Written evidence from the British In Vitro
Diagnostics Association (COM 81)
ACCOUNTABILITY FOR
COMMISSIONING DECISIONS
1. The NHS Commissioning Board will be held
to account by delivery against the NHS Outcomes Framework. The
NHS Outcomes Framework should be developed to reflect outcomes
focused on what matters to patients and healthcare professionals.
This will mean an increased focus on accurate reporting of clinical
outcomes, in which in vitro diagnostics have a significant
role to play.
2. Commissioners should be offered guidance
on areas where they may have less expertise in order to help them
to improve outcomes. They can then be held accountable for commissioning
according to such guidance. For example, the 2008 Carter review
of pathology services recommends that all commissioners should
be offered guidance on commissioning pathology services.
3. Commissioners will need to be accountable
for the outcomes that are achieved in their health economy. A
commissioning outcomes framework should include outcome measures
at all stages of the care pathway, including at diagnosis. For
example, commissioners should be held accountable for the stage
at which patients under their purview are being diagnosed as a
marker of the success of screening programmes.
4. The development of quality standards
should also help to support efficient and effective local commissioning.
As much as is possible, quality standards should be developed
to cover all areas of the service that GPs may commission. Quality
standards should include a focus on diagnosis to reflect the vital
role that this plays in the pathway and in patient outcomes.
5. BIVDA believes that some part of GP practice
income should be linked to the outcomes that the practice achieves
as part of its wider commissioning consortium. The Quality and
Outcomes Framework has shown that financial incentives can be
effective. Linking these financial incentives to outcomes should
drive up outcomes in the area. Linking a GP practice income to
that of their wider commissioning consortium will ensure that
GPs take an active interest in the outcomes being achieved by
their partnering GP practices.
INTEGRATION OF
HEALTH AND
SOCIAL CARE
6. Many health outcomes will depend on joint
working between GP practices, GP consortia and local authorities.
The link between GPs and local authorities will be particularly
strong in relation to awareness and early diagnosis, and the services
provided by these two groups will need to be integrated. It will
be important to ensure that data are collected in a way that can
be understood and used by both services, and that shared outcome
indicators are developed in this area.
7. Outcome measures shared across GP consortia
and local authorities will encourage a joint approach to public
health issues.
SPECIALIST SERVICES
8. GPs are unlikely to have the required
expertise or purchasing power to commission all specialist services.
It is not only low volume services where NHS Commissioning Board
and GP consortia will have to work together. Some high volume,
specialist services will need to be coordinated.
9. Pathology services provide an example
of a high volume service, some of which may be better commissioned
at an NHS Commissioning Board level. The 2008 Independent Review
of NHS Pathology Services by Lord Carter of Coles recommended
that pathology services be consolidated into reconfigured commissioning
networks.
10. There is a role for both national and
GP commissioning of diagnostic tests. Simple and routine tests
can be commissioned at a GP consortium level, keeping the commissioning
decisions as close to the patients as possible. However, national
commissioning may be necessary for more complicated tests such
as molecular diagnostics for use with personalised medicines.
11. It may also be necessary to commission
some national screening initiatives at an NHS Commissioning Board
level to ensure that there is equitable access across the country.
12. National commissioning will also be
necessary where there is a clear link with the Quality, Innovation,
Prevention and Productivity (QIPP) programme. There is a pathology
work stream in the QIPP programme which will need to continue
to consider the role of pathology networks as suggested by Lord
Carter of Coles in his 2008 review of pathology services.
13. It will also be important for people
responsible for both low and high volume service commissioning
to work together to ensure that the experience of care for the
patient along the pathway is joined up.
COMMISSIONING OF
PRIMARY CARE
SERVICES
14. Some clarity is needed regarding the
commissioning of services from GPs, and to what extent GP consortia
will be able to commission services from their constituent practices.
It is unclear as to whether or not a GP commissioning diagnostics
services from their own practice would be a conflict of interest.
Where a GP can commission services from their own practice, it
will be important to give patients a choice of service where it
is available.
COMMISSIONING FOR
INNOVATION
15. The NHS has traditionally been slow
to invest in and adopt new and innovative technologies, many of
which could go on to significantly improve patient outcomes for
people with cancer and other diseases. BIVDA feels that more can
and should be done to support the NHS in the uptake of new technologies
that have been recognised as bringing benefits to patient experience,
operational effectiveness and cost-saving. One area where new
technologies could have an impact on patient outcomes is through
the use of in vitro diagnostics to enable earlier diagnosis
of cancer patients. Commissioning should be developed to ensure
that these new technologies can be introduced.
16. Routes through which the uptake of assessed
technologies might be encouraged are currently inadequate. While
progress has been made in this area with the development of the
Diagnostics Assessment Programme (DAP) by the National Institute
for Health and Clinical Excellence (NICE), there is still some
way to go to ensure that recommendations that will come from DAP
are taken up by the NHS. NICE should consider what levers could
be introduced to encourage the adoption of new and innovative
tests. One way in which this could be done is through reference
to diagnostics in the newly developed quality standards by which
commissioning consortia could be held accountable.
17. The introduction of pilot centres for
innovative diagnostics that can improve cancer outcomes could
also help to stimulate uptake of those products and release their
benefits into the NHS by allowing evidence to be gathered and
demonstrating how a technology might be adopted.
18. The NHS Technology Adoption Centre (NTAC)
offers a good example of a process for encouraging the adoption
of technologies offering real benefit to patients (for example,
an intra-operative breast lymph node assay) that have previously
seen limited uptake in the UK. The NTAC process is a valuable
template that could easily sit alongside NICE, to help encourage
uptake of recommended technologies.
October 2010
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