Richmond Clinical Commissioning Group Report Summary
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1 Richmond Clinical Commissioning Group Report Summary Meeting Title: Richmond CCG Governing body Date: Report Title: SWL Effective Commissioning Initiative (ECI) Policy 2014/15 Agenda Item: 9 Attachment: E Purpose: (please delete /N as appropriate) Approval/ Ratification Discussion/ Comment For Information Other Author: Presented by: Dr Paul Elgey & Oliver McKinley David Sykes Head of JCC Executive Leads (Clinical and Officer) Further Information contact: David Sykes Head of JCC David.sykes@ richmond.gov.uk Executive Summary: The SWL Effective Commissioning Initiative (ECI) policy is a key commissioning policy which provides criteria to inform the commissioning of clinical interventions in SW London where national policy is absent e.g: Procedures with limited clinical effectiveness (PoLCE) Procedures where initial conservative therapy is possible Effective procedures where a threshold for intervention may be appropriate Procedures where NHS provision may be inappropriate It is a rolling document requiring on-going review to ensure specific policy areas are updated and new policies developed in accordance with new and updated local and national clinical policies and guidance. It ensures equality and consistency of treatments amongst patients and access to new services and interventions based on the best available clinical evidence. It is a tool to assess the appropriateness of referrals; e.g. through clinical assessment services or equivalent and supports the CCGs to decline inappropriate referrals, thus ensuring that funding can be diverted to key priorities. The success of the ECI depends on the policy being updated and refreshed and owned by the six south west London CCGs. In order for the document to be reviewed and revised it requires the effective participation of all six local boroughs public health teams and CCG commissioners. The update of the policy requires a rolling programme work-plan to be in place with regular meetings required for discussion and evaluation of new policies and policy changes before finalisation, due to the complexity of the policies and the need to ensure each criteria represents best clinical practice and current evidence. The policy required several amendments to ensure alignment with current systems and best practice including the new Working together a healthier Richmond for everyone Page 1 of 3
2 commissioning responsibilities brought about by the Health and Social Care Act (2012), updated published evidence, new NICE guidance and concerns raised regarding clarity of policy wording. Failing to review and agree revision of policies due to updated evidence and NICE guidance results in the policies being out of date and no longer evidence-based. This leaves CCGs vulnerable to policy challenge. Failing to review and agree clarity on policy wording could result in inequitable application of policy across CCGs due to differing interpretation. Again, leaving CCGs vulnerable to policy challenge. Prior approval routes within current document are now out of date. Therefore referral routes, collating levels of activity data and monitoring of adherence cannot be managed effectively. The 2 major risks for CCGs for failure to review the ECI are: o the consequences of successful policy challenge which could be legal, financial or reputational and o failure to realise financial savings through effective commissioning. The current policy for 2014/15 has been signed off and agreed at Clinical Executive Team on 14 th October. The ECI policy needs to be ratified by this group and delegated for any future approval. Financial/Resource Implications: Communication plan and stakeholder involvement: Committees that have previously discussed/agreed the report and outcomes: Equality Impact Assessment: NA SLCSU approach includes working with all Public Health departments and CCGs to inform and agree the policy, respectively. All other SWL CCG s have signed the document off and endorsed the new changes. NA Recommendation: It is recommended that the Governing body ratify the changes to 14/15 ECI policy. Next Steps: Once approved and ratified, the ECI 2014/15 Policy is ready for implementation into acute contracts. Working together a healthier Richmond for everyone Page 2 of 3
3 Which Strategic Objective(s) does the paper address? (please delete /N as appropriate) 1. Clinical Leadership: Use the experience of GPs and other healthcare professionals to commission safe, efficient, sustainable secondary, tertiary and community health services 2. Commissioning: Work closely with our local health providers in primary, social and community care, the local authority, and community and voluntary sectors to secure the best services delivered in the best setting for local people 3. Quality: Engage and involve the local population in the decisions we make in the planning, design, procurement and quality monitoring of services and ensure sustained focus on improving quality and safety of services 4. Governance: Ensure appropriate constitutional and governance arrangements are in place to enable the CCG to become a highly effective membership organisation 5. Finance: Ensure the most efficient use of resources to get the best value for patients Which Strategic Risk(s) does the paper help to mitigate? (please delete /N as appropriate) 1. Failure to ensure patient safety 2. Failure to ensure commissioned services are good value, quality and are delivered 3. Failure to maintain or improve health outcomes 4. Failure to develop and implement Out of Hospital Care Strategy 5. Failure to engage with and manage expectations of key stakeholders 6. Failure to maintain an on-going positive financial position Cover sheet version revised Page 3 of 3 Working together a healthier Richmond for everyone
4 Policy Changes Description of Changes Rationale for changes Document formatted Criteria were numbered and text formatted. Numbering of criteria and formatting of the descriptions of each criterion enable the document to be read and understood more easily. The numbering of criteria also enables specific sections of the document to be referenced with ease. Version Control Version control sheet added to document. Version control sheet depicts the changes made to this document from February 2014 to June This sheet is a step by step guide to the changes made in chronological order for easy referral. Ambiguous Policies Aesthetic Surgery General Principles Surgical Correction of nipple inversion Statement added: The table below describes the criteria/guidelines for aesthetic procedures and should be considered against requests for procedures as indicated in this policy document. See General Principles added to criteria. To indicate this criteria be used throughout this document for aesthetic procedures where there is no specifically written criteria. E.g. Tattoo removal. Statement of instruction to refer to General Principles criteria in order to clarify criteria and indicate that there are further criteria which need to be considered for this policy. Rhytidectomy (face lift) See General Principles added to criteria. Statement of instruction to refer to General Principles criteria in order to clarify criteria and indicate that there are further criteria which need to be considered for this policy. Pinnaplasty/Otoplasty See General Principles above, added to criteria. Inserted: The patient should be between 5 and 18 years of age (surgery under 5 should only be considered for children who require a hearing aid and where this will be better supported following a correction of ear prominence)the angle between the side of the head and the external ear should be more than 35 degrees. (Normal angle is between 20 to 35 degrees). General Principles added to indicate further criteria to be considered for this procedure. Criteria added for consideration when application is being considered in exceptional circumstances. Ages of child where this procedure is most beneficial, have been highlighted. Angle between side of head and external ear has been included in order to define congenital deformity and ensure consistency when considering this. It is necessary to consider any psychological distress of the child themselves, as opposed to the parents.
5 Hair Replacement Techniques to correct hair loss Abdominoplasty/Apronectomy Liposuction Facial Skin Procedures The level of psychological distress felt by the patient - The child rather than the parents are concerned about prominent ears. Further references for evidence included. Statement inserted: If clinical exceptional circumstances exist, applications for funding can be made in the form of an individual application (such as an Individual Funding Request (IFR). Correct formula for calculating percentage of excess weight added to criteria. * Percentage of excess weight lost = initial weight current weight x 100 initial weight (25 x height 2 ) (NB where weight is in kilos and height is in metres) Reworded criterion: Liposuction will not be routinely funded simply to correct the distribution of fat. If clinical exceptional circumstances exist, applications for funding can be made in the form of an individual application as per local agreement (such as an Individual Funding Request (IFR). Reworded criterion: Skin resurfacing procedures for cosmetic purposes or purely to improve appearance will not be routinely funded. Individual requests will be considered on References included as evidence and further rationale for these changes. As exceptional circumstances are assumed to exist in these cases, criteria now provides clear instruction to consider the IFR route as an alternative route for funding, as this procedure is not routinely funded on the NHS. Correct formula added in order to provide applicants with the knowledge of how best to calculate this point of the Abdominoplasty/Apronectomy criteria. Criterion is therefore more user friendly and encourages applicants to provide all the necessary information when applying for funding. Criteria reworded to ensure that there is no blanket statement here with regards to funding. Statement included instruction for applicants to apply for funding through the IFR route, in order to suggest that funding may be granted if exceptional circumstances exist. Wording of criteria adjusted to avoid a blanket statement, that cosmetic skin resurfacing procedures will not be funded. Exhaustive list of conditions removed in order to expand the criteria and refrain from implying that only treatment of certain conditions will be considered. Rewording ensures that evidence to prove exceptionality is provided, and that this treatment
6 Treatment of vascular lesions Injection of facial Botulinum Toxin for Cosmetic Indications Hair Depilation (hair removal) an exceptional basis where there is evidence that the procedure will improve clinically significant signs and symptoms Reworded: Individual requests will be considered on an exceptional basis which may include evidence that facial lesions cause significant disfigurement or obstructive symptoms. Reworded criteria: Botulinum toxin is not routinely funded for the treatment of facial ageing or excessive wrinkles. If clinical exceptional circumstances exist, applications for funding can be made in the form of an individual application (such as an Individual Funding Request (IFR). Botulinum toxin is available for the treatment of pathological conditions by appropriate specialists in cases such as Frey s syndrome-gustatory sweating after parotid surgery; Botox A injection is recommended as a first line treatment for Frey s syndrome and can be used in conjunction with or instead of oral anticholinergic medication. Criterion reworded: Treatment of severe hirsutism on the facial, neck and/or chest area will be considered if standard treatments have failed and exceptionality is demonstrated. Inserted: Funding will be agreed for a course of treatment after which a review of effectiveness will be required prior to would be appropriate. Criteria previously had been worded such as to begin defining exceptionality with the use of specific conditions. The policy was reworded in order to broaden the realm of potential circumstances which could exist for funding. Policy now also raises the necessity of evidence to prove that facial lesions may cause obstruction or disfigurement. Examples of conditions which are not normally treated are still mentioned as examples. Criteria reworded for clarification and avoidance of a blanket statement that Botulinum toxin is not funded for treatment of facial ageing or excessive wrinkles. Instruction given for applicants to explore the IFR route for funding in the event of exceptional circumstances. Conditions where this treatment is available is clarified. Criterion reworded in order to clarify the routes to follow for funding. I.e. Standard treatments must have failed in order for funding to be considered by ECI, and then exceptionality must be demonstrated if following the IFR route. As no specific timeframe for treatment was previously referred to in the criteria, a statement was inserted to allow for a curb in the number of treatments funded, prior to review. This prevents an indefinite number of treatments immediately being funded.
7 Asymptomatic Gallstones any further funding being agreed. Reworded criterion: CCGs will not routinely fund cholecystectomy for asymptomatic gallstones. Applications for funding should be made in the form of an individual application (via an Individual Funding Request (IFR) Criterion reworded for clarification. This now clearly instructs applicants that funding requests for this procedure should be made via the IFR route, as this procedure Is not routinely funded. Revised Polices Circumcision Open MRI Statement inserted: Circumcision will be considered on medical grounds where clinically indicated. Recurrent balanoposthitis resistant to antibiotic treatment. Balanoposthitis can be successfully treated using antibiotics. Most people do not have further infections. Circumcision is usually recommended only in adults in rare cases where someone has repeated infections. Patients who suffer from claustrophobia where taking an oral prescription sedative 1 to support conventional MRI has been tried and was not effective. OR Patients who cannot fit safely or comfortably in a conventional MRI, due to obesity or to some other confirmed clinical condition. 1. GPs should prescribe an oral sedative before referring for an Open MRI 2. Standard MRI has a 60 cm bore Changes to this criterion agreed by ECI policy group Clause inserted to prevent the inclusion of a blanket statement saying that circumcision for religious or cultural reasons will not be funded. Additional criteria added to include an additional clinical condition where the procedure may be indicated. Evidence is also inserted for rationale of criteria, as well as references. Criteria reformatted for clarification. Criteria clarified and expanded in order to highlight the necessity of an oral sedative actually being attempted prior to funding request. Criteria also expanded in order to capture a cohort of patients who cannot fit safely in the closed MRI machine due to clinical conditions other than obesity. Additional information provided for applicants to refer to, prior to Open MRI referral. Statement inserted clarifying that standing MRIs etc. are not routinely funded, and these requests require an IFR application. Evidence included supporting changes with the criteria and the viewpoint of the ECI policy group members with regards to certain types of MRI machines.
8 and can tolerate a maximum weight of 250 kg. Latest Standard MRI machines have an 80cm bore and are able to scan obese patients. Please check before referring for an Open MRI. Further sections included on Open/Semi Open MRI as well as Standing/weight bearing MRI for the information of the applicant to consider prior to referral. This further information also supports the decisions of the policy members with regards to changing this criterion. CCGs will not routinely fund: Standing, Weight-Bearing, Positional, or Upright MRI except on an exceptional basis via the IFR route. Further information inserted to criteria describing evidence of studies between open MRI and short bore MRI with regards to the reduction of claustrophobic events. Further information on open/semi open MRI included in criteria, as well as further information on standing MRI, for which is has been detailed there is limited scientific data. Carpal Tunnel Syndrome Clause inserted: This policy is not applicable to St George s Hospital - Refer to the St. George s Hospital Carpal Tunnel Management Guidelines & Referral Protocol. Dupyutren s Contracture Clause inserted: This policy is not applicable to St George s Hospital - Refer to the St. George s Hospital Dupuytren's Contracture Guidelines & Referral Checklist. Clauses inserted to bring attention to the fact those criteria at St George s Hospital for this procedure differ from those within the ECI policy. Policy members have agreed to postpone the revision of this criterion until next year s document is released. No further changes are therefore made. Clauses inserted to bring attention to the fact those criteria at St George s Hospital for this procedure differ from those within the ECI policy. Policy members have agreed to postpone the revision of this
9 Manual Lymphatic Drainage Varicose veins Statement inserted: CCGs will not routinely fund MLD as part of the Decongestive Lymphoedema Treatment (DLT) 1 or on its own. It can only be considered through the prior approval route. Applications for funding can be made in the form of an individual application (such as an Individual Funding Request (IFR)) The panels may consider referral criteria, staging (at appendix J) and guidelines contained in the Best Practice for the management of Lymphoedema (Lymphoedema Framework 2006) to determine exceptionality. In all circumstances, MLD should not be funded on its own but in combination with DLT. Entire policy developed in line with NICE guidance. Reworded and new criterion added. Further background inserted, as well as management information, rationale and evidence supporting this information. criterion until next year s document is released. No further changes are therefore made. Statement inserted to clarify that this procedure is not normally funded. An IFR request is therefore necessary. Blanket statement avoided. An additional reference for best practice guide is inserted as guidance in appendix of document. Entire policy reworded and developed for clarification, in line with NICE guidance. Statement inserted regarding varicose veins in pregnancy, which would exclude requests of this nature. Symptomatic patients are specifically said to be referred to a vascular service, this criteria therefore specifies the difference between clinical reasons and cosmetic. Policy is consequently clearer, though will effectively lower the current thresholds for access to surgical treatment. It is anticipated that an increase in activity levels will ensue. A financial forecast has therefore been recommended by the ECI policy group. Evidence regarding the use of support stockings has been included, as well as interventional management in order to further support the criteria and rationale newly developed.
10 Further Document Changes Appendix A Prior Approval Croydon CCG Request Funding Pathway Appendix B ECI/IFR application form Appendix G Local IVF poicies Appendix J Lymphoedema Staging and Referral Criteria. Appendix K NHS England Policies Appendix L Governance Out of date Prior Approval Sheet removed from Appendix A of document. CReSS arrangements added. ECI request form has been removed and replaced with the new and up to date IFR request form. Old polices have been removed, pending insertion of new and up to date policies. Wandsworth CCG policy for IVF has been approved and inserted in this document. Best Practice for the Management of Lymphoedema Guidelines 2006 has been inserted, including referral criteria and staging of lymphoedema. List of procedures inserted that previously were commissioned by SWL ECI and now managed and commissioned by NHS England. Dates changed to current dates for document. Chart depicting approval from each CCG for document sign off. This sheet was in need of updating by each CCG. This is currently being developed by each CCG and will be replaced once completed for each procedure. Prior Approval chart for Croydon CCG has been amended to include the CReSS arrangements in order to provide a clear indication of how requests are processed. Up to date IFR request form has been included. Significant changes made to the application form and to opportunity for applicants to provide essential information through a clear tick box format. Entire application form has been reformatted in order to be more user friendly. Each CCG is developing new IVF/Assisted conception policies. These will be inserted once the CSU have received them and they have been signed off for approval. Wandsworth CCG criteria for IVF has been inserted to this document. Richmond, Kingston and Merton policies have all been received. They will be included pending official sign off. This is ongoing. Inserted for clarification of information. Inserted for clarification of information. Up to date Governance page including up to date chart for the eventual approval from each CCG with regards to the criteria.
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