Memorandum by the Chief Executive North
West Lancashire Health Authority (NC 70)
I am writing on behalf of North West Lancashire
Health Authority to submit comments to the enquiry which you are
undertaking into the subject of NICE.
This Health Authority supports the role and
work of NICE in providing clear and authoritative guidance about
the effectiveness of particular forms of treatment. We would most
certainly wish to see that role continue, and indeed to see the
number of evaluations carried out by NICE increased. However,
we do have some concerns.
Firstly we are concerned that the public now
expect NICE guidance to be implemented immediately, and funded
accordingly. This, together with the pressures to implement National
Service Frameworks, mean that local health organisations have
little discretion over the use of resources yet are responsible
for meeting local needs. The media headline writers lead us to
believe that "postcode prescribing" is a bad thing.
Their emotive headlines fail to recognise that sensitive local
discretion is actually a very good thing.
Secondly we are concerned that NICE looks at
the effectiveness without giving a great deal of consideration
to the purpose of the treatment itself. Many positive NICE appraisals
have looked at cancer drugs, which are not curative, and which
in many cases offer only very short-term benefits. We are aware
of many different types of intervention, which can have a great
and sustained affect on the quality of patients lives, that are
forced into a lower priority position as a result of not having
been considered (yet) by NICE. Photodynamic therapy for age related
macular degeneration, surgical techniques for the treatment of
intractable angina, and neuro-surgical interventions for Parkinson's
disease are examples that fall into this category.
Thirdly we are concerned about the timeliness
of NICE guidance. We recognise the fullness of the agenda, but
believe that many pieces of guidance are issued only when the
treatment (often a drug) has been superseded. In practice this
therefore means that many drugs cannot be funded for use in clinical
practice until successor drugs have already been licensed.
In conclusion, while we recognise the value
of individual pieces of NICE guidance, we are concerned that little
account is taken of the overall impact of NICE guidance on a Health