Memorandum by Pfizer Limited (HI 92)
THE CONTRIBUTION OF THE NHS TO REDUCING HEALTH
INEQUALITIES
EXECUTIVE SUMMARY
Pfizer welcomes this opportunity to submit evidence
to the Health Select Committee's inquiry into the contribution
of the NHS to reducing Health Inequalities.
Pfizer believes that clinicians should have
the right to prescribe whichever treatment they feel will be most
efficacious and beneficial to each individual patient and that
the NHS should provide the support, finance and infrastructure
to enable this.
This is in line with National Institute for
Health and Clinical Excellence (NICE) and Department of Health
(DH) national guidance, but at local level, this guidance is not
always followed, for a variety of reasons, leading to health inequalities
in the provision of medicines to patients.
As a consequence of our experience in dealing
with health inequalities in treatment both in the UK and elsewhere
in the world, Pfizer believes that the NHS can achieve a reduction
in health inequalities by addressing two key issues:
1. that of differential access to medicines
and services across the UK, which can be rectified through reform
of the current Health Technology Assessment (HTA) process and
local level NHS reform to eliminate inequalities including "postcode
prescribing".
2. the issue of unequal access to lifestyle
and healthcare information. In addressing this issue, the NHS
should take into account the huge and largely untapped potential
that closer partnership with the pharmaceutical industry holds
for the provision of information to patients.
Pfizer is already working successfully with
the NHS to eliminate health inequalities at individual Primary
Care Trust (PCT) level and will welcome the opportunity to work
much more closely with the NHS to achieve the same results on
a UK-wide basis.
1. SITUATION
1.1 Pfizer's core contribution to reducing
health inequalities in the UK is through the medicines we produce.
Many of these medicines treat diseases that are caused by health
inequalities, yet in certain geographies and circumstances, patients
are denied access to them, leading to further health inequalities.
1.2 Cancer medicines alone now comprise
around 30% of Pfizer's product portfolio, alongside products for
use in therapy areas including respiratory and cardiovascular
disease.
1.3 However, our engagement alongside healthcare
providers in the UK and in healthcare services across the world
has given us insight into world-class patient relationships that
facilitate treatment in primary and secondary care.
1.4 Likewise, the evolution and diversification
of our company and industry into the fields of disease management
and the psychological needs of patients, as well as investigation
of socio-economic mapping and diagnostic tools, is reflective
of the manner in which we believe the NHS should address health
inequalities in the future and demonstrates the potential for
partnership with pharmaceutical companies.
1.5 In our view, there are two key points
around health inequalities that the NHS in the UK should and can
address:
1.5.1. Health inequalities, as they relate
to the NHS, are frequently created and exacerbated by differential
access to medicines and services.
1.5.2. Asymmetrical access to healthcare
information has the same negative impact, often due to differing
demands on NHS resources at local level. Addressing this issue
through a partnership approach with industry has enormous potential
and the NHS needs to consider how this can be achieved without
diminishing its independence and public service ethos.
2. ACCESS TO
MEDICINES AND
SERVICES
2.1. Despite government efforts to eliminate
"postcode prescribing", it still exists for a number
of different reasons, denying patients in specific geographical
locations access to medicines.
2.2 One example of this is devolution, which
has led to different appraisal bodies deciding which medicines
to make available in each country, based on very different HTA
criteria. This lack of standardisation across the UK has even
led to people moving across borders in order to obtain treatment
for conditions that they cannot receive in their home country.
2.3 There is therefore a clear need for
reform to address this issue so that the Scottish Medicines Consortium
(SMC) and NICE in England, Wales and Northern Ireland standardise
guidance and HTA methodologies.
2.4 However, HTAs themselves are at the
heart of the postcode prescribing problem, a fact that has been
recognised in some of the recommendations of the House of Commons
Health Committee (HSC) investigation into NICE, published on 09th
January 2008.
2.5 The HSC call for the creation of an
independent commission to review thresholds for Quality Adjusted
Life Years (QALYs) is a potentially positive step. However, we
believe that any reduction in the QALY threshold, whether in the
context of a brief initial assessment (as recommended in the HSC
report) or a full assessment, can only exacerbate the existing
health inequalities situation by denying yet more patients access
to the clinically proven medicines that they need.
2.6 Furthermore, we believe that such an
independent commission should go beyond the recommended composition
of NICE, DH and PCTs to include industry, academia and patients.
In addition, this group should have a wider remit, to review and
negotiate the joint development of models and approaches. This
should include work to:
2.6.1. broaden the approach taken to calculating
the value of medicines, including the HSCs recommendation to include
factors such as the impact on patients and caregivers
2.6.2. understand how a flexible approach
to, and broader thresholds for, Quality Adjusted Life Years (QALY)
might be introduced for certain priority disease areas and accept
the limitations of using QALYs to measure the value of medicines
2.6.3. ensure that the appeals process is
fully transparent and independently overseen
2.6.4. ensure that assessment methodologies
and assumptions etc. are standardised
2.6.5. further research is required to develop
more robust, inclusive and transparent methodologies for valuing
medicines. These need to acknowledge the variations in patient
response to medicines and the limitations of applying population
level models to individuals.
2.7 The HSC findings also noted the differences
in thresholds and preparedness to use newer technologies between
PCTs. This is a familiar picture in England and stems from budgetary
issues, with two key areas for concern being readily identifiable:
2.7.1. Some PCTs arbitrarily decide to deny
patients certain medications because of their own budget priorities,
going against NICE and DH guidelines and thus creating geographical
inequalities. As a direct example of this, Pfizer has a smoking
cessation product that was approved by NICE more than six months
ago and which is still being either refused to patients or only
made available as a second or third line treatment in some twenty
PCTs across the country.
2.7.2. Clear health inequality is generated
by differential approaches to exceptional case review at PCT level.
The most often cited examples concern oncology treatments, when
Cancer Networks receive different levels of support and funding
from PCTs regarding a particular medicine. As has been recognised
by the HSC, this can be dependent on the evaluation criteria and
thresholds used by individual PCTs to fit with their own budget
availability and which differ from the process and thresholds
used by NICE. This leads to situations where some patients can
receive one form of treatment as standard when others who live
in close proximity will be denied access to clinically effective
medicines and have to apply for them on a case-by-case basis,
with no guarantee of approval.
2.8 We believe there must therefore be clear
and common standards in every PCT for exceptional case review
to avoid postcode driven differences and a willingness on the
part of the PCT to conduct this conversation in public. There
must also be a common standard across PCTs to reach a decision
within a maximum of 2 weeks, since many of the patients caught
in this "NICE blight" have terminal illness or time
sensitive disease (eg Age-related Macular Degeneration).
2.9 As noted above, lack of available budget
is the decisive factor at PCT level. This is despite the fact
that while QALY thresholds have been static since 1999, in the
intervening period, the NHS annual budget has more than doubled,
from £40 billion to £90 billion, meaning that funds
for medicines ought to be available.
2.10 The issue is therefore one of forward
planning, to proactively allocate budgets in readiness for future
need, thus eliminating "postcode prescribing" and the
resultant health inequalities. We therefore welcome the HSC recommendation
that a change of language should take place where NICE HTAs requiring
mandatory funding should be renamed "NICE Directives"
in order to avoid confusion and ambiguity.
This state of preparedness can be achieved through
closer engagement between the NHS and the pharmaceutical industry
in "horizon planning" and medium-term resource allocation
to allow adequate provision for new licensed medicines awaiting
HTA and for those with a positive HTA decision in-year. This could
be achieved through introducing a central fund held at Strategic
Health Authority (SHA) level, to be allocated specifically for
the purpose of providing these new treatments on a planned rollout
as new medicines became available.
2.11 The HSC also recommended that there
should be better assessment of the level of uptake of NICE HTA
recommendations and we believe PCTs could be measured against
one another by the Care Quality Commission or Monitor on uptake
and diffusion as well as against comparator countries via an "innovation
index".
2.12 An additional policy device that we
believe should be used to encourage compliance within the NHS
and thus eliminate inequalities in access to medicines is the
introduction of uptake incentives at a local level for medicines
(or other technologies) that have had a positive appraisal. This
incentivisation could be achieved through the Quality and Outcomes
Framework (QOF) for GPs and through the introduction of a similar
system for medicines (such as chemotherapy) that are only prescribed
by hospital consultants.
3. ACCESS TO
INFORMATION AND
WORKING IN
PARTNERSHIP WITH
THE PHARMACEUTICAL
INDUSTRY
3.1 A key to addressing health inequalities
must be the education and empowerment of people, combined with
the delivery and availability of the necessary resourcesboth
educational and medicalwhich are the essential prerequisite
to receiving appropriate care.
3.2 The NHS has a vital role to play in
an upweighted and ongoing education programme aimed at groups
that have traditionally been hard-to-reach, often as a result
of factors arising from deprivation.
3.3 In conveying accurate information to
patients, we feel that there is a valuable, untapped resource
readily available within the pharmaceutical industry and Pfizer
will welcome greater engagement with the NHS at all levels, from
PCTs upwards, in order to help achieve this.
3.4 With both a commercial interest in producing
prescription medicines for use by those patients who most need
them and a genuine commitment to improving patient health, Pfizer
takes the issue of health inequalities very seriously and has
a proven pedigree in working in this field.
3.5 The Pfizer UK Foundation was established
by Pfizer in 2005 to address health inequalities across the UK
arising from social, economic, cultural and demographic factors.
It supports community based projects that tackle health inequalities
and which fall outside core NHS statutory funding. The aim is
to support projects providing tailored, innovative, modest and
local solutions to needs defined by local healthcare experts,
social care experts, community groups and charities and can also
involve working with innovative thinkers in primary and secondary
care. To date the Foundation has donated £2,894,079 (£1
million a year) to 121 projects across the UK, with an estimated
259,137 beneficiaries.
3.6 Our experience of direct engagement
at PCT level through other areas of our business, as demonstrated
by the two examples below, reveals the potential for effective
partnership between industry and the NHS in addressing health
inequalities across the UK in the future. Ten Pfizer Local Market
Managers (LMMs) are based locally around NHS Strategic Health
Authorities boundaries with a specific role to identify health
inequalities. They carry out regional strategic assessment which
include analysis of population demography's and assessment of
health needs across this population. Wherever possible, Pfizer
LMMs work in collaboration or partnership with PCTs and Health
Care Professionals locally to address these inequalities by providing
additional expertise and assistance to reach patients. It must
be stressed that the Pfizer LMM input does not in any way promote
productsinstead, the focus is on supporting disease awareness
activities and marketing support.
3.7 In April 2006, Birmingham East and North
PCT, UK Pfizer Health Solutions and NHS Direct launched a joint
partnership initiative, Birmingham OwnHealthð®ñ,
an innovative nurse-led care management service delivered over
the telephone to support up to 2000 patients with long-term conditions
in Birmingham. The focus is on changing patient behaviour in the
disease areas of diabetes, coronary heart disease and heart failure,
all of which are frequently associated with health inequalities,
while encouraging greater self care.
The early indications from the Birmingham OwnHealthð®ñ
service suggest some significant trends concerning community medical
resource access by Birmingham OwnHealthð®ñ
project participants over the past year, most notably:
A 48% reduction in hospital admissions
A 53% reduction in A&E visits
A 32% reduction in GP visits[329]
Other initiatives to improve healthcare in the
region may have had an influence on these results, so we are already
actively undertaking comparative analysis, cost effectiveness
and root cause analysis to see whether these improvements can
be translated into more effective use of healthcare resources.
We hope to be able to publish the results of this analysis in
mid 2008.
3.8 Another example of successful collaboration
at PCT level is the Town & Bridge Project in Ipswich, where
the council and PCT has set up a group called the One Ipswich
initiative. The Town and Bridge wards have a higher death rate
than the rest of Suffolk (up to 75% higher) and the One Ipswich
group was established to reach out to these two wards. A major
part of this initiative has been around smoking cessation, where
the PCT and local Stop Smoking Service identified the need for
additional resource to engage hard-to-reach smokers. Working in
partnership with them, Pfizer investigated reasons for lack of
uptake of smoking cessation services in these two wards and identified
logistical and transport difficulties as obstacles to accessing
the stop-smoking-services. As a result, of this partnership, the
SSS, PCT and the Town and Bridge project manager established three
new clinics in the community in October 2007, using experts such
as nutritionalists and exercise specialists to assist patients
and create a fully informed and incentivised "willing quitter".
Pfizer added marketing expertise to support this initiative, which
included utilising interior and exterior bus advertising on those
routes passing through the Town and Bridge Wards that serviced
the new clinics and placing posters and materials at Ipswich Town
football club matches. Results are currently being evaluated,
but the principle of ensuring that patients can access the services
they need is one that must be applied across the board to target
hard-to-reach population groups.
RECOMMENDATIONS
Reform and standardisation of Health
Technology Assessments by NICE and the SMC, including greater
transparency, flexibility and the establishment of an independent
commission to review and negotiate the joint development of models
and approaches.
"Horizon planning" in partnership
with industry and the establishment of a fund held at SHA level
to be used for new licensed medicines awaiting HTA and for those
with a positive HTA decision in-year.
The establishment of clear and common
standards in every PCT for exceptional case review and to ensure
decisions are made within a two week period.
The introduction of uptake incentives
at a local level for medicines (or other technologies) that have
had a positive appraisal, through QOF for GPs and a similar system
for other groups such as consultants.
Partnership between the NHS and the
pharmaceutical industry at national rather than local level to
achieve the best possible outcomes for patients, combining industry
resources and expertise with the experience and professionalism
of the NHS at educational and programme implementation levels.
January 2008
329 All three statistics from Birmingham OwnHealthð®ñ
report "Successes and learning from the first year"
report September 2007, Page 26. Birmingham East and North PCT,
NHS Direct and Pfizer Health Solutions. Back
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