It’s important that our members take the opportunity to respond to the ongoing consultation on NICE’s Depression Guidelines, which closes at 5pm on 12 September 2017.
Who can respond?
Anyone can respond to the consultation, however NICE will only acknowledge responses from stakeholders registered for the specific guideline. Registration is only open to organisations, not individuals.
If you’re not registered as a stakeholder, your comments will still be seen and reviewed by the Guideline Development Committee, but they won’t respond to your comments or publish them on the NICE website.
You can also contribute to a response being submitted by a registered stakeholder organisation.
How to register as a stakeholder
You can find out if you are eligible and register as a stakeholder on the NICE website. The process is quick and free of charge.
How to respond to the consultation
NICE consultations follow a very structured process. With the draft guideline, NICE will publish a series of questions to guide your responses and set out the scope of information they will accept. Please read through this information to ensure your response is as effective as possible.
NICE will only accept:
- one set of comments from each registered stakeholder organisation
- responses submitted on the pro-forma available from the consultation web page
NICE will not accept:
- responses that include attachments such as research articles, letters and leaflets
- any responses submitted after the consultation deadline on 12 September 2017
What happens after the consultation?
At the end of the consultation period, the Guideline Development Committee will discuss the responses received and decide whether any changes are needed to the guideline. They will respond to all comments submitted by registered stakeholders, and to any comments from people who have not registered but which result in a change to the guideline.
All registered stakeholders who comment on the draft guideline will be sent a confidential copy of the final guideline two weeks before publication. All the comments and responses will be published on the NICE website once the final guideline is published.
Alternatively, if you'd like to send your comments to us, to be considered as part of our organisational response, send them to firstname.lastname@example.org.
NICE campaign messages
This is a summary of the key issues and concerns we have identified within NICE’s updated Depression in adults: recognition and management guidelines.
No compelling evidence exists to support an argument for the superiority of Cognitive Behavioural Therapy (CBT) over counselling for treatment of depression. Research indicates that counselling delivers comparable patient outcomes to CBT. The most recent reported annual datasets from IAPT - data from actual patients treated in the NHS - show marginally better outcome rates for counselling than for CBT, delivered in fewer sessions.
Counselling can save £30 million for the NHS
Had the 152,452 IAPT clients in 2015 to 2016 completed a course of counselling instead of CBT, the savings could have been £30 million to the public purse. Counselling is a more cost effective intervention than Cognitive Behavioural Therapy (CBT). IAPT data shows that patients receive fewer sessions of counselling compared with CBT and so it is estimated that counselling is delivered at around £1,044 per client with CBT costing approximately £1,256 per client.
NHS data supports the case for counselling
NICE’s approach to what constitutes evidence prioritises evidence from randomised control trials (RCTs) which have weaknesses as well as strengths. This over-reliance on RCTs is despite the existence of probably the largest collection of outcome data on adults with depression in the world, through IAPT. But because it is not derived from a RCT design, this ‘practice-based’ data is not currently considered in NICE guideline developments. It's inconceivable that such data, collected at the public’s expense, should not influence the guidance that impacts on that service’s delivery.
NICE need to more clearly define counselling
There is a fundamental problem in comparing the effectiveness of counselling with other interventions. Counselling is an umbrella term for a range of talking therapies and so any analysis that this based on comparing the term counselling with sub-types of counselling is unhelpful at best - and at worst flawed.
Overwhelming public support for NHS counselling
A June 2017 survey conducted by Populus of 2,000 adults in Great Britain and Northern Ireland showed beyond any doubt that the public want and expect counselling to be available on the NHS for people suffering depression. In the survey, 98% agreed counselling should be available on the NHS, with 86% expecting counselling to be available.
Public support counselling and choice
The same survey showed that the public believe there should be a range of therapies available on the NHS. When asked, 98% of those who expressed a preference agreed that the NHS should offer a range of psychological therapies for adults who are suffering with depression. Choice is important in a modern NHS and research shows that patients who receive their therapy of choice have better outcomes.
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