Written evidence from Baxter Healthcare
Ltd (COM 44)
1. BACKGROUND
1.1 Baxter Healthcare Ltd has been providing
products and services to the NHS for over 50 years and we have
therefore been engaged alongside the NHS during its evolution
over those years. We have a strong track-record of providing healthcare
solutions for long-term conditions; be it providing life saving
and sustaining products, or understanding the patient pathway
that allows a patient to seamlessly travel between hospital and
the home to get the right therapy, at the right time.
1.2 We are one of the few companies that
support the NHS to deliver a range of specialist services/therapies.
As such, we have drug and service experience in home dialysis,
haemophilia, immunoglobulin therapy and provide tailored drug
solutions—be it for parental nutrition or chemotherapy,
for individual patients throughout hospitals in the UK. We are
therefore well placed to view objectively the strengths and weaknesses
of the current and proposed specialised commissioning arrangements
and welcome the opportunity to be able to respond to this Inquiry.
We have grouped our responses around the key headers indicated
by the HSC and our responses refer specifically to specialist
commissioning:
2. CLINICAL ENGAGEMENT
IN COMMISSIONING
2.1 Because of the nature of rare diseases,
clinicians are generally well engaged in defining patient pathways—however
at times, these pathways are then reviewed and commissioned in
a fragmented manner—which affects continuity of care and
leads to a disjointed approach to care pathways.
2.2 Where some specialist therapies have
defined patient pathways, it is important that there is a level
of commissioning consistency across the country. Commissioning
for specialist services, which are often complex, can lead to
variability of access to care across the country. An example would
be parental nutrition, where the 10 regions in England are proceeding
with the implementation of the service revision in different steps
and prioritising different parts of the pathway, which can lead
to a fragmented service. Clinicians with specialist knowledge
need to work together to educate commissioners and implement frameworks
that represent a consistent approach across the regions.
3. ACCOUNTABILITY
FOR COMMISSIONING
3.1 The NHS Commissioning Board, as defined
in the White Paper, will have responsibility for specialist commissioning
at national level. We would endorse this proposal as it safeguards
specialist therapies in both the short and medium term, particularly
during what may become a chaotic period of transition and change
within the NHS over the coming year(s).
3.2 We would caution against any immediate
review of the current definition set. The set was recently reviewed
and again, with so much change planned within the NHS, it is critical
that specialist services are maintained and not subjected to huge
upheaval, particularly when commissioning of some of these services
is already patchy and funding streams often uncertain.
3.3 Consistency of approach in commissioning
is critical. Skill sets and understanding of complex patient pathways
for specialist therapies is currently variable. It will be important
that the National Commissioning Board sets a level of quality
and consistency for applying the pathways around the specialist
definition set. This may mean that some sort of regional implementing
structure is required to ensure this level of consistency.
4. QUALITY
4.1 NHS Commissioning Board should use NHS
levers—such as CQUIN and PROMs to ensure that quality care
is delivered. For some specialist areas, such as haemophilia and
dialysis, stretching national quality standards could be set to
drive up quality—which would reduce regional inequalities
to access to care.
5. FUNDING
5.1 The NHS Commissioning Board will need
to be given appropriate funding to support commissioning of high
quality specialised services and therefore it is essential that
accurate budgets are established for these complex therapies.
6. PROCUREMENT
6.1 Procurement of services is a critical
element of effective commissioning. Procurement processes must
recognise the meaningful differences between the products, technologies
and services that support patient choice. In addition they must
also protect long-term investment in clinical research, innovation
and product development programmes that are required to support
future generations of rare disease patients.
7. PATIENTS
7.1 "Specialist commissioning"
by its nature presents a complicated model to patients who don't
understand how their therapies are commissioned or funded. One
of the central themes in the White Paper is `no decision for me,
without me'—this must be a key factor when commissioning
effective services. Patients should be able to input into decisions
about their care, and should have a point of recourse if they
have not been included in the decision about their care pathway.
8. TECHNOLOGY
ASSESSMENT
8.1 Assessing the "value" of products/technologies
and services that support rare diseases is clearly difficult.
The creation of an ethical framework through AGNSS has been welcomed
as a progressive step forward. AGNSS is a new body that needs
time to test the effectiveness of the framework over a period
of time—we would hope therefore that this body is not restructured
or changed and is allowed to continue in its current form.
October 2010
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