Evidence submitted by KCI Medical UK (NICE
14)
EXECUTIVE SUMMARY
Introduction
Founded by an emergency room physician in 1976,
Kinetic Concepts Incorporated (KCI) is a global corporation providing
leading edge innovation in wound care, pulmonary care, bariatric
care, and circulatory improvement in all care settings. KCI manufactures,
delivers and services one of the largest offerings of speciality
beds and related medical devices. The company is dedicated to
taking an active role in the healing process, helping to save
patients lives, improve the quality of patients' lives, and reducing
the overall cost of healthcare.
KCI Therapies have clinical evidence and/or
are financially justified in more than 350 publications, including
approximately 280 peer-reviewed clinical articles. Through research-based
protocols and a clinically trained support team, KCI helps ensure
that the right patient receives the right therapy for the right
length of time.
KCI welcomes the Health Select Committee's inquiry
into the work of the National Institute for Health and Clinical
Excellence (NICE).
Overview
KCI recognises that NICE and its guidance to
the NHS is seen as the gold-standard at an international level.
Guidance, particularly clinical guidelines, which to date have
been of most relevance to KCI, can have beneficial effects in
changing NHS practice and in developing the most effective way
of managing conditions. For this reason, it is essential that
guidance is developed through consultation with the most appropriate
clinical experts. It is also vital that the timescales associated
with the development of guidance do not result in the publication
of advice that is considerably lagging behind medical technology
innovation and clinical practice.
Recommendations
Research is carried out in the initial
phases of the development of clinical guidelines to identify the
most relevant clinical experts for that area, who are then invited
to be involved in the scoping exercise.
There is an assessment of the speed
of publication of clinical guidelines and other NICE guidance,
including guidance reviews, to ensure that there is a process
for timely update to reflect advances in technology and clinical
practice.
A formal process to monitor how NICE
guidance is used in the clinical setting is both developed and
implemented.
A formal process is developed for
the dissemination of clinical guidelines to relevant healthcare
professionals.
KCI'S VIEWS
ON THE
COMMITTEE'S
TERMS OF
REFERENCE
1. Why NICE's decisions are increasingly
being challenged
1.1 NICE is recognised across the world
for the guidance it provides to the NHS. One of the roles of the
Institute is ensuring that the NHS receives the best value from
limited resources by assessing clinical and cost effectiveness
through technology appraisals. It also provides advice to the
NHS on the best ways to manage treatment pathways for certain
conditions, through clinical guidelines. Guidance from NICE, especially
given the statutory implementation element of technology appraisal
guidance, is considered to be the marker by which many NHS organisations
make their funding decisions. This is especially true for treatments
that are innovative and/or perceived to be "high cost".
Often in these instances, funding will not be made available for
a treatment unless it is subject to positive guidance from NICE.
Therefore, should a treatment either not be subject to NICE guidance
or receive guidance that does not recommend its use on the NHS,
this can be the end of access to an innovative treatment and acts
as a significant barrier to clinical decision-making.
2. NICE's evaluation process, and whether
any particular groups are disadvantaged by the process
2.1 The most important element of the development
of effective and useful clinical guidelines is the scoping phase.
It is the opportunity for all the relevant stakeholders to ensure
that the remit of the guideline fits with clinical practice and
will provide a useful and necessary addition to NHS care. Currently
however, it is at this stage that the most appropriate clinical
experts are not always consulted. Details of the proposed scope
are published by NICE, but it is often not until the guideline
is in development, or until it is published that the most relevant
clinical experts are aware of the guideline. As the scoping phase
is the most important, it is vital for clinical experts to be
involved in this process.
2.2 In order to further ensure that clinical
guidelines are the most relevant, it is also vital to ensure that
the appropriate clinical experts are included on the guideline
development groups. While there is clinical representation on
these groups, it is essential that these clinicians and healthcare
professionals appropriately reflect the necessary clinical expertise
to understand the impact and practical application of a guideline.
3. The speed of publishing guidance
3.1 Currently, from the initial scoping
and referral phase for a clinical guideline, it takes at least
two years for the guidance to be published by NICE. In practice,
it is often longer than this time frame, due to adjustments to
the guideline as it develops and for logistical reasons. It is
then, as standard, at least three years before the guideline is
reviewed. The innovative nature of medical technology means there
is a relatively rapid pace of development. Clinical practice also
alters to reflect this technological change. It is therefore possible
for a clinical guideline to be behind both technology and clinical
practice by the time it is published by NICE, and significantly
behind by the time it is assessed in relation to carrying out
a review.
3.2 This not only means that the NHS is
charged with implementing guidance that may no longer be the most
appropriate, but that with a potential seven year time frame between
the initiation of a guideline and assessment of the need for review,
the impetus to develop high standard evidence on a technology
is reduced.
4. Comparison with the work of the Scottish
Intercollegiate Guidelines Network (SIGN)
4.1 Guidance provided by the Scottish Intercollegiate
Guidelines Network (SIGN) for NHS Scotland and by NICE for NHS
England and Wales, can be beneficial for the development of services
and the care of patients. However, in relation to the timing of
guidance, the timescales for the review of guidance from SIGN
can be greater than those for NICE guidance. As outlined in relation
to NICE guidance in the section above, timescales like this can
result in significantly out of date guidance.
5. The implementation of NICE guidance, both
technology appraisals and clinical guidelines (which guidance
is acted on, which is not and the reasons for this.)
5.1 KCI's experiences indicate there is
a lack of universal implementation within the NHS for NICE clinical
guidelines. Without the statutory implementation in terms of funding
and timeframe that is associated with technology appraisal guidance,
there is a significant diversity in approach to clinical guidelines.
NHS organisations charged with implementing guidelines have different
levels of awareness of guidanceespecially at the appropriate
levels to ensure best implementationand different processes
for the dissemination of guidance to relevant front-line healthcare
professionals. In order to ensure a more universal implementation
of guidance, there needs to be a specific process for the dissemination
within the NHS and a formal process for monitoring this by an
appropriate independent body.
Claire Weston
KCI Medical
March 2007
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