Specialised commissioning continues to be an issue of significance and uncertainty for both the NHS and industry. What do the latest reports of regional push back on the plans for devolution to Integrated Care Boards (ICBs) mean? Learn more about our upcoming webinar here.
For the past 2 years, Pharma, Medtech, and Diagnostic companies have identified the delegation of specialised commissioning to the new Integrated Care Boards (ICBs) as a key risk to their UK market access strategies. With its importance to income and the high risk of change devolution seems to promise, specialised commissioning is an obvious issue for providers of these products to place at the top of their risk logs.
The devolution plans are also a risk for the NHS. Not least, because around two-thirds of the income of a typical regional tertiary centre hospital’s income currently comes from specialised services. These are high-cost, low-volume services treating the most vulnerable and intensive patients.
Such services have always been managed on an insurance risk basis through regional consortia of commissioners and providers. For the past 10 years or so, we have seen NHS England (NHSE) centrally manage ‘spec comm’. Here, a central tenet has been that the high-cost medicines involved have been paid for as a pass-through cost with no local financial impact to hospitals or their local commissioners.
For 2 years we have seen complex and sporadic communication of NHSE’s plan to delegate spec comm and its funding to ICBs. This is intended to be a graduated process involving nine regionalised Joint Committees, bringing together NHSE and groups of ICBs. The plans are based on specialised services being grouped into three cohorts of services:
- Those that will be delegated
- Those that may be delegated
- Those that will remain centrally-managed by NHSE
This plan has major risks, especially as it has an inherent paradox. All policy announcements commit to consistent application of NICE and CRG advice, but the delegated funding will undergo weighted capitation, and will therefore vary considerably. So how can services be provided on an equitable basis?
There are other risks too. There is little evidence of practical work to ensure that patient pathways, cross-boundary flows, inter-hospital agreements, and other issues have been addressed. Clinical engagement has been marginal at best. How then is the NHS ready to safely move to new ways of working from 1st April 2024 with the most expensive, complex, and clinically-sensitive services?
On 1st November 2023, the South Yorkshire ICB public board meeting threw arrangements into the air in three sentences:
“Discussions are continuing between NHS England and the ICBs in the North East and Yorkshire regarding the delegation of responsibility for commissioning Specialised Services from April 2024. It has now been agreed by all parties that the transfer of responsibility will be deferred until April 2025. This will allow for further due diligence to be undertaken and ensure a safe transfer of this responsibility.”
So far, others have not made such a public statement of delay. The North East and Yorkshire region is generally regarded as more stable and financially secure than others. It also has simpler cross-boundary flows than others (most notably those with patient flows into the London centres).
If this region sees risks that prompt a delay, and can secure NHSE agreement to that, then where does it leave the others? and, how can you have a major Region working to one set of rules and the others at variance?
This leaves Pharma, Medtech, and Diagnostics in a position that requires even greater urgent and accurate scenario-planning surrounding the possible impact upon all aspects of business. That’s before considering actions to mitigate risk and develop opportunities. The absolute basics of market access are unclear – who sets the rules, who decides, who pays?
There has rarely been a time when so much is so unclear regarding an area that is so important to business, the NHS, and to patients.
Our response and upcoming webinar
In our briefings to clients, we have consistently explained, highlighted, and anticipated this policy arena. Webinars and symposia have reinforced those messages.
On 8th December, our final NHS Whispers webinar of 2023 will explore this topic in more detail. Join David Thorne (Principal Associate, Mtech Access) in his interview of Malcolm Qualie (former Medicines Lead for Specialised Services within NHS England) for an exploration of the state of play and what to expect in 2024.
We will release more details of what to expect from this webinar shortly. For those keen to reserve their place to hear Malcolm’s and David’s views on this key topic, early bird registration is now open here.
