23rd January 2017
NHS England consultation - generic commissioning policies
NHS England released consultation documents for new generic commissioning policies in October 2016. The deadline for responses was 15 January 2017 and we did submit a Neurological Alliance response.
Here’s the summary of what we submitted:
This consultation response covers the NHS England consultation exercises on four proposed generic commissioning policies:
1 In-year service developments
2 Individual Funding Requests
3 Funding for experimental and unproven treatments
4 Continuing funding after clinical trials
We welcome the opportunity to comment on these. NHS England’s current generic commissioning policies were adopted on an interim basis in March 2013 with a commitment to review in the same year. The adoption of permanent policies is therefore long overdue. However, we have concerns about the proposed policies as they currently stand, particularly around the extremely high thresholds and lengthy processes proposed for In-Year Service Developments (IYSDs) and Individual Funding Requests (IFRs). In addition, we are concerned about the absence from this consultation of a policy for access to clinically critically urgent treatment outside established policy. There is currently an interim policy for funding treatments for patients at clear risk of substantial and irreversible deterioration in their condition, or death, within three months, but it is not included in this consultation exercise. It is essential to patients’ welfare that there is a clear process for accessing funding in these cases.
A slightly edited version of the full submission is available here: