On 16 November 2017, we responded to the NICE consultation on their proposals for increasing capacity within their technology appraisal programme. NICE’s aim is to change the process to make it more likely that the first committee meeting reaches a final decision by doing more work before that meeting. This will increase efficiency and allow NICE to do more.
While we understand their goal, we have profound concerns about the proposals. In essence, the changes proposed reduce the role of patient and clinical experts and move the discussion and assessment of evidence out of the appraisal committee meetings, which are held largely in public, to a much less transparent and accountable part of the process.
Instead, the evidence assessment will be carried out before the committee meeting by a ‘technical team’, consisting of NICE technical staff, and external evidence review group and appraisal committee members, with the committee meeting itself reduced to a rubber stamp.
The proposals make it fairly clear that the bulk of the work of a technology appraisal is to be carried out by the technical team: evaluation of the case for clinical and cost effectiveness; resolving technical uncertainties and substantive issues; producing a report encapsulating their conclusions; and responding to comments made in the consultation. All that is left to the committee is to decide whether to accept the conclusions in the report or to require more scrutiny or evidence before the updated report is brought back to the next meeting.
Clinical and patient experts will be asked to submit their evidence in the form of personal statements, and if the technical team consider these to be ‘sufficiently clear’, the patient and clinical experts will not be invited to attend the committee meeting.
This is a massive backward step and in direct conflict with the commitment in the NICE Charter to value the input of patients/carers in the development of guidance and involve the people for whom the guidance will be relevant.
The proposals represent a dangerous direction of travel, and we oppose them. In our response we urge NICE not to trade transparency for efficiency: this is neither an acceptable nor necessary trade-off as it should be entirely possible for the process to be made more efficient without this significant sacrifice. We look forward to further discussion with NICE on this.
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