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Context
NICE is an executive non-departmental public body, sponsored by the Department of Health and Social Care. This body produces evidence-based guidance and advice, and plays a central role in developing quality standards and performance metrics for those providing and commissioning health, public health and social care services.
The draft guidance is for ‘traumatic injury’ defined as any injury requiring hospital admission at the time, including musculoskeletal trauma, spinal injury and limb loss. It expressly excludes complex rehabilitation needs resulting primarily from traumatic brain injury, whilst acknowledging that brain injury may be a secondary feature of other traumatic injury therefore requiring multi-disciplinary coordination of services.
The consultation is eligible for comment only by registered stakeholders, including professional bodies, NHS trusts and government departments. As such, individual stakeholders from the compensation sector are unable to directly contribute but are instead encouraged to do so via whichever national organisation best represents their interests, failing which to submit their informal comments via email. The deadline for responding is 17:00 on 8 September 2021, following which the guidelines will be published on 18 January 2022.
Clinical
The draft recommendations advise that the rehabilitation needs of an injured person should be assessed and discussed with the patient and their family at an early stage. Further, a person-centred and individualised approach should be taken throughout, with a named rehabilitation coordinator or key worker overseeing the injured person’s care while they are in hospital. Once discharged, a patient’s needs should be reassessed and the rehabilitation plan reviewed. The patient should be provided with a single point of contact at the hospital for information, help and advice for a limited time period and family members/carers should be actively involved in the transition to outpatient and community services.
As the consultation focuses on an NHS setting, this automatically overcomes one of the main criticisms by compensators of private case managers who in our experience, too-frequently prescribe rehabilitation packages which lack sufficient clinical governance. We strongly agree with the draft guidance that the rehabilitation coordinator should liaise with the multi-disciplinary therapy team when setting rehabilitation goals.
The draft guidance outlines how to develop a rehabilitation plan and how to monitor progress against the plan. In terms of the general principles for rehabilitation programmes, the guidelines assert that follow-ups, support and rehabilitation sessions could indeed be virtual. NICE states that there is qualitative evidence showing that “technology and telehealth can be suitable methods of improving flexibility and availability of specialist appointments”. We agree that healthtech provides wide opportunities for improving patient choice regarding rehabilitation delivery, including by providing them with alternatives to the traditional models of in-person therapy or care.
NICE recommends that patients should be advised of the availability of further help with funding for equipment, assistive technology, environmental adaptations and other forms of support with rehabilitation. This corroborates our own consumer research which found that one reason for the low take-up of healthtech is that health-related technology is still a nascent market and that part of the challenge is improving awareness of what technology is available and where it can be accessed.
In the hospital setting, we believe that organisational changes will be required to support clinicians with healthtech knowledge and integration, including in relation to procurement, staff training and awareness, product champions, after-sales support, ongoing competency checks, and user group meetings. In the community setting, therapists need to acquire IT skills and develop new protocols for the telehealth revolution, such as issuing guidance to patients regarding the initial logon, trouble-shooting any connection issues, and creating a suitable home environment for effective treatment.
A new healthcare infrastructure is required for clinical appraisal and certification of consumer-facing innovations, especially the multitude of health apps available for download via the usual online stores. The NHS is leading the way through its free-of-charge mytherappy information database which helps patients to find the right health apps for their injuries, all of which have been pre-screened and validated for digital safety and a sufficient clinical evidence base.
Claims
The consultation makes no express reference to mixed rehabilitation packages of NHS and privately-funded resources or compensation scenarios or of how they should interact. In our view, this represents a significant missed opportunity to evaluate how best to structure the common scenario of a private case manager liaising with statutory services, including how they should work with the appointed rehabilitation coordinator so as to avoid any clinical conflict or duplication.
If the guidelines are implemented as drafted then, at the very least, claims professionals should ensure that they seek disclosure of the rehabilitation plan and build relations with the nominated single point of contact, especially before the point of discharge in preparation for community interventions.
Conclusion
The publication of the guidelines is expected on 18 January 2022. Kennedys does not qualify as a stakeholder, but we will nonetheless provide our comments on the consultation, which NICE advises will still be considered although will not receive a formal response or be published on their website.
We would like NICE to acknowledge the overlapping role often played by compensators in rehabilitation following traumatic injury, even during the acute hospital phase, and to amend the draft guidelines to include contributions from a privately-funded case manager (and in some cases therapists) working alongside the NHS’s own multi-disciplinary team.
We strongly support the consultation’s exploration of healthtech innovations being integrated into a bespoke and patient-centred rehabilitation plan, because there can be a variety of indicators for technological solutions, including therapy accessibility where otherwise waiting times or geographical coverage might be a barrier, therapy monitoring and reinforcement between in-person sessions, or simply a personal preference.
The healthtech revolution will require an ongoing commitment to train and support through continuing professional development a new generation of healthcare technologists with the product knowledge and skills to help patients to use it effectively.
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United Kingdom