PrescQIPP's Pharmaceutical Industry Scheme Governance Review Board
The Pharmaceutical Industry Scheme Governance Review Board has been created by PrescQIPP in response to requests by commissioners to provide guidance as to the acceptability of Primary Care Rebate Schemes being offered to the NHS by the pharmaceutical industry. These rebate schemes are predominantly offered by medicines manufacturers as a way of reducing the effective price of a medicine to a commissioner without affecting the list price. Companies may be reluctant to change the list price which is used as a reference for medicines pricing in other countries.
The assessment process is described in detail below but is designed to identify potential issues that commissioners may wish to consider when deciding whether to use any of these schemes. The assessment is split into three sections as follows.
1. Clinical. The board is not a substitute for a commissioner formulary committee who would be much better placed to make a clinical judgement on the suitability of any product for their formulary. Occasionally a rebate scheme is offered to reinvigorate a product which is not attractive to the NHS clinically. The purpose of this section is to try and identify these products. It may be that a commissioner would take up a good scheme for a medicine which is not clinically attractive but is still used simply to reduce the spend on that medicine.
2. Contractual. The board scrutinise the scheme for complexity, ease of administration, length vs. market uncertainties etc. Any problems are identified and commented upon.
3. Financial. The realisability, and size of any payback are considered.
All assessments are placed on the PrescQIPP website and are available to members. Requests are welcomed for additional schemes that need assessing. Any comments about assessments should be directed to Kirsty Shadbolt (Project Manager), Liam Cahill (Project Lead) or Kevan Wind (Chair).
What This Means for CommissionersIn FY12/13 this 'service' was a pilot for the East of England, however with increasing activity, and interest from commissioners this is something that is available to PrescQIPP subscribers.
Whilst the Review Board neither promotes nor actively supports Rebates, the outcome of the Review Board's assessments will be featured on this page for commissioners to consider. The Review Board's role in the governance process will be to comprehensively assess these schemes, outlining issues, and inappropriate Schemes.
Whilst our processes are comprehensive, we thoroughly recommend that commissioners work with local committees to assess whether they are comfortable with the scheme. With conflicting information from DH, ABPI etc. around the existence, legality and appropriateness of rebates in primary care please note that commissioners sign up to such schemes at their own risk.
Primary Care Rebate Board Operating ModelIf you are a commissioner wanting to know more about our Primary Care Rebates Board, this is a great place to start. If you're a company looking to understand our process, or even submit a scheme this document is an essential read before getting in contact with us. You can download it here:
Primary Care Rebate Board Standard TermsThe PrescQIPP Standard Terms of Agreement for Primary Care Rebate Schemes offers a standard contract that pharmaceutical companies may wish to utilise as a part of their submission to PrescQIPP’s Pharmaceutical Industry Scheme Governance Review Board (PISGRB). You can download the Standard Terms here:
Quick guide to rebates and FOI requestsA number of commissioners have been receiving FOI requests about activity and claims around primary care rebates. This guidance seeks to provide some information about what to expect from FOI requests in this area, and how you may wish to respond proactively or reactively.
Pharmaceutical Industry Rebates in UK - October 2017
On 30th October PrescQIPP hosted a webinar on primary care rebate scheme (PCRS) governance systems in the United Kingdom, covering the PrescQIPP Pharmaceutical Industry Scheme Governance Review Board. The session was chaired by Kevan Wind, and was a general educational session for stakeholders, including the pharmaceutical industry to help explain our assessment process. We look at the background, key system considerations, general principles, and the similarities and differences within the UK systems. We also gave examples of where schemes commonly fail.
Introductory video to the Governance Review Board
In the video for subscribers below, Liam introduces the purpose and process of the Governance Review Board.
Guidance on PISGRB Contractual Assessment
PrescQIPP's Pharmaceutical Industry Scheme Governance Review Board has published some further guidance around is contractual assessment process, to further support companies seeking to submit schemes. The guidance provides a breakdown of the twelve questions used to score contracts submitted, with supporting commentary for a number of key questions.
Primary Care Rebates Administration System
Supporting the socing and administration of schemes we have assessed and published.
Primary Care Rebates Administration System
PrescQIPP is the country's largest provider of NHS governance around Primary Care Rebates, and was amongst the very first. Whilst we neither support nor endorse the uptake or existence of Primary Care Rebate Schemes, but have long held the view that whilst activity occurs locally that good governance and transparency should exist. For more information on our Rebates work please visit the Primary Care Rebates Webkit.
To support this activity we have produced a Rebates Administration System to assist commissioners in monitoring the possible financial returns from any rebate scheme you may seek to sign up to. You will only get the benefits if you sign up to the scheme yourself. Every month we take the NHSBSA ISP full data download and apply the working of the scheme to the relevant data set. This gives a theoretical rebate amount so commissioners don't have to work it out themselves or solely rely on data from pharmaceutical companies.
Historically we had a range of Excel reports, but have now incorporated these into one all-singing-all-dancing system, linked below:
The traditional Excel reports will be available for the remainder of the 2016/17 financial year, and will then be retired.Rebates Monitoring System Downloads
Please find below, the outcomes (Clinical, Contractual & Financial), documents and details about the schemes processed by the 'Review Board'. You can also view all the documents in one place here.