Jo’s Cervical Cancer Trust response to the consultation on the CEMIPP Report

 Jo’s Cervical Cancer Trust response to the Department of Health and Social Care’s consultation on the Cost-Effectiveness Methodology for Vaccination Programmes and Procurement (CEMIPP) Report.

The HPV vaccination prevents 70% of cervical cancers from developing and recent data has shown it has resulted in a significant reduction in prevalence of high-risk HPV among young, vaccinated women[1]. This will have an extremely positive impact on diagnoses and deaths, with our recent modelling work showing that by 2040 diagnoses will fall from 412 a year to just 104 in 25-29 year olds and deaths almost eliminated, falling from 27 to just six[2]. The HPV vaccination will help us to eradicate cervical cancer.

HPV and HPV-related cancers do not discriminate between genders and we believe the vaccination should not either. Prevention is far better than treatment and we hope to see the Joint Committee on Vaccination and Immunisation soon recommend a gender neutral vaccination.

We support the recommendation to lower the discount rate for health impacts from 3.5% to 1.5% per year. Vaccinations prevent diseases, many of which bring life-long consequences to those affected. 63% of women who are living beyond cervical cancer have experienced at least three and 24% at least six physical long term consequences of their cervical cancer treatment[3]. By increasing the value given to future health impacts, it is more likely that vaccines, and the extension of existing programmes, would be seen as more cost-effective. This includes extending the HPV vaccination to boys.

We are cautious regarding the recommendation that a ‘cap’ should be placed when assessing long term benefits. As stated above, it is crucial that the long term impacts of vaccination are included in any cost-effectiveness assessment, however it is also important that predictions are made using reliable modelling.

We have explicit concerns over some of the recommendations and do not think the recommendations should be taken together as a package as suggested by the Appraisal Alignment Working Group in their interpretation of the report. This would only make it harder for vaccines to be found cost-effective.

We believe lowering the cost-effectiveness threshold from £20,000 per quality-adjusted life year (QALY) to £15,000 could have a negative impact on vaccination. Prevention is far preferable to treatment, therefore we believe the threshold for vaccinations should not be lower than for other medicines. Changes could disadvantage rarer cancers or diseases and pose barriers to implementing a gender neutral vaccination programme, which will result in many preventable deaths.

Making it harder for medicines and vaccinations to demonstrate cost-effectiveness will result in patients not getting access to drugs that could improve or even save their life. It is important that manufacturers are engaged to ensure patients are not disadvantaged by any changes to appraisals.

Jo’s Cervical Cancer Trust is the UK’s only dedicated charity for women affected by cervical cancer and cervical abnormalities. Our vision is a future where cervical cancer is a thing of the past.