The Cancer Drugs Fund consultation closed this week – what are we hoping to see once the new fund is launched on 1 April? Our Policy Team explain some of the key points we raised in our consultation response.
Our previous blog posts explained the proposals for how the Cancer Drugs Fund (CDF) will operate from April 2016 and how drugs currently being funded will transition to the new system.
For the past 3 months, the policy team has been working behind the scenes to both understand the implications of some of the more technical aspects of the proposals as well as gathering the views of our patients and supporters.
Our survey about the proposals received a massive 704 responses from patients and supporters in just under a month, showing both the strength of feeling and concern on this issue. This vital insight helped us to form our response to NICE and NHS England and we have used quotes from patients throughout to ensure that the patient voices were highlighted, before the Fund is re-launched in April.
We also consulted with a variety of experts, including colleagues from NICE, other charities, academics and pharmaceutical companies to see what additional insight we could gather about the impact of the new proposals.
Key points raised in our consultation response
There is a real danger that the current proposals for the new CDF, if implemented as drafted, will actually reduce access to breast cancer medicines
All treatments available on the new CDF will need to be appraised and recommended by NICE. This includes all new treatments and all medicines that are currently on the CDF. However, we don’t think that the NICE appraisal process has changed sufficiently to guarantee access for breast cancer drugs.
The last six breast cancer drugs have been rejected by NICE, despite some of these being clinically effective. This is because NICE cost-effectiveness criteria is strictly set and new medicines for cancer have had great difficulty in meeting NICE’s threshold in recent years. The CDF was created in 2011 in recognition of the need for better access to life-saving and life-extending medicines for cancer patients, where these treatments have failed to meet NICE’s threshold.
There needs to be much wider reform of the NICE appraisal process
NICE clearly has a role to play: we need to be able to distinguish between drugs that are more or less effective, but we also need to ensure that the effective treatments have a way to be included in routine care on the NHS. The old CDF has been able to negotiate much more favourable prices and reimbursement plans to the NHS over the past 12 months.
Yet, under current proposals, NICE will not have the flexibility to negotiate on price, so many of the clinically effective drugs currently available at discounted prices on the CDF may no longer be available in the new system without appropriate reform to the NICE appraisal system. We believe that a wider review of NICE appraisal processes is needed to assess how flexible pricing could better ensure access to innovative medicines for patients.
We know that flexible pricing works in many other European countries and we would like to see this explored as an option as part of the re-design of the new CDF. Without such reform, breast cancer drugs currently available via the CDF, might not continue to be offered to new patients.
Patient involvement needs to be meaningful
Breast Cancer Now represents the interests of breast cancer patients and we often work with NICE when it performs appraisals of new treatments. While NICE should be commended for involving patients at every stage of the process, we are not sure how patient involvement can influence the final decision about the medicine being assessed.
For this reason, we would like NICE to provide further clarity on how patient involvement in a medicine’s appraisal process can influence the outcome of whether it is made available on the NHS.
End of life criteria
The NICE appraisal Process, is expected to remove the criteria of a small patient population, in order for treatments to be considered for the ‘End of Life’ criteria. This criteria carries a higher price bracket and applies to patients nearing the end of life.
Previously, this criteria meant that breast cancer drugs were not eligible to be included. The proposed removal of this criteria is very good news but the reform of NICE appraisal processes needs to be much more wide-ranging.
There are less than two months to make any changes to the proposals to the CDF and we very much hope that NHS England and NICE take this time to carefully consider the feedback they have received from the consultation process to ensure that the new CDF means better access to innovate treatments to all patients.
If you have any questions or concerns about the CDF, you can contact the Policy team by emailing firstname.lastname@example.org