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Is the new NHS guidance relevant to pharma?

The new NHS Commissioning Board has published its most important document of the year - one that will have a huge impact on the industry in 2013
Is the new NHS guidance relevant to pharma?

The new NHS planning guidance for Clinical Commissioning Groups (CCGs), Everyone Counts: Planning for Patients 2013/14, which will take over from Primary Care Trusts (PCTs) in England, this April. It is heavy on policy jargon, systems and programmes that might seem impenetrable. So should you really care about it? The answer is an emphatic yes.

The planning guidance, together with the NHS Outcomes Framework, is the document in which the NHS leadership (importantly this now means the NHS Commissioning Board – not the Department of Health) tells the rank and file CCGs in detail what it expects of them in the year ahead. In turn it will shape the demands CCGs will make of providers, the NHS Trusts and primary and community teams delivering healthcare. In effect it sets out the priorities for the NHS. If you want to speak to the NHS, it is more likely to engage if you speak to it about its priorities, and better still if you offer a way to help it meet them.

As well as brandishing the priorities as sticks, the planning guidance also offers carrots

Alignment with brands
Does this mean you can't talk about yourself, your issues and your brands? Not at all. But you must see your issues and products through the prism of the priorities the NHS is working to. For example, forget about your medicine's P value in clinical trials. Much more interesting to the NHS is whether it helps people go home from hospital sooner and makes them less likely to come back. Can you help to reduce mortality within 30 days from stroke, deaths from CVD in the under-75s and improve cancer survival at one and five years? 

A broader viewpoint of a brand's value proposition can be matched against the many performance indicators of the NHS Outcomes Framework under its five domains: 

  • preventing people from dying prematurely 
  • enhancing quality of life for people with long-term conditions 
  • helping people recover from episodes of ill health and injury
  • ensuring people have a positive experience of care 
  • treating and caring for people in a safe environment and protecting them from avoidable harm.

New incentives
As well as brandishing the priorities as sticks, the planning guidance also offers carrots. It covers some of the incentive schemes that can lead CCGs and NHS Trusts to earn more money. For example, can you help the NHS increase diagnosis and care of dementia patients? If you can, you'll be helping Trusts tick off one thing on the list of requirements for them to earn the extra 2.5 per cent of revenue that's available through the Commissioning for Quality and Innovation (CQUIN) scheme. Similarly, if you can help cut mortality then you will assist a CCG to earn its Quality Premium bonus payment.

Going local
The Planning Guidance has replaced the old annual NHS Operating Framework which set out the marching orders for the service. It is different in that it relaxes some previously rigorous top-down control and moves the service towards local decision making and patient rights. CCGs can now set three of their own local priorities (alongside four fixed national priorities), which contribute to the Quality Premium, for example.

Local CCGs will also have much greater control over designing their Quality, Innovation, Productivity and Prevention (QIPP) programmes to deliver the NHS savings and efficiency challenge. In CQUIN, there are four national targets, but the rest are agreed locally to drive quality and efficiency care between CCGs and providers.

If you engage with medics and other healthcare professionals (HCPs), why not ask if achieving high quality care in their therapy areas is being incentivised locally?

Implementing NICE guidance
On medicines, the guidance reinforces the 'comply or explain' approach to drive compliance with National Institute of Clinical Excellence (NICE) guidance. Specifically, providers must automatically include medicines with positive NICE technology appraisals (TA) on local formularies 'in a planned way that supports safe and clinically appropriate practice' (beware the NHS's ability to use these words as cover for slow inclusion), as well as:

  • publishing local formularies
  • tracking adoption of NICE TAs through the Innovation Scorecard
  • supporting and overcoming system barriers to the implementation of NICE TAs and other guidelines through the NICE Implementation Collaborative.

Patient rights
The NHS Constitution pledges to make the NHS the best customer service in the world. As well as seeking to make the NHS a seven-days-a-week service, reflecting concern over poorer patient outcomes at weekends, patients get a chance to comment on their experience of care through a new 'Friends and Family' test, which initially takes feedback on whether a patient would recommend their hospital and healthcare team to close friends and relatives. This Friends and Family test is weaved back into the new incentives - the results for individual NHS trusts will count as part of the Quality Premium and CQUIN schemes.

Outcomes data
After localism and patients, the third pillar of the guidance is data. A new website is planned to provide up to date, accurate data from all along the care pathway. Clinical data reporting by GP practices will form part of the standard GP contract, and secondary care outcomes data is on the way too. This will be a gradual process as the NHS locally and nationally grapples with the challenges of clinical data collection: collection, comparability and publication on a whole new scale. Given the industry's work with data there may be scope to share experience.

After localism and patients, the third pillar of the guidance is data

Although not as directive as the old operating framework, you can be sure that this new planning guidance will influence local NHS priorities just as much as before. If industry wishes to deepen its engagement with the NHS, it needs to understand and address Everybody Counts. Those working in the NHS have to.

Article by
Dr Mark Saxon

director in Hanover’s healthcare team delivering media and policy led programmes for brands into the NHS. He can be contacted on

20th March 2013

From: Sales, Healthcare



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