Submission to North East Essex Consultation on IVF Services
June 2015
We are supported by the following organisations:
Dear Sir/Madam,
We are writing to you as the Co-Chairs of the Fertility Fairness campaign, to respond to North East Essex CCG’s consultation on the commissioning of specialist fertility services. Fertility Fairness is an umbrella body, which has the support of a number of organisations working in the field of infertility from professional bodies to patient support groups.
North East Essex CCG has proposed introducing severe service restrictions on access to IVF treatment for all but a very smallgroup of patients, which amount to an essential decommissioning of the service. Fertility Fairness strongly opposes this decision, and we recommend that you do not continue with this policy change.
Infertility is a disease as recognised by the World Health Organisation and, as with any other medical condition it is deserving of treatment.Simon Stevens, Chief Executive of NHS England, has recently publically argued against the rationing of NHS treatment, stating that ultimately the basis on which people get care on the NHS should be their ability to benefit from treatment.[1]
Restricting access to IVF treatment completely would mark a drastic departure from the NICE guidelines, and would be wholly inadequate as far as patient and national policymaker expectations are concerned. Fertility Fairness is aware from other public consultations within the region that there is a high degree of local support for the commissioning of specialist fertility services, and we would expect that the population within the North East Essex CCG would share these views.
Furthermore, the restriction of fertility services raises serious questions of equality since other CCGs continue to offer wider access to specialist fertility services. Apart from the Mid Essex CCG, every other CCG in England now commissions at least one cycle of IVF. As such if North East Essex approves this policy change they will be one of only two non-funders of IVF, in the country. This would also exacerbate the widening of a postcode lottery in a region that, up until recently, was considered the best in the country.
Fertility Fairness also considers that the consultation document that North East Essex CCG has produced is flawed:
HIV and Hepatitis C Patients
The CCG has proposed restricting access to IVF, except where the “male partner has a chronic viral infection”,such as HIV of Hepatitis C. Fertility Fairness was confused to see this policy exception when NICE has clearly stated that HIV positive men and hepatitis patients who are receiving treatment have a minimal risk of transmission, and would not normally receive IVF.[2]
It is perverseto see the CCG restricting access to patients experiencing infertility, who do need the specialist fertility services, and instead offering treatment to patients who may well not require any IVF at all.
Evidence Used
TheCCG’s consultation document states that IVF provisionis being restricted because “it does not provide sufficient benefit to the overall health economy”. Fertility Fairness strongly disputes this assessment as NICE – the expert body – has determined 3 full cycles of IVF to be a clinical and cost effective treatment. Fertility Fairness would appreciate it if the CCG would provide more information on how this assessment was reached.
Fertility Fairness was also concerned to see CCG justify this restriction in their recent board meeting by reference to the fact that “many of the CCGs across Essex and the Midlands and East region have already taken steps to heavily restrict and rationalise some of the services that we are considering”.[3]Rather than adopt strategies of underperforming CCGs we would suggest that North East Essex CCG look to more positive examples. For instance in the North East of England a collaborative commissioning policy has enabled 13 CCGs to offer 3 full cycles of IVF. The main consideration of any CCG in commissioning decisions should be the advice of NICE, contained in the Quality Standard and Guideline on fertility.
Consultation Methods
Fertility Fairness was also concernedbythe manner in which theCCG presented their case for the reduction of IVF services. Guidance from NHS England suggests that CCGs should seek to provide communities with ‘balanced and objective information’ when consulting the general public.
However, the North East Essex CCG’s consultation document states that IVF in 2013/2014 cost roughly £386k, and compares this to the cost of 25 drug treatment courses for breast cancer or 108 patients being admitted to an acute stroke unit.
Fertility Fairness does not consider that this is a balanced or objective way to present the evidence, as it is positioning IVF as a direct competitor to life-threatening conditions. This presentation suggests that patients are at risk of death if fertility services are not cut. In reality the NHS funds a plethora of treatments that improve our wellbeing and are non-fatal, and Fertility Fairness would be interested to know if the CCG has ever presented the evidence in this manner before when consulting on restricting other NHS funded services and the rationale for choosing these particular examples.
In light of the above points, Fertility Fairness ask that the North East Essex CCG review its proposals to decommission IVF services. We would be very glad of the opportunity to discuss this with you further and look forward to hearing from you.
Yours sincerely,
Susan Seenan and Sarah Norcross
Co-Chairs of Fertility Fairness
Fertility Fairness (FF) campaigns for equal access for those with an established clinical need to a full range of services for the investigation and treatment of infertility on the NHS - It is funded through equal grants from Ferring Pharmaceuticals Ltd and Merck Serono Pharmaceuticals Ltd - Its activities are directed by the FF Committee, on which non-commercial interests enjoy a significant majority - For further information, please visit:
Or write to Fertility Fairness (Decideum Ltd), NIddry Lodge, 51 Holland St, London W8 7JB - For patient information please call Infertility Network UK 0800 008 7464 - Email:
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