The Death Knell of the Pharmaceutical Ad Board?
Understanding how industry can engage with CCG commissioners within the new rules suggested by NHSE on managing conflicts of interest.
June 2016 saw the release of the updated statutory guidance "Managing conflicts of interest : Revised guidance for CCG's" and came after widespread adverse publicity questioned whether CCG commissioners should be paid for participating in advisory boards run on behalf of pharmaceutical companies.
Before I go into depth about the new guidance I think it is important to look at the true "value" of pharmaceutical / medical device / medical diagnostic company interactions with CCG commissioners.
As medical marketing professionals we all know how important that first element is when we start to fill in our strategic / brand planning template. An accurate environmental analysis determining the NHS landscape in which we are promoting our goods and services into is vital to the success of our planning. The NHS is cash strapped, constant budget cuts are the norm and commissioning structures are constantly evolving. You might have market access teams on the ground, but to succeed you need to be looking at the macro level and predicting the impact that national changes will have on your overall strategy and then adapt your tactical implementation accordingly.
In the 21st century the patient pathway is king regardless of the disease area. The products and services exceeding growth expectations are sold by companies who understand the clinical pathway, can negotiate the shifting sands of the payor pathway and who listen to their stakeholders. By completing this picture they produce targeted messages, delivered in appropriate media that demonstrate the true "value" of their intervention.
Take, for example, a new device for use in the Emergency Department setting that it is "proven" to establish a diagnosis in half the time that would be achieved by existing technology. Well that's amazing isn't it? Surely saving time on diagnosing the patient is a no-brainer, strong messaging to the ED staff is bound get this product trialled and used? We don't need to know anymore. WRONG !
It may appear on the surface that TIME is a pressure to the ED consultants, but we need to scratch below the surface to reveal whether that extra TIME actually gives them anything meaningful and what is the true value of the intervention in the patient pathway? If diagnosis is quicker and more reliable does this mean that treatment can be started quicker? Does this test mean that patients can now be treated within the 4 hour wait window or are they already achieving this with existing technology? What does this mean for primary care commissioning? Is this going to mean achieving admission avoidance strategies? What is the value and practicalities of using this test in the primary or intermediary care setting? What healthcare professional resource is going to be required to adopt the new technology? What is the process for changing the pathway and who are the stakeholders? Which targeted patient profile would be the focus of a real world study to show the local health economy benefit?
For this technology even to be considered it is vital to gather this information from the multidisciplinary stakeholders across the clinical and payor landscape. If we don't, or cant, engage with these people then the most we can hope for is limited success, we simply wont see any of the barriers until it is too late.
SO the question goes back to how can you engage with commissioners and payors within a background of transparency and amongst regulations that are fostering concern about close industry relationships.
NHSE has published a revision of the 2103 guidance around Managing Conflicts of Interest with the following key recommendations:
Each CCG should appoints a guardian to ensure compliance with transparency guidance
Four new medicines optimisation committees will be established to take the onus away from local commissioners
Any interaction with organisations need to be totally transparent and recorded.
A requirement for CCGs to include an annual audit of conflicts of interest management within their internal audit plans
This does NOT mean that industry and payors cannot connect and provide mutually beneficial feedback, it just needs to be done in the RIGHT way with the RIGHT regulation and with the RIGHT partners.
Insight is our lifeblood, so here at Lancaster Hammond we are keeping right at the edge of these changes and would be happy to come and talk to any industry colleagues about the implications of these changes to your brand. We are experts in mapping patient pathways across multiple disease areas and can offer you a bespoke package according to your needs from specific qualitative and quantitative market research to focus groups and advisory boards (yes these are still possible and very valuable).
Drop us a line if we can help ensure that your brand is the one that is overachieving target in 2017.
Debbie Lancaster and Julian Hammond
June 2016 Revised Guidance