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HMRC internal manual

VAT Health

Nurses, midwives and health visitors: Problems arising from the exemption for unregistered nursing personnel

Applying exemption to the supplies made by unregistered nursing personnel to approved institutions but not supplies made to such institutions by those such as psychotherapists etc creates an apparent anomaly. However, we consider that this position is justified as unregistered nursing personnel working in hospitals provide services that a registered nurse used to perform. In contrast, when a psychotherapist provides services to the patient in a hospital, exemption is not applicable as he/she is doing so usually for geographical reasons only. The fact that he/she may have a direct relationship with the patient is not enough to justify exemption under item 4 when exemption under item 1 would not have been applicable.