Policy Development Service

Impact

Redesigning the process of developing policies that define when a specific treatment will be commissioned has delivered efficiencies and improved value for 15 clinical commissioning groups (CCGs) across Lancashire, Merseyside and Warrington.  Patients now get the right treatment, at the right time.

We produced a set of policies as a single model at scale using the latest clinical evidence and advice from specialists to drive the criteria. This work has ensured that polices are harmonised wherever possible to remove the ‘postcode lottery’ and that taxpayers’ money is used wisely.

Best practice including learning, feedback from users, and project documentation from our model has been used to drive NHS England’s design of a single end-to-end national toolkit to deliver policy development. This included terms of reference, a robust process chart, evidence review forms, governance documents, communication and engagement process and EIRAs. This will ensure a sustainable, collaborative approach to developing policies fairly and equitably.

Situation

Clinical Commissioning Policies are applied for specified treatments and define the circumstances when treatment will be commissioned by a CCG. Where CCGs have policies with different criteria, there is potential for inconsistency in how patients are treated, giving rise to claims of ‘postcode lottery’.

The underlying principles currently adopted throughout the NHS for reviewing Individual Funding Requests (IFRs) are that they should be appropriate, clinically effective, cost effective and ethical.

The NHS is not obliged to provide every treatment that a patient or group of patients may demand. However, it does have a duty to achieve its statutory financial balance whilst prioritising its allocation of resources for the population it serves using evidence of clinical and cost effectiveness and patient engagement. This is where a strong Policy Development Service such as that delivered by MLCSU is critical for a CCG’s Individual Funding Request (IFR) process to succeed.

Action 

Across the 15 CCGs we reviewed a total of 90 policies, carrying out an Equality Impact and Risk Assessment (EIRA) and an evidence review for each: 57 were identified as requiring consultation and engagement work, and 33 did not require consultation and engagement due to negligible change to the criteria. 

We supported seven CCGs in Merseyside to implement the most recent NICE clinical guidance for managing lower back pain and sciatica. They saw many inappropriate referrals but with the revised policies patients enter an appropriate back pain management pathway sooner – treating the causes rather than the symptoms of their pain.

Our through process involved:

• An engagement process tailored to local healthcare systems
• Stakeholder engagement including providers, public and the third sector
• A full EIRA and consultation, engagement and communications service (also provided by MLCSU) on each developed policy
• Full project management, research and scoping services
• Provision of strategic advice and direction for policy development
• Support for CCGs to identify policies for priority development and advice regarding the potential impact of a policy development
• Monitoring of the national landscape to inform our service
• Support for CCGs to take finalised policies through their internal approval processes and on to implementation, including contract agreements, stakeholder notification and data monitoring after go-live to determine impact and uptake of the revised policies.

Contact information:

Jonathan Horgan, Head of Medicines Management & IFR Services

Mobile: 07809 334188   Email: Jonathan.horgan@nhs.net

Harinder K Sanghera, Senior IFR & Clinical Policy Development Lead

Mobile: 07809 321589   Email: harinder.sanghera@nhs.net