Written evidence from Genzyme Therapeutics
(COM 50)
Genzyme Therapeutics is one of the world's major
biotechnology companies, committed to researching and producing
treatments for serious and life-threatening diseases, and in particular
meeting the unmet needs of sufferers of the rarer conditions.
Genzyme has a very close interest in specialised commissioning,
and wishes to provide evidence and observations relating to that
important issue.
IN SUMMARY
— Genzyme fully supports a reforming agenda
that empowers many more of the stakeholders in healthcare, and
which puts patients first and at the centre of the healthcare
process.
— The new White Paper proposes GP consortia
commissioning of the majority of healthcare, with the new NHS
Commissioning Board commissioning current regional and national
services.
— Without a strong commitment, the differing
pace and priority of the GP consortia will lead to increased service
inequality—defeating the intention of the reform.
— Genzyme's prime concern is that current
functions that have been proven to be effective and cost-effective
( such as national specialized commissioning) are neither unwarrantedly
discarded or diluted, nor paralysed, by the process.
— There is further concern that national
commissioning of currently "regional" or "clinical
network" services may move them away from the patient (and
from many developed local care networks).
— It may be better to commission and performance
manage at a national level, but continue to deliver locally.
Addressing the "themes" of the Committee's
inquiry, and particularly regarding specialized commissioning,
Genzyme would wish to comment as follows:
1. (a) Clinical Engagement in Commissioning
The Board should retain and develop the expertise
that already exists within the national and regional specialized
commissioning bodies.
The GP consortia should appoint a specialist
commissioner who would:
— educate GP consortia about regional and
national specialized services and the benefits brought to patients
derived from integrated commissioning; and
— involve and facilitate GPs having a "special
interest".
2. (b) Accountability for commissioning
decisions
The Board and the GP consortia must manage both
financial and clinical outcome risk. There should be a commissioning
outcomes framework that addresses health outcomes and quality
of care, and has significant patient input. Decisions should be
evidence-based, and follow NICE and NPC guidance. Decisions should
only be made within the competency of the commissioner.
3. (c) Patients' Voices and Choices
Commissioners should actively seek the involvement
of patient groups. To include the seldom heard (but equally important)
voices, involvement and enfranchisement of all could be via the
"umbrella" patient organizations rather than through
the participation of currently high-profile patient organizations.
4. (d) Role of the NHS Commissioning
Board
The establishment of an independent Board to
provide national leadership on commissioning for quality improvement
is welcomed. The Board can develop effective relationships with
the GP consortia by agreeing clear, shared, objectives; ensuring
timely and full communication; by formulating clear guidelines
and procedures for actions; by creating effective and meaningful
performance management processes. Further, the Board could support
efficient and effective local commissioning by creating effective
information systems; by creating, and requiring compliance with,
where appropriate, national disease registries; by conducting
research into the clinical and societal values and successes of
the new commissioning pathways; by defining and agreeing which
services are to be commissioned by which body.
5. (e) Resource Allocation
The true treatment and ongoing costs of the
services to be commissioned should be established. This should
incorporate costs incurred in both primary and secondary care
sectors. The costing should also consider the issue of non-healthcare
costs that are needed in a patients care package, and growth costs.
The costs for services designated to national commissioning should
be identified. To avoid the perception of "top-slicing"
or "clawback" there should be the simultaneous allocation
of funds from the NHS to both the Board and the GP consortia.
To manage risk, there should be Board oversight of mandatory risk
pooling structures.
6. (f) Specialist Services
Many of these are already defined and are commissioned
nationally, with very good clinical and cost-effectiveness, and
no inequality. Some specialist services are provided regionally
or through clinical networks. These are more vulnerable to local
priorities and so inequalities do exist. It is essential that
services currently commissioned nationally are not threatened
by any influx of quantity of "ex-regional" services.
This could be by reduced attention or even "paralysis"
during the redesignation process.
October 2010
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