Consultation response: GHSM researchers argue that proposed changes to NICE technology appraisal may lead to unfair discrimination

GHSM PhD student Victoria Charlton and Dr Annette Rid have led the preparation of a detailed response to a joint consultation by the National Institute of Health and Care Excellence (NICE) and NHS England on changes to NICE’s technology appraisal process. The submission was based on two meetings of the KCL/UCL Social Values and Health Priority Setting group, which meets regularly to discuss current issues in decision making about health resource allocation.

The group’s submission highlights several issues associated with the proposed changes, arguing that the introduction of a new ‘budget impact threshold’ for technologies approved by NICE could lead to unfair discrimination. Under the proposals, technologies whose NHS budget impact is expected to exceed £20 million a year would be subject to delayed implementation, regardless of their cost effectiveness. A key driver of budget impact (but not of cost effectiveness) is the size of a given technology’s eligible patient population. The submission therefore argues that the proposal will introduce a new form of numerical discrimination, as patients suffering from relatively common conditions would be subject to delayed access to effective treatments compared to those suffering from less common conditions whose treatments do not breach the threshold.

The submission highlights the example of infliximab, a drug that is currently recommended by NICE as a cost effective treatment for both acute exacerbations of ulcerative colitis and severe active Crohn’s disease. Its price is the same for both indications, but the total cost of treating the small group of patients with the former condition is far lower than that of treating the 4,000 eligible patients with Crohn’s disease.  Under the proposal, the latter would breach the budget impact threshold, leading to delays in introduction.  The former would not.

 An editorial article further exploring these issues has been prepared by the group and is currently under consideration. The full consultation response is available here: kcl-ucl-social-values-group-response.


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