Topic details

Title of policy or policy statement

Systemic anti-cancer therapy (SACT) treatment break: Continuation of funding for SACT following a break in treatment.

Programme of care

Cancer.

Clinical reference group

Chemotherapy.

URN

n/a – generic policy.

1 Summary

This report summarises the feedback NHS England received from engagement during the development of this policy, and how this feedback has been considered.

There were six internal responses and three from stakeholders registered with the chemotherapy clinical reference croup (CRG).

The responses were generally supportive of the principle of the policy, but recommended improvements in clarity in some sections.

2 Background

The policy is a revision of the NHS England guidance on SACT treatment breaks which was suspended during the COVID-19 pandemic.

The policy will replace the process described in COVID-19 rapid guideline: delivery of systemic anti-cancer treatments, National Institute for Health and Care Excellence (NICE) guideline [NG161].

This policy proposition has been developed by a working party of the chemotherapy CRG, the cancer drug fund (CDF) lead pharmacist and the chemotherapy CRG lead commissioner to develop the updated policy document.

The policy has been sense checked by the Commercial Operations team, including the CDF team.

The policy will be reviewed by the specialised commissioning Senior Management team (SMT) prior to moving to publication.

3 Engagement

NHS England has a duty under Section 13Q of the NHS Act 2006 (as amended) to ‘make arrangements’ to involve the public in commissioning. Full guidance is available in the Statement of Arrangements and Guidance on Patient and Public Participation in Commissioning.

In addition, NHS England has a legal duty to promote equality under the Equality Act (2010) and reduce health inequalities under the Health and Social Care Act (2012).

The policy was sent for stakeholder testing for two weeks from 29 April 2022 to 13 May 2022. The comments have been discussed by the policy working group and following consideration, a decision made on any changes to the proposition may be recommended.

Respondents were asked the following questions:

• Do you support the proposition for the treatment break policy for use in systemic anti-cancer therapy (SACT) based on the information described within the policy and within the criteria set out in this document?
• Do you believe that there are any potential positive and/or negative impacts on patient care as a result of this policy? If so, please give details.
• Do you have any further comments on the proposition? If Yes, please describe below, in no more than 500 words, any further comments on the proposed changes to the document as part of this initial ‘sense check’.
• Please declare any conflict of interests relating to this document or service area.
• Do you support the Equality and Health Inequalities Impact Assessment?

A 13Q assessment has been completed following stakeholder testing.

The Programme of Care has decided that the proposition offers a clear and positive impact on patient treatment, by making the process of treatment breaks during SACT treatment clear and transparent without disrupting current care or limiting patient choice, and therefore further public consultation was not required.

This decision has been assured by the Patient Public Voice Advisory Group.

4 Engagement results

The draft policy was circulated with draft frequently asked questions (FAQ) which had been developed in conjunction with representatives from Bowel Cancer UK.

Responses were received from two clinicians, one as an individual and the other representing the British Thoracic Oncology Group.

The British Thoracic Oncology Group were broadly supportive of the policy and recommended the inclusion to the FAQ’s of ‘What happens if my cancer progresses during an unplanned treatment break?’.

The second clinician queried the need for the policy, stating there will always be clinical exceptions whereby treatment may be paused for good reason which may not be within the boundary of the policy.

The third response was from an individual who was in favour of the policy as being a pragmatic approach to a complex area.

Further feedback was sought from the chemotherapy CRG, CDF commercial team and the NHS England regional pharmacists.

All of the feedback from these sources was positive to the intent of the policy. However, feedback indicated aspects of the wording of the policy required revision to improve clarity, and to be more explicit regarding the management of exceptions. Examples include:

• Inconsistent use of terms used, ieSACT/medicines and immunotherapy. These have been amended throughout the document.
• The rationale and need for the policy have been made explicit as how the policy is intended to be used.
  • The FAQs which will support the policy has been amended to acknowledge exceptional clinical circumstances will not be detailed in the policy and clinicians should discuss these with the CDF cancer pharmacists.
• The application of the policy for people of all ages (infants, children, teenagers, young adults, and adults) has been strengthened.
• The wording regarding the use of Cetuximab and panitumumab has been amended to highlight the use of a planned intermittent treatment strategy involving cetuximab or panitumumab with cytotoxic medicines is not commissioned by NHS England.
• How clinicians can apply for consideration of intermittent treatment break strategies for other tumour sites, eg renal cancer were discussed.
  • The wording in the policy was improved to direct clinicians to the methodology to submit a policy proposal for consideration.

No comments were received from the children and young people’s CRG.

In line with the 13Q assessment it was deemed that further public consultation was not required.

5 How has feedback been considered?

Responses to engagement have been reviewed by the policy working group and the cancer PoC. The following themes were raised during engagement:

6 Has anything been changed in the policy proposition as a result of the stakeholder testing and consultation?

The following changes based on the engagement responses have been made to the policy:

• The whole of the policy has been reviewed to ensure consistent use of terminology and to improve clarity.
• The section relating to exceptions was reworded to ensure clinicians are aware of how the regional pharmacists will measure any requests for resumed funding following a treatment break, and how exceptions are managed under the policy.
• The FAQs were revised to include the recommended additional question on what happens if a person’s cancer progresses during an unplanned treatment break.

7 Following the consultation, are there any remaining concerns outstanding that have not been resolved in the final policy proposition?

No.