Memorandum submitted by Merck, Sharp and
Dohme (MSD)
As you know the Public Accounts Committee is
meeting on 11 June to consider the National Audit Office Report
Prescribing Costs in Primary Care. As MSD is a leading
supplier of branded medicines to the NHS, I thought I would write
to draw a number of points about the Report to your attention.
MSD agrees with the NAO that savings can be
made through more efficient prescribing, and we support the NAO
view that value for money is a function of both quality and economy.
However, we believe the NAO's conclusions must be approached with
a number of caveats, principally because the concept of switching
patients from one medicine to another is not straightforward and
it is erroneous to assume that medicines in the same class always
have the same clinical effect.
The NAO Report conclusion that GPs can prescribe
lower cost clinically effective medicines without affecting patient
care is misleading. It states that this could save primary care
trusts (PCTs) more than £200 million a year. The NAO also
state that their report examines how the DH and NHS can seek to
influence prescribing decisions where different drugs have: "the
same clinical effect but different prices". MSD would like
to draw the Committee's attention to the fact that there are important
differences in medicines which treat the same condition.
For instance, replacing angiotensin-II receptor
antagonists with ACE inhibitors as suggested by the NAO is not
replacing like-for-like. Both medicines are for high blood pressure
but have different pharmacological properties. This is also the
case with medicines which are more closely related, where medicines
can have the same pharmacological properties yet still be different
chemical substances. For example in the statin class, an area
currently targeted for efficiency gains, it is vital to understand
that simvastatin and atorvastatin are chemically different and
therefore will affect different people in different ways. It is
inappropriate to assume all patients can be switched with no effect
on clinical outcomes.
The assertion that PCTs could match the prescribing
of low cost drugs achieved by the "best" PCTs without
affecting clinical outcomes is therefore open to question. There
is no proper measure of clinical outcomes vs. prescribing available
in the UK.
An additional yet important point which must
be taken into consideration is that there are costs associated
with switching patients from one medicine to another, which takes
time and effort on behalf of clinicians and may have adverse consequences
for patient compliance.
On the prices and costs of medicines generally,
it should be noted that primary care medicines accounted for 11%
of NHS costs in 2005—the same proportion as ten years ago.
It is also important to note that prices of branded medicines
are 21% lower in real terms than ten years ago.
I should finally like to comment on the NAO's
observations on pharmaceutical industry marketing activity, where
it has quoted from the Health Select Committee's 2005 report on
the Influence of the Pharmaceutical Industry.
The NAO repeats the Committee's unsubstantiated
statement that industry promotion is "relentless" and
aggressive, and there seems to be a tacit acceptance that promotion
is somehow inappropriate. However as the industry pointed out
when the HSC report into the Pharmaceutical Industry was published
in 2005, the evidence did not match their assertion. In fact,
most doctors receive only a handful of representative visits in
a month and the NAO lists 17 other influences on GP prescribing
(page 19). Also, the NAO's research points to the fact that 26%
of doctors do not see representatives in their surgery, and the
vast majority only see representatives between once per week and
once every three months. According to industry research the majority
of GPs say they value the clinical and product information provided.
Nor is there is any mention of the strict standards
of regulation imposed on our marketing activity by the MHRA, in
addition to the industry's own rigorously enforced Code of Practice
which sets limits on the amount of marketing information that
can be sent to GPs and the number of visits that can be made by
representatives
7 June 2007
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