ACCESS TO MEDICINES FOR END-OF-LIFE AND VERY RARE CONDITIONS: TRANSITION FROM IPTR TO PACS

Similar documents
Process for End of Life and Very Rare Conditions (orphan and ultra-orphan medicines)

17 January 2018 Mary Maclean 50 West Nile Street Glasgow G1 2NP

Dear Colleague. DL (2017) June Additional Funding for CGMs and Adult Insulin Pumps Summary

NHS Circular: PCA(M)(2011)4 abcdefghijklmnopqrstu TREATMENT OF ERECTILE DYSFUNCTION: PATIENTS WITH SEVERE DISTRESS. Summary

SMOKING OUTSIDE HOSPITALS: AN OPPORTUNITY TO COMMENT ON PROPOSALS

USE OF UNLICENSED MEDICINES AND OFF-LABEL MEDICINES WHERE A LICENSED MEDICINE IS AVAILABLE

Scottish Medicines Consortium

Access to newly licensed medicines. Scottish Medicines Consortium

abcdefghijklmnopqrstu

DL (2018) 14. Dear Colleague UK INFECTED BLOOD INQUIRY RETENTION OF RECORDS

Your letter posed five questions for the Group. The questions are repeated below (in italics) along with our answers:

abcdefghijklmnopqrstu

A range of issues were explored during these evidence sessions including: The equity of access to fertility treatment across NHS boards.

abcdefghijklmnopqrstu

From the Permanent Secretary and HSC Chief Executive

Professional Development: proposals for assuring the continuing fitness to practise of osteopaths. draft Peer Discussion Review Guidelines

A Guide to the Scottish Medicines Consortium

Dear Colleagues, NATIONAL STANDARD FOR MONITORING THE PHYSICAL HEALTH OF PEOPLE BEING TREATED WITH LITHIUM

HEALTH AND SPORT COMMITTEE AGENDA. 14th Meeting, 2018 (Session 5) Tuesday 1 May 2018

abcdefghijklmnopqrstu

Fleetbank House 1 st Floor, 2-6 Salisbury Square London EC4Y 8AE. Mr Simon Stevens Chief Executive of NHS England By .

1.2. Please refer to our submission dated 27 February for further background information about NDCS.

SUBMISSION FROM GLASGOW CITY COUNCIL

Date 18/02/13 Our Ref I write in response to your request for information in relation to NHS Lothian s Formulary

Primary Substance Misuse Resources Quality Assurance Tool The Resource in a School Context and/or Community Setting

State of Support for the Healthwatch network

URGENT UPDATED ADVICE ON DOSAGE OF OSELTAMIVIR IN CHILDREN UNDER ONE YEAR OF AGE WITH SWINE FLU

CALL FOR WRITTEN EVIDENCE ON THE FINANCIAL MEMORANDUMS TO THE PALLIATIVE CARE (SCOTLAND) BILL

Dear Colleague SUPPLEMENTARY INFORMATION ON CANNABIS BASED PRODUCTS FOR MEDICINAL USE

Access to clinical trial information and the stockpiling of Tamiflu. Department of Health

Dementia Action Alliance survey for carers and professionals

Dear Colleague GENERAL OPHTHALMIC SERVICES OPTOMETRY INDEPENDENT PRESCRIBING. Summary

NHS: PCA(D)(2015)7. Dear Colleague STRATEGIC VISION FOR E-DENTISTRY. Summary

Dear Ms Smith, Linda Smith Assistant Clerk to the Public Health Petitions Committee TG.01 EDINBURGH EH99 1SP

A framework for all staff working with people with Autism Spectrum Disorders, their families and carers

Consultation on the role of the Scottish Health Council: Strengthening people s voices in health and social care

We need to talk about Palliative Care COSLA

DE-DESIGNATION OF YELLOW FEVER VACCINATION CENTRES

NHS:PCA(D)(2014)6. Dear Colleague ROLL OUT OF DEFIBRILLATORS TO INDEPENDENT DENTAL PRACTICES PROVIDING NHS GENERAL DENTAL SERVICES (GDS) Summary

abcdefghijklmnopqrstu

The extended timeframe associated with being listed on the CCSL;

SCAN Skin Group Friday 1 st November 2013

HFMA briefing July Medicines costs in Scotland

Consultation on the role of the Scottish Health Council

Prevention of stroke and systemic embolism in adult patients with non-valvular atrial fibrillation

Patient and Public Reference Group for Medicines ADTC Sub-group NHS Tayside 17 th February 2015

PRIMARY CARE MEDICAL DIRECTOR v PFIZER

pí=^åçêéïûë=eçìëé= = iéïáë=j~åççå~äç=jpm= ACTION PLAN FOR IMPROVING ORAL HEALTH AND MODERNISING NHS DENTAL SERVICES

MINUTE OF MEETING HELD ON 3 NOVEMBER 2008, ST ANDREW S HOUSE, EDINBURGH

PUBLIC PETITIONS COMMITTEE AGENDA. 2nd Meeting, 2019 (Session 5) Thursday 24 January 2019

PRESENT. Ms N C F McElvanney (Chair) IN ATTENDANCE

abcdefghijkm abcde abc a Health Department Workforce Directorate NHS Circular: PCS(DD)2006/5 Dear Colleague

Key to Survival - Unlocking access to new treatments

Driving Improvement in Healthcare Our Strategy

abcdefghijklmnopqrstu

Healthcare Improvement Scotland s Improvement Hub. SPSP Mental Health. End of phase report November 2016

Good enough? Breast cancer in the UK

An evidence rating scale for New Zealand

FINANCE COMMITTEE DEMOGRAPHIC CHANGE AND AGEING POPULATION INQUIRY SUBMISSION FROM NATIONAL OSTEOPOROSIS SOCIETY

SCAN Colorectal Group

Title Corporate Parenting Plan

1. Introduction. 2. Role of PSI as Pharmacy Regulator

Working with you to make Highland the healthy place to be

MS Trust Comments on the ACD

Enhanced Service for people with dementia in Primary Care

Medicines in Scotland: What s the right treatment for me? Information for patients and the public

Activity Report April 2012 March 2013

NHS: 2002 PCA(O)6 abcdefghijklm

Activity Report March 2013 February 2014

Ixekizumab for treating moderate to severe plaque psoriasis [ID904]

NHS: 2004 PCA(D)9 abcdefghijklm

JOB DESCRIPTION. Sessional Youth Worker (Lothian) April 2018

CANCER IN SCOTLAND: ACTION FOR CHANGE The structure, functions and working relationships of Regional Cancer Advisory Groups

FREEDOM OF INFORMATION CHRONIC FATIGUE CLINIC

Yellow Card Centre Scotland Centre for Adverse Reactions to Drugs (Scotland)

Scottish Autism - Oban Autism Resources Day Care of Children Lorne Resource Centre Soroba Road Oban PA34 4HY

NHS: 2003 PCA(D)12 abcdefghijklm

Powys teaching Health Board. Local Healthcare Professionals Forum. Terms of Reference - DRAFT

Abiraterone: Reaching men who need it the most

NORTH OF SCOTLAND PLANNING GROUP

A Step in the Right Direction. What People Living with Arthritis in Scotland want from their Politicians

A guide for MSPs/MPs and Parliamentary Staff

NHS: 2002 PCA(D)6 abcdefghijklm

ALCOHOL ETC. (SCOTLAND) ACT 2010 GUIDANCE FOR LICENSING BOARDS

JOB DESCRIPTION. Sessional Youth Worker (Dundee) September 2016

David Karikas, Mike Melvin, Alan Bingham, Alexa Anderson, Eileen, Stephanie Guerin, Mike Melvin,

Neurological Alliance of Scotland. Executive Meeting Tuesday 9 th September 2014 MND Offices, Firhill, Glasgow at am

Dear Colleagues, EXTENSION OF PAUSE TO THE USE OF VAGINAL MESH

Waverley Gate 2-4 Waterloo Place Edinburgh. Date 16/12/11 Your Ref Our Ref. Enquiries to Richard Mutch

SCOTTISH PARLIAMENTARY EVENT 12 TH NOVEMBER 2014

Scottish Police Authority Board. Meeting. Date 27 September 2018 Stirling Court Hotel, Stirling

abcdefghijklmnopqrstu

2.2 The primary roles and responsibilities of the Committee are to:

abcde abc a Dear Colleague GENERAL DENTAL SERVICES

Scottish Parliament Region: North East Scotland. Case : Tayside NHS Board. Summary of Investigation

Ms Margaret Mitchell MSP Convener, Justice Committee Room T2.60 The Scottish Parliament Edinburgh EH99 1SP 19 August 2016

IAYMH International Youth Mental Health Conference, Expression of Interest in hosting 2019 event

Re: Handling of gabapentin and pregabalin as Schedule 3 Controlled Drugs in health and justice commissioned services

National Group for Volunteering in NHS Scotland

NHS: 2002 PCA(D)2 abcdefghijklm

Transcription:

Dear Health and Sport Committee T3.60 The Scottish Parliament Edinburgh EH99 1SP Tel: 0131 348 5224 Calls via RNID Typetalk: 18001 0131 348 5224 Email: HealthandSport@scottish.parliament.uk 5 March 2014 ACCESS TO MEDICINES FOR END-OF-LIFE AND VERY RARE CONDITIONS: TRANSITION FROM IPTR TO PACS As you will be aware, on 5 November 2013, the Scottish Government Chief Medical Officer and Chief Pharmaceutical Officer wrote to all NHS boards. A copy of the letter is attached at Annexe A. The letter indicates that the Scottish Government does not consider it acceptable for any patient whose clinicians may currently be considering, or in the process of an IPTR, to be disadvantaged because of the timing of events. It goes on to emphasise that the concept of exceptionality should no longer be a factor in any IPTR under consideration but that decisions should be primarily about the individual clinical case. It adds that IPTR panels should exercise flexibility in their decision making in recognition of the issues highlighted in the Health and Sport Committee Report, and of the fact that we are entering a period of transition to a new clinically led peer review process. It concludes that patients should not be adversely impacted by this transition. The Committee agreed to hold a session on 25 February 2014 involving patient organisations, clinicians, the pharmaceutical industry and the SMC, in order to gauge wider reaction to the SMC proposals. A submission was received by the Committee for this session from the Beatson Oncology Centre Consultant Committee. A copy of the submission is attached at Annexe B. The Committee was concerned at the contents of the submission from the Beatson Consultants, which appeared to suggest that, at least in NHS Greater Glasgow and Clyde, little had changed, despite the CMO s letter, and patients were effectively still being denied access to certain SMC not recommended medicines on the basis of it not being possible to demonstrate exceptionality. The Committee agreed that this required urgent clarification, particularly in the light of the CMO s letter and the repeated assurances to the Parliament and to the Committee by the Cabinet Secretary that no patient who might not be able to access medicines under the current IPTR system but who would be likely to be able to access them under the proposed new arrangements should be denied access during the interim period.

At its meeting on 4 March 2014, the Committee agreed to write to the four NHS boards whose cancer patients are treated at the West of Scotland Cancer Centre asking them to provide a copy of their current IPTR policy and any associated guidance in respect of this interim period. The Committee also agreed to ask boards to indicate what specific changes had taken place in the light of the CMO letter. The Committee has also written to the Cabinet Secretary about this issue. I would be grateful if you could reply by Friday 28 March. Yours sincerely Duncan McNeil MSP Convener Health and Sport Committee

Annexe A: Letter from the Scottish Government Chief Medical Officer and Chief Pharmaceutical Officer of 5 November 2013 to NHS boards ACCESS TO NEW MEDICINES TRANSITIONAL ARRANGEMENTS FOR PROCESSING INDIVIDUAL PATIENT TREATMENT REQUESTS You will be aware that the Cabinet Secretary for Health and Wellbeing responded positively to the Health and Sport Committee s Report on Access to New Medicines. A debate held in the Scottish Parliament last month showed a great deal of consensus and support from MSPs across the Chamber to the recommendations from the Committee and the Scottish Government s positive response to them. There is a lot of work that will need to be done in the coming months to put in place these changes and we do not underestimate the impact that this will have on Boards as changes are put in place. There is one specific aspect of the proposed package of changes that we particularly want to flag up now. The Cabinet Secretary announced that the current IPTR system will be replaced with a new Peer Approved Clinical System (PACS). This will be administered locally (i.e. within NHS territorial Boards) but within a national framework, and will be audited by Healthcare Improvement Scotland. The new system will focus on patient outcomes. We are very mindful that as these changes are put in place (and the Cabinet Secretary has asked that they are implemented urgently) there are patients across Scotland whose clinicians may currently be considering, or in the process of, an IPTR. The Scottish Government does not think that it is acceptable for these patients to be disadvantaged because of the timing of events. We are therefore writing to you to ask you to consider 2 things. Firstly, the Cabinet Secretary has asked us to re-emphasise that the concept of exceptionality should not be a factor in any IPTR under consideration in your Board but should be primarily about the individual clinical case. In addition, IPTR panels should exercise flexibility in their decision making in recognition of the issues highlighted in the Health and Sport Committee Report, and of the fact that we are entering a period of transition to a new clinically led peer review process. Patients should not be adversely impacted by this transition. Secondly, we will be seeking input from you and others in putting in place the PACS. To help implement this new system, and to be able to assess the impact and effect of the changes made, we will need information on the types of applications you are currently dealing with. Therefore we are asking that you take the steps necessary within your Board to be able to share information on IPTR applications made in this transitional phase with the Scottish Government. We will keep in contact with you as the process develops.

Annexe B: Letter from the Beatson West of Scotland Cancer Centre Consultant Committee to the Scottish Parliament Health and Sport Committee We are writing regarding the forthcoming Health & Sport Committee meeting at which access to newly licensed medicines will be discussed again. We would appreciate the opportunity to comment on current aspects of access to medicines in our Cancer Centre, the largest in Scotland, serving more than 50% of the Scottish population. As Glasgow-based cancer clinicians trying to provide the most effective and most appropriate treatments for our patients, the issue of access to drugs through the IPTR process remains highly problematic. We continue to experience repeated rejection of well-articulated IPTR applications. Following the Chief Medical Officer s letter of November 2013, we had hoped that there would be a noticeable change in the application processas well as a significant improvement in access to these important medicines. Unfortunately, this has not been evident. Despite the wording of the CMO letter, which emphasised that the concept of exceptionality should not be a factor in any IPTR under consideration and the recommendation that decisions should be primarily about the individual clinical case, our applications are still being repeatedly rejected. The following rejection letter is not atypical: The panel agreed that this application could not be accepted as one or more of the access criteria were not met i.e. there was no evidence presented that this patient would have a significantly different response to the general population of patients covered by the medicine s licence or the population of patients included in the clinical trials for the medicine s licensed indication We find it difficult to see how this statement suggests any change from the previous requirement that we demonstrate that (a) patients are in some way different to those in the medical literature reviewed by SMC or NICE and (b) that this difference means they are more likely to derive benefit from the treatment. These responses to our applications seem simply to be evidence of a continuing requirement to demonstrate exceptionality. Indeed, our Clinical Directorstated in a Consultants meeting of 2nd December 2013 that, as far as he could tell, the CMO letter would have no bearing on the implementation of the IPTR process and that it was business as usual. We have since had more detailed electronic correspondence from our Director and Head of pharmacy outlining what they suggest are changes to the approach in line with the CMO letter. However, these changes appear to suggest little difference other than the presence of superficial statements suggesting a more flexible intent in the review of applications. The document states core IPTR policies remain intact and the process for decision making remains unchanged; the onus remains on the specialist to demonstrate alignment of the case with existing IPTR approval criteria. Although the document outlines mechanisms by which flexibility in the process will be enhanced, many of these recommendations should already be in place locally, albeit a part of the process that has largely not been followed. We have seen no evidence of any difference in approach to date. Importantly, the documentation we complete remains unchanged and continues to require us to

provide supportive evidence of specific differences between the patient for whom we are making the application and those in the literature appraised by SMC / NICE. None of us is aware of patients who have had these medicines approved for use in circumstances where they would previously have been rejected. Our greater concern, however, is that colleagues in Oncology departments elsewhere in Scotland report that their access to these medicines has improved since November 2013. The existence of postcode prescribing within Scotland adds to the injustice experienced by our patients.