House of Commons - National Health Screening - Science and Technology Committee

National Health Screening - Science and Technology Committee Contents

5 Screening policy and advice

84. During our inquiry we heard that the UK National Screening Committee's (UK NSC) independence from Government was highly valued and gave added legitimacy to its advice. Dr Sian Taylor-Phillips, Warwick Medical School, told us that health screening advice to government "needs to be as independent as it can be"[234] while Dr Margaret McCartney, a GP from Glasgow, stated that the UK NSC being "as independent as possible" could "only be to the population's advantage".[235] For Professor Susan Bewley, King's College, London, the UK NSC's independence was something that had "to be fiercely protected".[236] However, some witnesses questioned if recent changes to the structure of the NHS in England had negatively impinged upon the UK NSC's independence.[237]

The governance of the UK National Screening Committee

85. Building on the work of our predecessor Committees, we have taken a close interest in ensuring that the institutional design of scientific advisory bodies facilitates the production of high-quality, evidence-based advice to government.[238] In particular, we have considered the growth of the network of Scientific Advisory Committees (SACs); an advisory structure highlighted by our predecessor Committee as holding the potential "to strengthen the UK's ability to make policy decisions that are based on the best available evidence" and establish the UK Government as "an international exemplar" in scientific advisory systems.[239]

86. The Government Office for Science (GO-Science) describes the purpose of SACs as helping government departments to:

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The current functions of the UK NSC appear broadly consistent with those of an SAC. According to its most recent policy review and annual report, the UK NSC provides "authoritative evidence-based"[241] and "independent advice" to "ministers and health services across the four UK countries on screening policy for all conditions".[242] Dr Anne Mackie, Director of Programmes, UK NSC, explained that the purpose of her team was to "bring together the best international evidence and expert opinion, following consultation and a synthesis of the peer review literature, to the committee".[243] Public Health England (PHE) noted that this "active review process" was "based on the latest science", [244] with the UK NSC then considering "the review and its recommendations, any stakeholder submissions and the view of UK NSC Director of Programmes"[245] in order to make "a recommendation to the four UK Governments".[246]

87. Despite the similarities between the functions of an SAC and those of the UK NSC, the formal status of the UK NSC appeared ill-defined. Dr Mackie told us that the UK NSC was "a standing ministerial advisory committee in terms of governance"[247] and that it was "not classed as a scientific advisory committee or a public body".[248] The Minister confirmed that, for "historical reasons", the UK NSC was "not at the moment" an SAC but considered it a "reasonable question to ask", noting that part of the current Independent Review of the UK National Screening Committee would be examining this point. [249]

88. SACs fall within the scope of both GO-Science's 2011 Code of Practice for Scientific Advisory Committees ("the Code") and its 2010 Principles of scientific advice to government ("the Principles").[250] The Principles set out the high-level "rules of engagement" between government and those providing independent scientific advice and point to the need for "clear roles and responsibilities", "transparency and openness", and "independence".[251] The Code goes further and provides detailed guidance on the establishment, management and conduct of SACs, as well as its relationship with the sponsor department.

89. Dr Mackie was, at first, unsure which code of practice the UK NSC adhered to, stating that she would "need to talk to the Department to understand which code of practice we work within".[252] She subsequently told us that the UK NSC was "not required to comply with the code of practice for scientific advisory committees" but that there was a set of "procedural rules" agreed "between the four countries".[253] However, she noted that a "code of practice" was "being developed that draws on CoPSAC [Code of Practice for Scientific Advisory Committees]".[254]

90. From the evidence we have taken, the UK National Screening Committee (UK NSC) broadly performs the functions of a Scientific Advisory Committee, yet it is not classified as such. A compelling reason for the status quo was not offered. It is of concern to us that the UK NSC Director of Programmes did not know what code of practice the UK NSC worked within. This suggests that the UK NSC's "procedural rules" are not informing its day-to-day work.

91. The Code of Practice for Scientific Advisory Committees (CoPSAC) reflects the authoritative guidance on providing independent scientific advice to government departments. It was intended to apply to advisory committees regardless of their specific structure and lines of accountability. We are, therefore, at a loss to understand why efforts are apparently underway to develop a distinct code of practice for the UK NSC that "draws on" CoPSAC, rather than adhering to CoPSAC in full. We recommend that the UK National Screening Committee adopts, and adheres to, the Code of Practice for Scientific Advisory Committees in its full and unchanged form.

The relationship between Public Health England and the UK National Screening Committee

92. In April 2013, the UK NSC became "part of" Public Health England (PHE), an executive agency of the Department of Health (DH).[255] Prior to this date, the UK NSC's annual reports indicate that it was funded by, and reported directly to, the DH.[256] While some witnesses were unconcerned by the UK NSC becoming part of PHE,[257] others expressed uncertainty about the impact of this move on the UK NSC's independence. The UK Faculty of Public Health raised concerns that "the current home" of the UK NSC in PHE "could be seen by the public as putting its continuing independence in doubt".[258] The Faculty also highlighted that wider questions about PHE's own independence from the DH had been examined by the Health Select Committee in early 2014.[259] Breakthrough Breast Cancer noted that the Advisory Committee on Breast Cancer Screening, which feeds into the UK NSC's deliberations, had also "fallen under the jurisdiction of […] PHE".[260] While there was no suggestion that this had resulted in any "restriction on the ability of the group to give independent advice", Breakthrough Breast Cancer stated that "consideration should be given to how this group can be held at arms-length from PHE to maintain its reputation as an independent source of advice".[261]

93. The Code of Practice for Scientific Advisory Committees states that they "should expect to operate free of influence from the sponsor department officials".[262] We therefore asked the Minister if this meant the Deputy Chief Medical Officer for England should not also be Chair of the UK NSC. The Minister replied that "the CMO team is independent and gives Ministers independent-minded advice".[263] The Minister therefore did not see "one [role as] being independent and the other not".[264] Professor David Walker, Chair, UK NSC, concurred noting that the "CMO has a statutory independent role and is allowed to take an independent view, separate from the Department. Therefore, it can act independently".[265]

94. Dr Anne Mackie, Director of Programmes, UK NSC, told us that while PHE "hosts" her and her team, "the members [of the Committee] are independent of Public Health England".[266] The Minister echoed this point, stating that she was "not aware" of any problem relating to the UK NSC's independence, adding that the UK NSC was "not within PHE" but rather that PHE "provides the secretariat" for the UK NSC.[267] However, different language is used in the Immunisation and Screening National Delivery Framework & Local Operating Model ("the Framework"), published jointly by PHE and NHS England in May 2013. The Framework states that the UK NSC, alongside the English National Screening Programmes and the NHS Cancer Screening Programmes, "sit within the Health and Wellbeing Directorate of PHE".[268] Evidence from PHE expanded further upon the relationship, acknowledging that PHE is:

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95. There is a worrying lack of clarity regarding the relationship between Public Health England and the UK National Screening Committee (UK NSC). It is essential that the two parties formally define their working relationship and identify the safeguards in place to ensure the UK NSC's continuing independence. We recommend that a memorandum of understanding between the UK National Screening Committee and Public Health England is promptly drawn up and placed in the public domain no later than December 2014.

234 Q3 Back

235 Q112 [Dr McCartney] Back

236 NHS008 [Professor Bewley] para 20 Back

237 NHS0036 [Breakthrough Breast Cancer and Breast Cancer Campaign] para 3.4.2; NHS0049 [UK Faculty of Public Health] para 1.2.7 Back

238 Oral evidence taken before the Science and Technology Committee on 2 April 2014, HC 1185, (2013-2014); Science and Technology Committee, Second Report of the Session 2014-15,After the storm? UK blood safety and the risk of variant Creutzfeldt-Jakob Disease, HC 327 Back

239 Science and Technology Committee, Third Report of Session 2009-10, The Government's review of the principles applying to the treatment of independent scientific advice provided to government, HC 158-I, para 2 Back

240 Government Office for Science, Code of Practice for Scientific Advisory Committees, (November 2011), para 6 Back

241 UK National Screening Committee, Policy Review. Screening in the UK 2011-2012, p 5 Back

242 UK National Screening Committee, NHS Screening Programmes, Annual Report. Screening in England 2011-2012, p 8 Back

243 Q191 Back

244 NHS0040 [Public Health England] Appendix 3 para 17 Back

245 UK National Screening Committee, 'Policy Review Process', accessed 10 July 2014 Back