a lump sum, so an assessment of their compensation once and for all, or for provisional damages? ANSWER: Yes, the majority elected for a one-off lump sum award, but there was also the option to take...
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QUESTION: Is it right to understand that the approach that the tribunal was required to take to the assessment of compensation was to apply the same approach that the courts would apply in a claim, a tortious claim, for damages for personal injuries? ANSWER: Yes, my clear understanding is that the tribunal was assessi...
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QUESTION: Then in terms of legal representation, the costs of legal representation were met through this process? ANSWER: Yes.
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QUESTION: So those who were making the claims had the benefit of lawyers to assist them in advancing their claim? ANSWER: Yes. When the tribunal started in 1995, we had a meeting with the members who agreed to go down 32the route of a tribunal. They also agreed that the Society should engage a legal team who wo...
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QUESTION: Then there was a right of appeal against the Tribunal -- ANSWER: Yes.
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QUESTION: -- award to the High Court? ANSWER: That's correct.
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QUESTION: And is it right to understand that in the early years there were a number of appeals because it was thought that the tribunal assessments were too low? ANSWER: Yes.
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QUESTION: Did that have the effect essentially of raising them overall for the future or has the need to appeal to the High Court continued to occur regularly? 33ANSWER: It continues, perhaps not to the same extent. I mean when the vast, vast, majority of appeals to the High Court resulted in a s...
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QUESTION: Now, this obviously covered hepatitis C only, but in 2002 the tribunal's remit was extended to encompass HIV? ANSWER: Yes.
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QUESTION: How did that come about? ANSWER: In 2002 we had an election coming up, again, and we'd had the hearings of the Lindsay Tribunal, including the very powerful public testimony of members, during the course of the tribunal, and in the two years leading up to the tribunal and during the course of the tribunal we...
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QUESTION: So if we go back to your statement, so WITN7418001, pages 28 to 29. If we start at the bottom of page 28, we can see there was an amendment to the 1997 Act through the Hepatitis C Compensation Tribunal (Amendment) Bill, 2002. Then if we go to the next page, you've listed in paragraph 59 those who could ap...
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QUESTION: Then if we go to the next paragraph, you tell us also 35that: "New areas of claim were introduced under the [2002] Act ..." ANSWER: Yes.
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QUESTION: "a. [Child], spouse, father or mother of those who had died could claim under loss of society or psychiatric injury including post-traumatic stress disorder; "b. Partners or spouses of those infected could claim under loss of consortium; "c. Children or spouses of those who died could claim for loss of soci...
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QUESTION: So the significance of the 2002 Act -- is this right -- is twofold. First of all, it establishes, or extends the rights that were conferred by the 1997 Act to those infected through HIV, and then it provides for a wider range of types of claim that's applicable to both those infected with hepatitis C and th...
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QUESTION: In terms of assessment for loss of earnings, which is one of the heads of claim that can be advanced to the tribunal -- ANSWER: Yes.
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QUESTION: -- do you know how the tribunal typically assesses the loss of earnings? ANSWER: I think they bring a number of expert witnesses, they look at the person's educational record, they do IQ tests, they look at the career path they may have had without hepatitis C. There may be opportunities that the individual...
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QUESTION: Then in terms of those who are bringing a claim as a carer -- ANSWER: Yes. 37
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QUESTION: -- effectively for the care that they will have provided, gratuitously, to a relative, how is that cost of care assessed? Do you know? ANSWER: I can't answer that, no.
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QUESTION: In terms of the aggravated and exemplary damages or the 20 per cent uplift, have there been many cases in which claimants have opted to try to establish an entitlement to aggravated or exemplary damages? ANSWER: Not that I'm aware of, no.
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QUESTION: So claimants have typically gone for the 20 per cent uplift? ANSWER: Yes, yes.
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QUESTION: In terms of who sits on the tribunal, I don't mean by name, but what are the kind of -- what kind of individuals are appointed to the compensation tribunal? ANSWER: They tend to be barristers, all of them.
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QUESTION: How important has the availability of legal representation been for the success of the tribunal in your view? ANSWER: Vital. I think the availability of legal expertise and expert witnesses has been absolutely vital, because if you have across the board payments, as we had in '91, then you really don't need...
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QUESTION: You've set out your view in your statement that the tribunal has been a success? ANSWER: Yes.
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QUESTION: And again, you've identified, I think, a number of the factors. One, the availability of excellent legal support. Another, the availability of excellent expert witness support. You've also identified the non-adversarial nature of the tribunal, although you've suggested that there might have been a shift i...
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QUESTION: So we can understand the typical pre-Covid process -- ANSWER: Yes.
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QUESTION: -- so a written application would be submitted -- ANSWER: Yes.
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QUESTION: -- is that right? ANSWER: Yes.
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QUESTION: And that would set out, essentially, the basic facts about the claimant, and then would that written application be accompanied by supporting expert evidence? ANSWER: Yes, there would be a written application. There would be proof from the medical records that individual had been exposed to hepatitis C or H...
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QUESTION: So those would all be submitted to the tribunal? ANSWER: Yes.
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QUESTION: Would there then always be a hearing in every case, or could an assessment be made on the basis of the written material? ANSWER: I'm not -- I think a hearing was -- in every case there was a hearing.
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QUESTION: In terms of the structure of that hearing, there would be the claimant, their legal representative. Would it always be necessary for all the experts to come and give oral evidence? ANSWER: No, not necessarily. Very often the expert's written evidence would be read into the record and taken as read.
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QUESTION: Would it be right to understand that there would be no other side represented? There would be no opposition to the claim? Or was there someone there representing the Department or the Government? ANSWER: There was usually somebody there from the Department 42of Health -- I guess keeping an eye on the ...
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QUESTION: To what extent did the individual have to give evidence to the tribunal in the hearings? Was that always the case? ANSWER: It wasn't obligatory but the vast majority of cases, they gave evidence.
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QUESTION: So would the tribunal be composed, then, of one member? There would be a single lawyer -- ANSWER: Usually, three, usually, yes.
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QUESTION: Usually three? ANSWER: Yes.
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QUESTION: And they would ask -- or could ask questions? ANSWER: Yes.
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QUESTION: But did whoever was there representing the Department, did they play an active role in the proceedings, asking questions? ANSWER: They did at times, yeah. Yes, they did, yeah. But 43the questions were usually directed to the legal team or to the expert witnesses but very rarely to the individual givin...
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QUESTION: Would the Department make competing submissions? So if you have got the claimant's representative making a submission as to how the loss of earnings should be calculated and what figure the tribunal should award, would you have the Department making submissions to say, "No, no, it should be a lesser figure"...
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QUESTION: So it's an element of individual recognition? ANSWER: Yes.
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QUESTION: The recognition of the impact there has been on that individual's life? ANSWER: Yes.
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QUESTION: In terms of the disadvantages of the scheme, would it be right to understand that the major downside has been the length of time it has taken for some cases to be finally resolved? ANSWER: Yes, I mean, I think the process has been very good for the vast majority of people but some cases have taken several ye...
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QUESTION: And has there been any expressions of dissatisfaction 46on the part of those who have made claims, that you're aware of, or, broadly speaking, have those who have participated made their claims to the tribunal been content or accepting of the outcome? ANSWER: Well, I think where there was any level of d...
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QUESTION: There is obviously no such thing as a typical case, but is there a typical length of time that it's taken -- for those who were directly infected, to the primary cases, not the secondary cases, and who were infected as adults, so if we leave aside the additional complications in terms of time that might aris...
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QUESTION: I'm going to move now to a separate issue, which is the health amendment card and the Health Amendment Act -- or the Health Amendment Card Act, I think it 50is. Can you tell us first of all, in broad terms, how the Irish healthcare system works and what a medical card is? ANSWER: Well, a medical card i...
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QUESTION: Now, you've told us, in your statement, how the Health Amendment Act Card came about. Can you just summarise for us, what led to the campaign for that scheme to be 51set up, and what you think swayed the Government and influenced the Government into setting up? ANSWER: It was not a hard battle. Unlike...
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QUESTION: If we just look briefly at the Act, WITN7418005, please. If we go to page 3. We've got the Health (Amendment) Act, 1996, and we can just pick up the essence of it in paragraph 2: "A health board shall make available without charge to persons who, in the opinion of the chief executive officer of the board, h...
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QUESTION: Then if we look at the guide you've appended to your statement, WITN7418011, this is a 2020 piece of guidance about the working of the card, and I think if we can pick it up on page 3, under the heading "Introduction": "This 2020 Information Guide to Services is for persons who contracted Hepatitis C through...
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QUESTION: Then if we go down to the bottom of the page, under the heading "What is the HAA Card?": "The ... Card is for eligible men, women and children who contracted Hepatitis C from the administration within the State of contaminated blood or blood products. It is not the same as a medical card [you've told us wha...
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QUESTION: Then there is reference to a Drug Payment Scheme Card; what's that? ANSWER: That's if you have prescribed drugs there is a limit you have to pay every month, and after that you get it reimbursed anything additional you pay.
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QUESTION: Then this guide goes on to explain that the: "The HAA Card gives eligibility to additional HSE services, on more flexible terms and conditions than the medical card." And then it explains it's for the lifetime of the card holder, and it's personal to the card holder. So it doesn't extend to family and member...
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QUESTION: Was there a concern when this scheme was enacted that 55it would be unfair or amount to some form of queue jumping because it was prioritising or conferring an entitlement upon a particular group of individuals that others would not have? ANSWER: No, because the 3,500 individuals had developed serious m...
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QUESTION: So it wasn't something that was -- has led to any resentment or any sense of unfairness from the rest of the population to your knowledge? ANSWER: No, none whatsoever.
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QUESTION: Then you've set out in your statement, if we go back to the statement, WITN7418001, and we go to page 33, please, paragraph 77. So you've set out in paragraph 77 the services that those who hold the HAA card receive, or are entitled receive? ANSWER: Yes.
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QUESTION: The first is: "Open Access to public hospital facilities for Hepatitis C or any related condition. The cardholder should not have to wait more than two weeks for an 56appointment with their liver specialist and also for their first referral to another specialty. This is generally referred to as the tw...
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QUESTION: Then if we continue through the list of services, so if we go further down the page, we've got: "Access free of charge to a registered [GP] of [the individual's] choice and to all GP medical and surgical services for all medical conditions." 58And you've explained how that is different from the position...
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QUESTION: Then if we go over the page, we can see the list continuing: "Access to chiropody and podiatry services ... "Access to complementary therapies [and that includes] massage, reflexology, acupuncture, aromatherapy and hydrotherapy." And they're all set out in the guide that we looked at a few minutes ago, and ...
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QUESTION: Then if we just go to the next paragraph. We can see, 61here, the reference to home support services. ANSWER: Yes.
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QUESTION: Now, as I understand it, this is something that's distinct from the home nursing service? ANSWER: Correct.
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QUESTION: That's meeting clinical needs, care provided by, or arranged by nurses? ANSWER: Correct.
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QUESTION: This is more along the lines of domiciliary support, assistance within the home with household tasks; is that right? ANSWER: Yes.
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QUESTION: And, again, what's the take-up and importance been of that particular service? ANSWER: There has been a significant take-up of that. A significant number of our members, certainly, would have a home worker who comes in and does tasks around the house: cleaning, cooking, ironing, gardening. They would receive...
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QUESTION: Now, you were asked in your statement whether you thought the HAA card was a success and you've said unequivocally yes. Why is that? Why is that your view? ANSWER: I would have said if we were speaking back in '95, '96, '97, our members were much more concerned about compensation on these issues and the fo...
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QUESTION: And same question as with the compensation tribunal. 63If you were setting up the scheme again from scratch, would you make any changes to it or has it worked in the way you would have wished it to? ANSWER: No, I think I wouldn't make any changes, I think it works very well. I would clarify, perhaps, t...
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QUESTION: And so we have the Hepatitis C Compensation Tribunal (Amendment) Act 2006, which set up the scheme. And I think we've got some regulations? ANSWER: Yes.
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QUESTION: But I don't think we need to look at those. 68If we go back to that guide that we were looking at earlier, because it's got a section on insurance, and think it might be a convenient way of picking it up. WITN7418011, please, page 23. So we've got the heading "Insurance Scheme", travel insurance, mort...
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QUESTION: If you don't fall within either of those categories, I don't know if there are any who would, you then have to make out a case for eligibility? 69ANSWER: Yes.
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QUESTION: But essentially it's proof of infection or acceptance that you were infected and infected through blood or blood products? ANSWER: Yes, but you don't have to keep proving it. So as you say, if you have an HAA card or if you got an award from the Compensation Tribunal, as a person with hep C or HIV then you ...
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QUESTION: Then if we just go back to the top half of the page, so we can see the three types of insurance under the scheme, so: life insurance, mortgage protection and travel insurance. Can I deal with life insurance first of all. How does that work in practice? What does this give people that they would otherwise h...
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QUESTION: Is this underwritten by the state? ANSWER: Yes. And in fact the -- so what happens is, we have two insurance companies who provide policies under the scheme. They have to be accepted by the scheme. And then the insurance company will -- you know, they'll do an evaluation, as they normally do, and then they...
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QUESTION: Just sticking with life insurance for a moment, how 72important has that been for your members? ANSWER: I think it's been very important because it means that individuals can take out life insurance at a reasonable cost; they can provide for their family, their dependants, in the event of their death up...
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QUESTION: Then the second type of insurance, the mortgage protection insurance for a new primary home or repair, renovation or refurbishment of current primary home; does that, essentially, work in the same way? ANSWER: Yes.
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QUESTION: But you've told is in your statement that the uptake of that has been relatively low. Do you know why that was? ANSWER: I think there was a reasonable uptake in year 1 but after that, it just -- people just haven't been taking it up. I'm not sure why. It's surprising. To me, also, with the life insurance...
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QUESTION: Then the third form of insurance is travel insurance. Again, is that essentially done in the same way, so you're insured in the way you would be if you were in -- ANSWER: Perfect health.
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QUESTION: -- perfect health, and then the increase is effectively underwritten or paid for by the state? ANSWER: Yes.
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QUESTION: And how important has that been for -- ANSWER: Extremely important, I think the vast majority of card holders take that out, especially now we've started travelling again post-Covid, but it's really important. It means that the individual and their family can take out travel insurance. That's been very, ve...
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QUESTION: You told us how this was something raised back in the '80s and it took all of the way through the discussions following the 2002 Act and the Lindsay Inquiry report for this to eventually come to fruition. Was there resistance on the part of Government or was it just ignored or ...? ANSWER: There was a littl...
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QUESTION: Then just a final question from me for now, Brian. Those three types of scheme that we've been looking at, so the provision for compensation through the tribunal, the HAA card and then the insurance scheme, these are all measures that have been taken by the state -- ANSWER: Yes.
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QUESTION: -- in recognition, would this be right to say, of the suffering and disadvantage that individuals have experienced through treatment at the hands of the state. As well as the obvious benefits of the schemes themselves, the provision of financial assistance, access to health services and so on, how important...
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QUESTION: Then does the HAA card cover the joint operations for haemophiliacs? ANSWER: No, that's entirely under the Haemophilia Service.
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QUESTION: The home care that you described, what's the source of funding for that? Is that the Department of Health? ANSWER: The Department of Health.
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QUESTION: I asked you earlier about how the tribunal approaches the assessment of the cost of care, if carers are making a claim, and you indicated you weren't sure of how they approached it? ANSWER: Yes.
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QUESTION: Is there a way we would be able to find that out? ANSWER: Absolutely. I think if you were to contact Raymond Bradley from Malcomson Law, he would have 79dealt with vast majority of cases of carers, so he would have all of the detail.
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QUESTION: Thank you. In terms of the information that's publicly available about the tribunal's approach, does the Government publish data about the awards? ANSWER: The tribunal publishes an annual report and they publish the total number of cases heard and then the -- the -- sort of, the total awards, and you can div...
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QUESTION: You gave some figures that are quoted in the Archer Inquiry Report about both the range and average. Are those still accurate, do you know, or has there been a significant change since then? ANSWER: Can you remind me what figures I quoted for Archer.
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QUESTION: I can. I haven't got the report in front of me, but the final report says that you told the Archer Inquiry the average payment was -- it's about EUR 850,000, from a range of between EUR 14,000 and EUR 3.1 million. ANSWER: That range would certainly be correct. It is impossible to know what the average paym...
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QUESTION: And in terms of the tribunal awards, is it right to understand then that the individual awards are not published? There is no -- ANSWER: That's correct.
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QUESTION: There is no decision from the Tribunal? 81ANSWER: That's correct.
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QUESTION: If they are appealed to the High Court, the High Court judgments would be publicly available? ANSWER: Not that I'm aware of, no.
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QUESTION: Just -- ANSWER: Again, I think right through every step of this process we've taken as much care as possible to ensure confidentiality.
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QUESTION: Yes, understood. Just turning back to the HAA card scheme. The liaison officers, what's the background of the officers? ANSWER: They would generally be health service employees. They would be -- perhaps some of them would have a nursing background but generally they'd be health service employees. But cruci...