Agenda item - Public Involvement
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To consider the following items raised by members of the public:
(a) Petitions: To receive any petitions presented by members of the public to the full Council or to the meeting itself;
(b) Written Questions: To receive any questions submitted by the due date of 12noon on the (insert date) 2017.
(c) Deputations: To receive any deputations submitted by the due date of 12 noon on the (insert date) 2017.
4.1 There was a Public Question from Ms Linda Miller:
Clinically effective commissioning
When the 39 treatments under review were announced to the HOSC (February 2018) the CCG informed us:
1) that our CCG together with the four other CCGs in Sussex East Surrey have compiled the list,
2) that the changes are not “substantial” so do not trigger HOSC discussion and public consultation, and
3) the aim is to reduce spending.
My question is:
1) We have a National Health Service and the public expect the treatment available to be based on national, evidence-based guidelines. Please could the HOSC ask the CCG to inform us what the NICE guidelines are for each of the 39 treatments under review.
2) Please could you define “substantial”: how exactly is the CCG planning to alter, for example, the treatment people with cataracts might receive? Please could you ask the CCG to inform us, for all 39 procedures, exactly what changes are being proposed.
3) Brighton and Hove CCG intends to cut £14 million from its spending in 2018/19(1). Once we have the NICE guidelines and the details of the changes being proposed, if this committee finds that people in Brighton and Hove are being offered an inferior standard of care based on local, financially motivated decisions, what powers does this HOSC have to challenge those decisions?
(1) Alliance Update, June 2018
4.2 The Chair noted that the response to this series of questions was lengthy. He would therefore not read it out, but the full response had been shared with members and with the questioner and would be included in the minute of the meeting:
NICE publishes all of its guidelines on the NICE website: https://www.nice.org.uk/Searching for a specific treatment or condition will bring up details of all the relevant guidance.
However, There isn’t NICE guidance for all the treatments in tranche 0,1 and 2 and if there is NICE guidance, in most cases it is purely guidance and not mandatory: https://www.nice.org.uk/about/who-we-are/our-charter
NICE and other clinical guidance (e.g. from the medical colleges) has been reviewed during the process of updating the policies.
The Clinically Effective Commissioning Programme has been set up to reduce clinical variation, improve quality of care and ensure application of National evidence based guidance such as NICE across the population of Sussex. A key driver is improving the clinical value that we offer our population, defined as achieving the best outcomes for individual patients and for the public within the available resources. A detailed evidence review is carried out for each treatment area, capturing all NICE and any other National Guidelines and this is then carefully evaluated to ensure a representative Policy is then formulated. This will then need to be implemented across Sussex and East Surrey via contractual routes absolutely facilitated by Clinical engagement with our GPs and Hospital Clinicians to ensure patients receive equitable evidenced based care with greater shared decision making to support them to make informed decisions.
There is no statutory definition of ‘substantial’ in relation to ‘substantial variation in services’ (Public Health, Health & Wellbeing Boards and Health Scrutiny Regulations 2013 section 23). Government guidance recommends that NHS bodies and HOSCs informally agree on which change plans should be considered substantial. The local rule of thumb is that planned changes which are likely to have a serious detrimental impact on any service users or a minor negative impact on many users, should be referred to local HOSCs.
The Health Policy Committee is the forum for recommending to the CCG whether the potential change is substantial or not.
The CCG does not consider that any of the service changes relating to tranche 1 or 2 of the CEC initiative reach this threshold and has consequently not formally consulted the HOSC on any related changes in service.
The Cataract Clinical Policy sits within the Clinically Effective Commissioning pipeline and will be timetabled to be addressed within the next year. The approach to agreeing a Sussex wide Policy will follow a defined process, as will any new Policies. This will entail an evidence review of any National Guidance and subsequent detailed scrutiny following an ethical framework by a working group comprising of Clinicians, Commissioners, Public Health Leads and lay members. The draft Policy will then be publicly shared to ensure transparency in our approach, we are liaising with Healthwatch for their guidance. If the Policy poses substantial variation in Services this will be brought to the HOSC for formal consultation.
The suite policies are available on the CCG website setting out exactly what criteria will be followed in order to ensure clinically effective commissioning.
The HOSC is required to provide additional scrutiny to developments and variations in local health services. This role is an important safeguard for ensuring that services are not removed or scaled back without due consideration to how resources are deployed locally. If the HOSC felt that changes were being made to services and without appropriate consideration to the impact on the community and the use of NHS resources in the round, then the HOSC has the ability to escalate its concerns to the Secretary of state for Health for review and decision.
The £14m reduction in spending is a target across the entirety of commissioned health services in the city. As part of this, clinicians are currently reviewing all health and care services that may have limited or no clinical benefit to patients to identify any areas where money is not being spent as effectively as it should be. Any decisions proposed as a result of this review will be based on whether a service is clinically effective and is a clinical priority, as well as input and feedback we have received from our local population. The clinically effective commissioning programme fits into this and is something we have already been working towards for some time.
4.3 Ms Miller asked a supplementary question: “does the HOSC intend to conduct further scrutiny of the Clinically Effective Commissioning programme, and if so will this be in public?”
4.4 Several members noted that they were committed to this issue being scrutinised in public.
4.5 The Chair agreed to provide a written response to this question.