The Urology Trade Association welcomes the opportunity to respond to the Department of Health’s consultation Refreshing the Mandate to NHS England 2014 – 2015.
The Urology Trade Association (UTA) is the leading urology membership organisation, representing 95% of urology product manufacturers and suppliers to the urology appliance market.
An estimated six million people in the UK are affected by continence problems and many rely on urology appliances on a daily basis. High quality urology appliances allow users to manage their conditions, maintaining their quality of life and independence and avoiding repeated medical consultations. A majority of continence services are delivered in the community and this will be the main focus of our submission.
The UTA has become increasingly concerned about arrangements made previously by some PCTs and inherited by clinical commissioning groups (CCGs) which restrict patient and prescriber choice in the selection of urology appliances. We believe that choice in this area is vital to improving outcomes for patients who use urology products, and we hope that NHS England will act to promote choice in the interest of patients.
In urology care, the range and choice of appliances and associated care items that are available for prescription on the NHS is governed by the Drug Tariff, which also acts as a reimbursement framework for NHS providers. An important benefit of these arrangements is that it guarantees equality of access across the country. The Drug Tariff is a comprehensive list of products which have been assessed and approved at a national level as clinically effective and cost effective. However, we are aware that a number of NHS Trusts are introducing local formularies which narrow down the range of products approved for use at a national level into a reduced set of products for prescribers to recommend to patients.
- What views do you have on the proposed approach to refreshing the Mandate?
The UTA agrees with the proposed approach to refreshing the Mandate but would caution that too much change to the Mandate at this early stage, with it having only come into effect in April 2013, could delay the successful embedding of its responsibilities by NHS England.
That said, ensuring that the Mandate pays particular reference to the importance of maintaining patients wellbeing and dignity is very important – as was shown in the Francis Review. The points made in the Berwick review of patient safety are also apposite.
In its consideration of how patients’ dignity and wellbeing can be protected, the Mandate should ensure that NHS England pays particular attention to conditions, such as urology related conditions, which impact on people’s quality of life and where lack of appropriate support and products could create further complications and public expense.
- What views do you have on assessing NHS England’s progress to date against the objectives?
As mentioned above, NHS England has only recently taken on its responsibilities and the objective of the Mandate. This means that it is currently too early to properly assess its performance against objectives.
- What views do you have on the proposals to help people live well for longer?
The UTA agrees with the ambition to help people live well for longer, but thinks that the proposals focus entirely on helping people to live longer and not on helping people to live well.
More consideration should be given to the support that can help people to live more independent and more satisfying lives. Urological conditions have a significant impact on people’s wellbeing – without the proper support and the appropriate products many people would need near constant nursing care, for example. Patients having access to appropriate products is vitally important if they are to independently manage conditions such as incontinence. It can also help save the NHS money through reduced wastage, reduced infections and reduced reliance on health and social care.
By helping people to better manage their continence problems, NHS England can significantly improve their quality of life – helping them to live well and helping to reduce the burden on the NHS and wider public services.
It is, of course, also right that NHS England should have objectives around reducing deaths from treatable conditions – earlier diagnosis is an important part of this. As continence problems are often a manifestation of a wider problem, giving people better support and helping them to talk about their condition can also help with the early diagnosis of illnesses such as cancer. GPs should be encouraged to address continence issues with their patients, especially with high risks groups, such as the elderly, who might be slow to come forward with such problems.
- What views do you have on updating the Mandate to reflect the Francis Inquiry and the review of Winterbourne View Hospital?
The UTA believes that the Francis Inquiry and the review of Winterbourne View Hospital raised some very important issues about the need for people to be treated with dignity and respect. An important part of that is recognising and providing for the individual needs of each patient.
The UTA has witnessed a disturbing trend in urology patients being denied access to the products that are right for them. For example, some local areas have introduced formularies which effectively limit the range of products that prescribers can offer to patients. This means that while patients are entitled to access to whichever product on the Drug Tariff that best suits their individual needs, in reality they have access to only a small number of them. For patients with urological conditions this can be devastating as the smallest difference to a product – for a person with reduced dexterity, that difference might be a catch which opens at a different angle, for example – can make the difference between being able to self-care and having to have a nurse change their products two or three times a day.
When incorporating the recommendations from the Francis Inquiry into the Mandate for NHS England, it is important that the needs of individual are foremost – only in this way will patients’ dignity and wellbeing be protected.
- What views do you have on updating the existing objective to reflect the challenge for NHS England to introduce the “friends and family test” to general practice and community and mental health services by the end of December 2014 and the rest of NHS funded services by the end of March 2015?
The UTA believes that the “friends and family test” can be useful in enabling NHS England to get an better understanding of what people think of the care that their loved ones receive. Family and friends are often in an excellent position to assess this – they see how the patient is responding to their care and they are often the people that patients turn to first if there are problems.
However, the pressure on GPs to reduce costs and meet targets often means that they do not have enough time to spend with each patient and to explore their needs. This is especially a problem with conditions which people might be more reluctant to discuss with anyone, even their friends and families. Conditions such as incontinence still have a taboo about them which means that people would be less likely to discuss their problems and their treatments with others, even if cost pressures at the local CCG has meant that their access to the products that they need has been limited.