Deadline: Wednesday 11 May 2016
NHS England is currently consulting on a method for their Clinical Priorities Advisory Group (CPAG) to use when making decisions on which services or medicines should be prioritised for funding. This method is to be used for recommendations for the 2016/17 round of new investments in specialised services. How this method works will be of great importance to groups with treatments either currently being assessed or that will be assessed before 2017/18. We will of course be responding to the consultation; however we would also encourage anyone likely to be impacted by the decisions to express their opinion.
Specialised services are those which are required by relatively few individuals, require specialised and relatively rare expertise, and tend to be relatively expensive. NHS England is the only national commissioner of specialised services in England. The majority of patients affected by rare conditions will access the medicines they need via NHS England’s specialised commissioning process. The process for deciding which new medicines or interventions are given funding through the NHS is a lengthy and complex one.
In 2015, NHS England agreed on the principles underpinning the process for prioritising services and interventions for funding, relative to others. They are now looking to develop a method to apply these principles. It is vitally important that the method used by NHS England is transparent, rational and consistent, particularly as there is a backlog of treatment and service proposals to be considered. It is highly unlikely that NHS England will be able to fund all the policies put forward by clinical reference groups within their limited budget.
The proposals describe a process by which CPAG will be asked to categorise each policy proposal as high, medium or low patient benefit, taking into consideration the quality of the evidence available, showing clinical effectiveness. The policy proposals will then be placed on a matrix, with the incremental benefit of the treatment or service on the x axis, and on the y axis the incremental cost, determined by the cost per patient over five years. The proposals will then be batched into five priority levels of relative prioritisation, based on the position of each policy proposal on the matrix. Before making its final recommendations CPAG will also consider whether any adjustments should be made to the baseline recommendation based on NHS England’s broader strategic ambitions such as reducing health inequalities.
Due to the relatively high costs of many treatments for rare conditions, NHS England has acknowledged that many of these would be unlikely to receive a baseline relative prioritisation of above level 3. This is particularly the case as the description of patient benefit will not include any non-clinical factors. Although it is not clear yet which prioritisation bands are likely to be fully or partially funded, in order for the process not to systematically disadvantage rare disease patients, the adjustments applied would need to be substantial. We are also concerned about the possibility that CPAG may make the decision not to fund a treatment which fits within the funding envelope, based on the relative level of benefit, even though all proposals which have been put to CPAG will already have passed through a number of filtering and prioritisation stages.
For more on why we consider this consultation important, see our Director’s recent piece in the Guardian.
If you would like to discuss this work please contact our Policy Officer, Louise.