A “ridiculously short” timeframe for consultation on plans for the future design of specialised services including rare cancers and neurosurgery has left insufficient time for meaningful patient engagement, patient groups have claimed.
A consultation launched on 12 December by the NHS Commissioning Board allows just six weeks for interested parties to respond to detailed specifications for more than 130 different disease areas.
The timetable is driven by the need to have the specifications in place in time for the commissioning board to start commissioning the services in April 2013.
However, many organisations have raised concerns about the consultation process and a lack of patient engagement in developing the specifications.
Macmillan Cancer Support head of policy Duleep Allirajah said the board had “effectively created no opportunity for meaningful engagement”.
He added: “The timeframe for this consultation is ridiculously short. The scope of change being recommended is massive and the proposals will require in-depth scrutiny to fully understand them.”
National Voices director of policy Don Redding said the short time frame and “terrible timing” of holding the consultation over the Christmas break “exposed the fact that the commissioning board doesn’t yet have a code of practice for consultation”.
The government would have been obliged to follow Cabinet Office code of conduct on consultation. The latest version says consultations can vary between two and 12 weeks but should reflect the complexity of what is being consulted on and the capacity of the interested parties to respond.
Sally Brearley, chair of the specialised services public and patient engagement steering group, told HSJ that although the move to commission these services nationally was welcomed there was concern amongst members that this did not set a precedent for consultation by the commissioning board.
Specialised commissioning is currently carried out by on a regional basis by 10 specialised commissioning groups and the type and quality of services commissioned varies between areas. Under the Health Act 2012 specialised commissioning will be handled by the commissioning board in line with nationally agreed specifications. This has been met with approval from most parties in the hope that it will reduce variation.
Alastair Kent, director of Genetic Alliance UK, told HSJ members would have liked longer to scrutinise the plans but accepted the timetable was set out by the act.
The board claims patients were involved with the development of the service specifications as members of clinical reference groups.
More than 60 CRGs were involved in drawing up the service specifications. The voluntary groups were made up of clinicians with expertise in the area and two patients who were invited to take part. However, patients were not allowed to represent the views of any charities or groups they may have been involved with and there are reports that many found it hard to get their voice heard in groups dominated by clinicians.
John Murray, director of the Specialised Healthcare Alliance, said patient groups recognised the need for pace but were concerned that service specifications agreed in haste were going to be “set in stone”.
Mr Murray added: “PPE representation has been very limited and it’s not necessarily realistic to expect those individuals [involved in CRGs] to have shared what was happening. This is the first opportunity for a broader constituency to see what’s being proposed and whether these plans are well founded.”
A spokeswoman for the commissioning board said the board was “committed” to involving patients, carers and the public in decisions about patient care.
She said clinical reference groups would retain patient representation “ensuring that patients are right at the centre of the planning and commissioning of specialised services.”