The PISGRB 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 published list price. Companies may be reluctant to change the list price which is used as a reference for medicines pricing in other countries and of course a rebated price is less likely to be known by their competitors.
The role of the PISGRB is only to provide an independent assessment of any particular scheme. PrescQIPP does not approve or reject schemes, neither do we act as a partner in the contract between the NHS and the company. Individual commissioners can accept or reject any scheme as they see fit. Our assessment is there simply to assist that process.
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 rebate schemes. The assessment is split into three sections as follows.
Clinical: The PISGRB clinical assessment 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 used extensively in their area simply to reduce the spend on that medicine.
Contractual: The PISGRB scrutinise the scheme for complexity, ease of administration, length vs. market uncertainties etc. Any problems are identified and commented upon.
The PISGRB has published some further guidance around the contractual assessment process, designed to further support companies seeking to submit schemes. The guidance provides a breakdown of the questions used to score contracts submitted, with supporting commentary for a number of key questions. You can download the guidance below:
Guidance on PISGRB Contractual Assessment.pdf
Financial: The realisability (how likely the scheme is to work for a commissioner), and size of any payback are considered.
All assessments are placed on the PrescQIPP website and are available to subscribers. Requests are welcomed for additional schemes that need assessing. Any comments about assessments should be directed to Kirsty Shadbolt (Project Manager) at firstname.lastname@example.org.