NHS England’s prioritisation framework for the commissioning of specialised services sets out the principles to underpin decision-making, the priority order for use of funds, and the process for developing clinical policies for proposed new investments. We have welcomed the intentions outlined in the “general principles” section of the document, we do however, feel that what follows is unclear and sometimes contradictory. This should have been dealt with in NHS England’s response to their consultation, but has not.
Much of what we said in our submission to the consultation focussed on the definition of key terms, most of which have not been addressed. The lack of precision within their proposals leaves much of the framework unclear. We highlighted the need for definition of the terms: “patient group”, “relevant guidance”, “adequate and clinical guidance”, “reasonable cost to the public” and “measurable benefit”. Without proper definition of the terminology within the document we cannot be sure how the prioritisation process will impact upon our community, or whether the decisions will be consistent.
NHS England’s response lacks clarity around several aspects of the process including: how separate pathways at NHS England integrate with each other, at what point in the process the principle of “affordability” will be applied, what form the new clinical review panel will take, how NHS England plans to better support the CRGs and how patient and public voice can be better integrated into the process.
Questions around the fast tracking of interventions where benefits are obvious and the design of an appeals process have also gone unanswered.
The analysis to the consultation responses completed by The University of Essex details the most important points from the 278 responses that NHS England received. The six pages that NHS England produced are inadequate.
Ironically Essex University’s analysis, published at the same time as NHS England’s response to the consultation, pointed to stakeholder feelings that patient and public voice was not given enough weight.
“There was a common view that the voices of the patients and public are not given sufficient weight, for example: The patient voice needs to be taken more seriously - it currently feels that although patients are included in many stages of the process their opinions carry little weight in the final decisions." (Patient member of a Clinical Reference Group)
Nick Meade, Genetic Alliance UK’s Director of Policy, is a member of NHS England’s Patient and Public Voice Assurance Group (PPVAG). The group have been asked to assure the consultation process for NHS England’s new prioritisation framework. The group agrees with our position that the response from NHS England has been inadequate and will not be providing assurance for the consultation until more work is done to comprehensively respond to stakeholders comments.
It has been really disappointing to see that, regardless of all the excellent engagement work that the NHS England team conducted during the consultation process, their final document makes very little of the information that they collected. This framework is extremely important to our community. The failings of the previous process have been heartbreaking for patients and patient organisations and we should be determined not to let prioritisation decisions rest on a flawed process once again.
The next step for NHS England should be to attempt to fully utilise the information provided to them during consultation, and to better incorporate the ideas of the people who are affected by decisions at the end of this process into a new draft, in order to get the approval of the PPVAG. We will keep you up to date with progress in this area.