Medical Technology Group (MTG) – Written evidence (LSI0025)
The Medical Technology Group (MTG) is a coalition of patient groups, research charities and medical device manufacturers working to improve access to cost effective medical technologies for everyone who needs them. The MTG is the only UK coalition of patient charities and medical technology companies working together to improve patient access to medical technologies. The common purpose of the MTG is to increase patient access to the best diagnostic, imaging, surgical and supported-living technologies in the NHS.
5. What can be learnt from the impact of the 2011 UK Life Sciences Strategy? What evidence is there that a strategy will work for the life sciences sector? How can its success be measured against its stated objectives?
In 2016 the MTG published our report ‘Deja Review: What lessons can be learnt from the past?’ This report set out the learnings that should be taken from previous NHS initiative aimed at supporting the life sciences sector in the UK. This report came in advance of the publication of the Accelerated Access Review and focussed on how it could avoid the pitfalls of other reports and initiatives.
We set out five areas we believe the Government should focus on:
The subsequent publication of the AAR and the recently published Life Sciences Industrial Strategy have addressed many of the issues raised in this report. The AAR has clear focus on the need for the NHS to improve its ability to harness the opportunities presented by innovative technology and use those to improve patient outcomes and deliver a thriving Life sciences Sector. By implementing the recommendations included in the report these benefits can be realised.
6. Does the strategy contain the right recommendations? What should it contain/what is missing? How will the life sciences strategy interact with the wider industrial strategy, including regional and devolved administration strategies? How will the strategies be coordinated so that they don’t operate in ‘silos’?
The MTG supports the recommendations contained the Life Sciences Industrial Strategy. There is a welcome focus on the role of the NHS and the use of innovative technology. Alongside this there are a number of recommendations around streamlining processes such as NICE assessment and uptake mechanisms.
The Strategy focusses on the Accelerated Access Review and suggests the recommendations within this should be form the basis of processes to streamline assessment methods, something the MTG would support.
Alongside streamlining the assessment methods for NICE appraisals, the MTG would also like to see a robust monitoring system for the implementation of recommendations from NICE – especially recommendations relating to medical devices. At present there is no benchmarking or tracking of NICE appraisals in relation to medical devices.
The report refers to the Academic Health Science Networks as a key vehicle for driving local and regional work, something the MTG has called for in the past.
The MTG is keen to see how the Strategy will align with other NHS strategies. Government programmes such the Procurement Transformation Programme, which came out of the Carter Review of NHS efficiency, will have an impact on how innovative technologies are used in the NHS. The Life Sciences Industrial Strategy should be implemented in line with these initiatives.
10. How can public procurement, in particular by the NHS, be an effective stimulus for innovation in the Life Sciences Sector? Can it help support emerging businesses in the Life Sciences sector?
The role of the NHS in supporting the Life Sciences cannot be understated. The UK has the World’s largest single healthcare system, something that should be harnessed to support the Life Sciences industry.
NHS procurement systems often focus on the upfront cost of an innovation or device, rather than looking at the life time value of products. This issue is particularly acute in medical devices, which rarely come with a NICE recommendation and for which there is not PPRS type pricing system.
The Life Sciences Industrial Strategy does not address the issue of procurement directly, focussing on the role of the NHS and the need to deliver value for money. The MTG supports the general thrust of this approach but we would like to see a greater focus on how the NHS purchases technology as part of the implementation programme. This should feature heavily in the work to build collaboration between NHS and industry, helping drive a focus on the long term value of technology, ahead of the short term cost.
The MTG believes that NHS procurement mechanisms should take into account the longer term and wider societal benefits of medical devices. This should include a focus on the benefits delivered by medical technologies outside of year one, and the benefits that are accrued outside of healthcare settings, such as those in social care and to welfare spending.
11. How can the recommendations of the Accelerated Access Review be taken forward alongside the strategy? Will the recent changes to the NHS England approval process for drugs have a positive or negative effect on the availability of new and innovative treatments in the NHS? How can quick access to new treatments and the need to provide value for money be reconciled?
The MTG supports the recommendations contained in the AAR. Establishing innovative pathways for devices based around horizon scanning, data collection, regulatory decision, evaluation and commercial decision and commissioning and uptake support, is the appropriate approach to take. The MTG also supports the stratification set out by the AAR – a specific bespoke pathway for products with a transformative designation, support from AHSNs for products with a high value to the national NHS and support from local commissioners for products with a high value to local NHS.
The Life Sciences Industrial Strategy is clear that the recommendations in the AAR should be used to ’streamline the processes and methods of assessment for all new products, simplifying and accelerating access and using a single clear decision point.’ The MTG supports this recommendation and would like to see the recommendations of the AAR form the basis of a long term, strategic approach to the NHS approach to innovation.
The MTG has long called for technology assessment to take into account the wider societal benefits of devices. Through broader assessment of the full range of benefits on offer the value for money that will be delivered from devices will become clear.
13. Who should take responsibility for the implementation of the Life Sciences Industrial Strategy and to whom should they be accountable? What should the UK Government’s role be? What should the role of the academic, charitable and business sectors be?
The Strategy sets out the key principles for governance and implementation:
The MTG supports the principles and the intent behind them. The Strategy also proposes the establishment of an ‘oversight board’. The MTG believes this board should have representation from across Government and NHS – this should include the Department of Health, BEIS, Department for International Trade, DExEU and NHS England. The MTG would also like to see patient representatives given a formal role on the oversight board.
The MTG would like to see a single point within the existing architecture that is responsible for implementing the strategy, this would most likely be the Office for Life Sciences (OLS). However, the OLS cannot be given sole responsibility for implementation as many aspects will fall out of their remit and will be the responsibility of other Government departments and agencies. The role of the OLS should be to oversee the implementation and support delivery in a coordination role.
Significantly for the medical device industry, a key component of delivery will be on the ground within the NHS. Delivering patient access to innovative technologies will be the key factor in supporting an innovative Life Sciences sector, it is therefore crucial that the roles and responsibilities of NHS organisations and NHS England are clearly defined, understood and agreed to as the strategy is implemented.
This should include an assessment of current initiatives in relation to medical devices and their use. Current NHS initiatives, such as the Procurement Transformation Programme that came out of the Carter Review of NHS Productivity, should be assessed as to how they can support the Strategy and both work programmes should be implemented alongside one another.
The Academic Health Science Networks should be given a clear role in the ‘on the ground’ delivery of the strategy and they should be supported to do so accordingly. These organisations are uniquely placed as an interlocutor between the NHS and industry and as such are the ideal vehicle for implementation.
14. What is the role of companies within the sector, particularly the large pharmaceutical companies, in the implementation of the strategy? How are they accountable for its success?
The medical device industry, alongside patients, the NHS and Government will have a critical role in the implementation of the Strategy.
The success of the Strategy will be in its ability to deliver long term strategic collaboration between industry and the NHS. The Strategy highlights the work of MTG member, Medtronic, in delivering efficiencies through collaboration with the NHS. The MTG would like to see this approach replicated across the NHS. Through close collaboration and joint working, industry and the NHS will be able to deliver system wide efficiencies and deliver effective treatments to patients.
The MTG would like to see a clear and defined role for both industry and patients in the oversight board, this would ensure they have a clear say in the key strategic decisions regarding the strategy.
15. Does the Government have the right structures in place to support the life science sector? Is the Office of Life Sciences effective? Should the Government appoint a dedicated Life Sciences Minister? If so, should that Minister have UK-wide or England-only responsibilities?
The MTG believes the existing structures, and those proposed in the Strategy, would be able to deliver effective implementation. At a national level, the Office for Life Sciences should be given a clear role in coordination of implementation.
It is critical that Government departments and NHS organisations such as NICE are given a clearly defined role in this process, with a set of well-defined objectives. The oversight board should have representation from those organisations to provide an effective governance vehicle.
At a regional and local level, the AHSNs should be given responsibility and support for the delivery of the Strategy. The AHSNs are uniquely placed to work across the NHS and industry to deliver collaboration and real impact for patients.
16. What impact will Brexit have on the Life Sciences sector? Will the strategy help the sector to mitigate the risks and take advantage of the opportunities of Brexit?
The risk to the life sciences sector from Brexit cannot be overstated, not least the uncertainty around future regulatory regimes, the impact on the work force, the ability of the UK to attract global investment and the export challenges posed to SMEs.
However, there are significant opportunities. The UK has a reputation as the gold standard when it comes to its regulators; this can be harnessed to attract investment. Whilst first and foremost the UK must maintain favourable terms for trade with EU partners, Brexit does offer opportunities to open up foreign markets on new terms.
The Life Sciences Strategy is well timed and contains the elements needed to deliver a successful Brexit and a thriving life sciences economy afterwards. The elements contained in the Strategy address the critical issues and as such the MTG are keen to see it implemented.
14 September 2017