This was the response letter to NICE:
Dear Heather,
Thanks for the implementation document draft. I have consulted with the S4ME committee and would like to convey the following comments:
Much of the implementation statement looks appropriate and we would support. Several issues came to our notice.
1. The section on Educational materials is likely to be contentious and we feel it could be significantly improved. Our suggestions are given in more detail below.
2. The document currently does not convey any sense of urgency for implementation and it is of significant concern that services may not properly implement the guideline for some time without impetus to make changes as soon as possible. This could be addressed to some extent with inclusion of target dates for implementation, a recommendation that local systems publish their own implementation timelines in consultation with commissioners, and with recommendations to consider funding allocations to fast-track implementation, training, and service changes and development, notably given the urgent need to address the historical dearth of adequate or safe care provided for this patient group.
It should be made clear that 'do not offer' recommendations should be implemented without delay (paragraph 4 of p.1 could lead to confusion in this regard). I.e., GET (for example) should no longer be offered, with immediate effect. Clarity could be provided as to how research recommendations will be implemented and whether any of the GRIP member organisations will liaise with NIHR on this.
3. The Lightning Process is misspelt and was not previously recommended so it would be best just to say not recommended.
4. It may be constructive to refer to the list of expertise a specialist team should cover, which is set out at guideline recommendation 1.10.1, and to remind that the guideline did not specify the professions that should make up a specialist team. This may aid providers and commissioners in working towards ME/CFS specialist teams comprised of professionals with a broader and more appropriate skillset, such as specialist nurses.
In developing specialist teams providers should bear in mind that home visiting provision for those severely and very severely affected needs to include medical clinicians who can assess needs for medical treatment, such as specialist nurses, GP's and consultants, not just therapists with more limited skills for whom performing such assessments would mean exceeding the bounds of their professional remit.
5. Under provision of services it would be good to mention aids and adaptions in the context of OT specifically. The mention of access to dietitians with a special interest in ME/CFS is supported by the guideline but may currently be unrealistic due to scarcity. People with severe and very severe ME/CFS will have greater access requirements, (e.g., home visits) so it could be noted this should be factored into funding and capacity considerations.
6. The document could include a paragraph recommending that providers and appropriate organisations update and review their information and literature, including online materials, to ensure that these are guideline compliant, which is to say consistent with the guideline, accurate in representing its content and not misleading in any regard.
Education considerations and resources
In relation to Educational Resources, our view is that it needs to be transparent that we have a current problem with a lack of consensus over appropriate materials. A number of patient support and advocacy groups (including Doctors with ME which is not in any usual sense a recognised professional organisation) have produced materials consistent with the new guideline. Some of the material from these groups is not ideal and we think it best not to highlight anything specifically. The professional organisation for therapists involved in ME/CFS care is BACME. BACME has attempted to redraft its materials in line with the new guidance but some of the background material is not well evidence-based and we do not feel it should be highlighted. Medical Colleges should be updating materials but in view of the way they have dragged their feet in accepting the new guidance this remains an unknown quantity.
What is needed is for patient support groups and all professional groups to get together to provide a consensus on what educational materials should look like. For other conditions this is usually unproblematic. Unfortunately, with ME/CFS, professional organisations seem to have difficulty in accepting the evidence base. In the present state of flux we suggest re-drafting the section on educational materials along the following lines:
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Education considerations
The medical schools and royal colleges write their curricula in line with the
GMC standards framework. All GMC registrants have a professional duty to remain up to date with the relevant areas within their scope of practice. A review of medical education with regard to ME/CFS
will be needed, to ensure undergraduate and post graduate doctors have
an up to date understanding of the diagnosis and management of the condition.
Education resources reflecting the guidance
Education resources on ME/CFS are currently undergoing rapid change and users should expect to see further changes in line with the guidance. There is an urgent need to develop a consensus between professional bodies and the main patient support organisations.
Forward-ME is a coordinating body representing 11 charities and voluntary organisations. A number of them are updating their existing resources and guides aimed at GPs and other healthcare professionals to reflect the updated guideline. Several individual patient support organisations have produced resources to support people with pacing and energy management including
Action for ME, the
ME Association, and the Wellcome Public Engagement Award Funded
Dialogues for ME/CFS. The recently formed
Doctors with M.E. has an
education page which attempts to collate compliant resources from UK and other global providers. In a
survey of users of the linked case based online
CPD module, 96.1% thought more education or training for medical professionals on ME/CFS is needed.
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Yours sincerely,
Jonathan Edwards