Following the merger of four organisations to create Black Country ICB, the consolidated commissioning organisation wanted to ensure there were harmonised clinical treatment policies in place across its new geographic footprint to ensure fair access to treatments and interventions.
Arden & GEM assigned a team to support the ICB which brought together clinicians with significant experience and knowledge in secondary care, policy implementation, and delivering IFR services. Over a two-year period, Arden & GEM has reviewed and compared 118 existing policies, drafted 38 new policies for ratification, and developed 18 Blueteq® templates for implementation.
The challenge
To ensure fair access to clinical treatments and interventions, it is essential that all NHS funding decisions are made in a robust, open and transparent manner. Clinical policies support commissioners in achieving this by considering the evidence, ratifying treatment options and ensuring consistency in eligibility across a health and care system.
Black Country CCG (now known as Black Country ICB) was formed in April 2021 following the merger of four Clinical Commissioning Groups in Dudley, Walsall, Wolverhampton and Sandwell. As part of the merger it was essential that the consolidated commissioning organisation had harmonised clinical treatment policies in place across its new geographic footprint.
To achieve harmonisation, and undertake any necessary policy development, the ICB needed clinical support from a team not just experienced in developing policies but also with expertise in the practical implementation of policies and Individual Funding Request (IFR)/prior approval process.
Our approach
By assigning clinicians with significant experience in secondary care, policy implementation and IFR services, Arden & GEM ensured the ICB’s support team was able to bring in both best practice and operational knowledge.
Understanding existing policies
The team’s first task was to understand the current position of the policies that were in place across the four places. This initial review identified and risk rated 118 clinical treatment policies across the four places:
- 17 policies were considered high risk due to significant difference between the policies within each place
- 55 policies with medium risk, where some harmonisation was needed which also required public and clinical engagement
- 46 policies were low risk as they were either already harmonised across all four places, or only one standalone policy was in existence.
This initial review gave a priority order for further policy work to be completed within, with the ICB’s in-house team focusing on the high risk policies. However, a significant amount of resource would be needed to review and implement the remaining medium and low risk policies.
Arden & GEM was asked to provide further support in the following areas.
Developing comparator tables
Comparator tables were developed for 57 policies to scope and compare existing classifications and criteria, both within the four places and against any policies which were part of the Evidence Based Interventions (EBI) list due for implementation in the same year. Recommendations were made with considerations clearly documented, including advice on whether they would increase or restrict access.
Drafting and ratifying new policies
Where new policies were needed, the Arden & GEM team worked closely with the ICB to agree timescales, deadlines and whether evidence reviews would be required from the public health team. Where evidence already existed, this was included along with any notes about how this might impact access.
In order for new policies to be reviewed and ratified, they needed to be considered by the Black Country Clinical Policy Development Group (CPDG) which comprised clinical leads, specialty leads and GPs. A policy schedule was agreed with the ICB project lead to ensure an appropriate number of draft policies were being taken to each Policy Board so ratification could take place as quickly as possible.
Navigating complex policy areas
For policy areas which were multi-faceted, guidance was provided to the ICB to bring the several existing policies into one harmonised policy. This would simplify the referral process for clinicians and demonstrate transparency across different criteria. For example, the harmonised cosmetic surgery policy included 22 different interventions, while the breast surgery policy included six different interventions across three areas, breast cancer patients, non-breast cancer patients and gender dysphoria patients.
Incorporating the views of public and patients
As part of the review process, Arden & GEM’s communications and engagement team undertook listening exercises with the public and patients. This ensured their views on any proposed changes to certain treatment policies, based on clinical evidence, were heard. This included making information available via websites, emails and face to face meetings, inviting feedback either in person or via an online questionnaire, and analysing responses.
Supporting implementation
Once a policy was ratified by the Black Country CPDG, it needed to be efficiently and effectively implemented across the ICS. To support this, Arden & GEM developed templates to be used by referrers, from both primary and secondary care, within the Blueteq® system. This work would often begin as final drafts were prepared so that the ICB’s IFR team could check, amend and publish these as quickly as possible. Having a consistent set of templates helps referrers in supplying the right information and confirming relevant funding criteria.
The outcomes
Over a two-year period, Arden & GEM has worked closely with Black Country ICB to deliver a programme of policy harmonisation and development support including:
- Undertaking a desktop review and risk rating of 118 clinical treatment policies
- Developing detailed comparator tables to scope and compare 57 policies across four places
- Drafting 38 new policies for ratification by the Black Country Clinical Policy Development Group
- Developing 18 Blueteq® templates based on the ratified criteria of the newly developed policies.
As a result, the ICB has been able to move forward at pace in this critical yet complex area of commissioning.
"It has been really helpful to be able to call on the CSU team for support as and when we needed. They have been flexible depending on where we were in the harmonisation process. We had regular catch ups to ensure everything was on track and that the work was being done as we required. Whatever we have asked of the team has been provided in a timely manner."
Hannah Peach, High Cost Drugs Pharmacist and Policy Lead at NHS Black Country ICB
You can find out more about our policy development and harmonisation support here.