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New criteria for approving NHS vaccines could cut access

Recommendations would make it harder for people to access vaccines on the NHS in future

Louise Prime

Thursday, 01 March 2018

Proposed changes to how the cost-effectiveness of vaccines is assessed in England could make it less likely for vaccines to be deemed cost-effective and approved at current prices, experts have warned – and the Association of the British Pharmaceutical Industry has expressed its ‘significant concern’ that the recommendations would make it harder for people to access vaccines on the NHS in the future.

In 2014, after considering whether or not meningococcal disease group B vaccination should be introduced for children, the Joint Committee on Vaccination and Immunisation (JCVI) asked for a review of the methodology it used to appraise vaccination programmes, to see whether or not the rules for determining the cost-effectiveness of new or existing programmes should differ from those used for appraising other health-related activities that use public resources.

So, the then Department of Health (DH) set up the independent Cost-Effectiveness Methodology for Immunisation Programmes and Procurement (CEMIPP) group to consider whether the method for appraising cost-effectiveness of vaccination programmes should change; CEMIPP sent its report* to the DH in July 2016. The Department asked the Appraisal Alignment Working Group (AAWG) to make an analytical assessment of the report, especially given its potential implications for health appraisals beyond immunisation. This was received at the end of January 2018, and the Department for Health and Social Care (DHSC) has this week published the conclusions from both reports and opened a 12-week consultation.

CEMIPP noted that its 27 recommendations, depending on how they are interpreted and which are implemented, could have an impact on which vaccination programmes are funded in future – and also have potential relevance beyond vaccination programmes to the funding of interventions in the wider health system. The recommendations include, for example:

  • Lowering the cost-effectiveness threshold from £20,000 per quality-adjusted life year (QALY) to £15,000 per QALY; AAWG noted in its analysis: “Everything else being equal, a lower cost-effectiveness threshold for immunisation would imply a stricter hurdle for new vaccines to be found cost-effective compared to existing methodology.”
  • Lowering the discount rate for health impacts from 3.5% per year to 1.5% per year, implying that greater weight is given to costs and benefits further into the future; AAWG noted: “A lower discount rate implies that greater weight is given to costs and benefits further into the future.”
  • And an indefinite time horizon of analysis (i.e. the time period over which impacts of a vaccine are considered).
The AAWG commented that the recommendations in the CEMIPP report, “Would make it less likely for vaccines to be deemed cost-effective and approved at current prices”. And the industry body, the ABPI, which said it welcomes the commitment to a public consultation on the report’s recommendations of the report, has already said, “[It] expresses significant concern that recommendations set out in the consultation would impact negatively on the health of the nation by making it harder for people to access vaccines on the NHS in the future.”

ABPI value & access director Dr Paul Catchpole warned: “The UK currently has a world-leading immunisation programme so it is profoundly concerning that proposals to introduce stricter hurdles for one of the most effective public health interventions available to us are even being considered.”

*Review of Cost-Effectiveness, Methodology for Immunisation, Programmes & Procurements. A report prepared by the Department of Health, July 2016.

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