Mr. Niall Cody:

As I outlined in my remarks, this started off as a result of an audit on a medical consultant. In the course of that audit, which was not setting out to uncover a strategy that was being applied across medical consultants, the auditor looked at the set of arrangements and then started to raise questions. In the context of the Dublin region, generally what we do, if we come across an example of a set of arrangements, is to see if there are other examples of it. That is the way we work.

The Dublin region became aware that a number of consultants were incorporating and setting up this type of structure, and from that we established the facts in certain cases. We then had to get legal opinion because there were certain arrangements, even to the extent of whether a medical consultant could incorporate. We sought a whole series of legal advice. We got our legal advice, we got expert accounting advice on the treatment of goodwill and then, in the context of the Dublin region where most of the consultants who have significant private practice are based, the Dublin region started to expand the project.

Mr. Philip Brennan is head of the Dublin region and he wrote to the IMO and the IHCA about our concerns in this area. We then decided that we would expand the project from the Dublin region nationally. The Comptroller and Auditor General's report sets out some of the detail of how we selected cases and the features involved, and we took it from there.

It is a feature of what we do. We do sectoral reviews and then we establish whether there is a risk. If there is a risk, we expand it nationally and it then takes its course.