NICE’s consultation on the proposed case for change for its methods closes today. The consultation exercise has proved to be a huge undertaking, generating very high levels of interest from across the life sciences ecosystem, demonstrated by the 400 plus individual attendees at NICE’s engagement webinar in November. At that webinar NICE also impressed upon the attendees that this would be the last methods review of its kind, with future reviews happening in a modular fashion.
Whatever your perspective on NICE’s methods, such a consultation, with interest from a truly broad group of stakeholders, can only be a good thing. We are particularly encouraged to see NICE’s determination to consider the views of external stakeholders and the public, with societal preference as the basis in much of its proposals. We also commend NICE for making flexibility and adaptability central themes, and acknowledging the challenges inherent to the dynamic nature of the life sciences industry. NICE’s willingness to account for this dynamism, and the methodological difficulties it can bring to NICE, is extremely welcome. Specifically, we support NICE’s intention to consider a greater degree of flexibility when uncertainty exists for conditions where evidence generation is understood to be complex and difficult. We hope that in the long-term this might provide greater patient access to innovative technologies
However, we along with many others, consider that NICE’s recommendations do not go as far as they could in relation to some challenging areas. For instance, NICE’s proposal to explore quality of life instruments beyond EQ-5D is welcome, but there is also an urgent need for guidance on the use of disease specific utility measures. We hope NICE will take on board ours and others feedback on this matter. Equally, we are also concerned about some proposals that would see NICE consider the cost, and therefore budget impact, of some interventions alongside cost-effectiveness. Further, Decideum opposes proposals not to recommend a technology for a particular subgroup, even when the technology is found to be clinically and cost effective for the whole population. We believe that this in fact contradicts NICE’s stated aims to ensure patients have access to cost effective health technologies, and would set a dangerous precedent on the fundamental role of NICE recommendations.
We know that, despite its broad scope, NICE’s review represents evolution rather than revolution. However, we still hold out hope that we will see improvements that will demonstrate NICE’s, and the broader system’s, commitment to encouraging innovation in life sciences that can transform the experience of patients.
Read the full response here: Decideum Response to NICE Methods Review Consultation
For further insight on the methods review or if you would like to know more about Decideum, please email us at email@example.com.