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The proposal for MedTech mandatory funding is a welcome step in the right direction. However, NHS England needs to be more ambitious in enabling the health system to realise and harness the value of innovative medical technologies. Greater flexibility needs to be afforded to the mandate’s restrictive eligibility criteria. As it stands, very few technologies will be awarded mandatory funding through failure to meet the criteria. This will be to the detriment of patients and the system will continue to neglect MedTech’s potential.

This December, Decideum responded to the NHS England and NHS Improvement Consultation on the MedTech Funding Mandate Policy.

In our full response, we outlined issues regarding the initial piloted 3 products proposed by NHS England. The products selected have already benefited from Innovation and Technology Payment funding. Decideum does not believe it is logical to pilot products, which ought to have already benefited from uptake support, to be the most informative test cases.

We also recommended the set-up of a transitional arrangement to offer MedTech previously appraised by NICE, a chance to be reviewed based on the new funding mandate. It is possible companies would re-think their economic cases to explore the possibility of securing mandatory funding.

In this article, we outline the consultation’s key eligibility criteria for MedTech to be awarded mandatory funding, and its limitations. We also make recommendations to improve the funding mandate’s proposals.

We focus specifically on the 3 cost-related criteria:

  1. MedTech must: deliver material savings to the NHS; the benefits of the innovation must be over £1 million over five years for the population of England

The £1million figure restricts the types of technologies that might be made available on the NHS. The fact that a product would not deliver more than £1million in material savings over five years alone, does not necessarily mean it would not be highly valuable to patients and the NHS.

As an example, several innovative and valuable technologies may not provide cost savings of £1million over the 5 years individually. However, collectively, such material savings may be achievable. If NHS England is looking to foster a positive MedTech environment, then it would seem logical to reward any cost-saving medical technology with mandatory funding, not just those technologies with especially high cost-saving potential.

This criterion may also disadvantage MedTech indicated for patients with rare diseases. Take, for example, two technologies that deliver equal material savings per patient, with one indicated for a population much larger than the other. Whilst both technologies offer equal value in terms of material savings per patient, one – with the larger patient population – will find it easier to meet the material saving criteria than the technology indicated to treat a smaller patient population. This would lead to service inequity for the population.

To remedy this issue NHS England should consider calculating savings on a per patient basis. That way comparators could also be assessed on a like-for-like basis.

  1. MedTech must: be cost-saving in-year; NICE modelling would demonstrate a net saving in the first 12 months of implementing the technology

The 12 month figure is restrictive. Only granting mandatory funding to technologies which are cost-saving in-year one inhibits the volume and speed of innovative medical technologies reaching patients on the NHS. It is likely that highly innovative and clinically effective medical technologies will carry upfront costs. It is therefore plausible that it will be difficult for high cost, highly disruptive technologies to provide net savings in the first 12 months.

This criterion may also limit technologies such as cancer screening diagnostics, where health outcomes and benefits are not realised until a much later date. Cancer diagnostic products may see cost savings realised at a longer time horizon compared to interventional procedures such as surgery, where cost savings are realised more immediately.

Decideum suggests that a mechanism exists to grant mandatory funding for MedTech that delivers considerable benefit, but is unlikely to reach net savings within 12 months on the NHS. This would ensure that the most innovative and valuable medical technologies reach patients quicker, with the knowledge that they will ultimately be cost saving. Such a mechanism would also show an appreciation for the variety of cost-saving time horizons that different products have.

  1. MedTech must: be affordable to the NHS; the budget impact must not exceed £20 million, in any of the first 3 years

Decideum appreciates that with finite health budgets, managing the budgetary impact of health technologies is important. However, we also believe that restricting what the NHS funds based on budget can damage innovation uptake and long-term benefits to NHS patients.

We believe the £20 million budget impact over any of the first three years is an arbitrary figure. It seems as though the same figure has been taken from NICE’s Technology Appraisal (TA) and Highly Specialised Technology appraisal (HST) budget impact threshold. We believe that NHS England should explain how it calculated this figure. If indeed, the £20 million figure derives from the TA and HST budget impact threshold, Decideum would like to know whether, as is the case in TA and HST, there would be an opportunity for the company to engage in commercial discussions with NHS England if the threshold was exceeded.

There ought to be a mechanism that allows technologies which exceed the £20 million budget impact threshold to receive mandatory funding, should the technology provide exceedingly high health benefits with potential cost-savings over the medium to long-term. This would ensure that patients who stand to gain the most benefit from certain technologies do.

Conclusion

Ultimately, this proposal is not as ambitious as it could be. NHS England’s analysis stipulates that of NICE’s 74  MTGs and DGs (Medical Technology Guidance and Diagnostic Guidance), only 4 would meet the eligibility criteria. That is, only 4 since the MTG/DG programmes began in 2010/11. Would this offer much improvement in the acceleration of MedTech uptake?

As set out above, affording flexibility to the criteria, would enable more technologies the opportunity to achieve mandatory funding, whilst also ensuring uptake of valuable innovations for patient benefit. This could be accomplished through legislating the use of approved technologies which have met the funding mandate criteria.

For more information regarding Decideum’s response to the consultation, please contact will.greenhill@decideum.com

Will Greenhill

Consultant

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