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Alcohol Dependence and Harmful Alcohol Use: Consultation Tables with Developer's Responses

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Alcohol Dependence and Harmful Alcohol Use: Consultation Tables with Developer's Responses National Institute for Health and Clinical Excellence Alcohol dependence and harmful alcohol use Guideline Consultation Comments Table 24 June 2010 – 19 August 2010 No Typ Stakeholder Or Doc Sec. Page Comments Developer’s Response e der No No Please insert each new comment in a new row. Please respond to each comment No 236 SH Association for Family 21. All General General AFT welcomes the recognition of the role of close Thank you for your comment. Therapy and Systemic 01 relationships and addressed in this guideline for adults, Practice (AFT) children and adolescents who are dependent on alcohol or have harmful drinking, including the children of parents with alcohol problems. Systemic couple and family therapy training in the UK provides different levels of training for people to learn how to address complex relationship and issues associated with alcohol dependence and harmful use, by helping close relatives / support networks to build on their strengths, provide support, and find ways to change the problems so that they understand the needs of partners, parents and their children and begin to find ways to deal with these. Information can be found on the AFT website: Training framework for family and relationship focused practice'. The site also provides access to Current Practice, Future Possibilities as well as Report on the evidence base of systemic family therapy: www.aft.org.uk . 520 SH Public Health Wales 1.0 All General General This organisation responded with no comments to make. Thank you. NHS Trust 1 539 SH RCP & BSG 35. All General general Emphasis. The emphasis is on diagnosis and management Thank you. The guideline describes 02 in the community and specialist settings. There is little diagnosis and management in all NHS mention of detection in Accident & Emergency Departments, provided and/or funded services, or in District General Hospitals, where the majority of including acute hospital settings. Acute alcohol-related admissions are non-elective. The evidence- hospitals are mentioned at several points base for the value of an alcohol specialist worker or alcohol throughout the guideline. However, the specialist nurse in detecting harmful and dependent alcohol role of screening in A&E departments and misuse should be included. The first mention of screening acute hospitals is covered by the with the Paddington Alcohol Test is in Appendix D on page published NICE public health guideline PLEASE NOTE: Comments received in the course of consultations carried out by the Institute are published in the interests of openness and transparency, and to promote understanding of how recommendations are developed. The comments are published as a record of the submissions that the Institute has received, and are not endorsed by the Institute, its officers or advisory committees. 1 of 136 43 (NICE/short). There is little mention of alcohol-related (NICE, 2010a). Nevertheless we agree liver disease. that the role of specialist alcohol liaison staff in acute hospitals, in relation to diagnosis and management, should be highlighted. The precise configuration and organisation of these services will be more directly and appropriately addressed in the specific commissioning guidance for alcohol which NICE is currently developing. 540 SH RCP & BSG 35. All General general Lack of Psychiatry input into District General Hospitals. Thank you. We agree that the role of 03 The main problem in this whole area is that there is a major liaison and addiction psychiatry in A&E shortage of liaison and addiction psychiatry input into and acute care and the need for Accident & Emergency Departments and District General collaborative care between psychiatrists Hospitals. The fundamental need is for liaison and and physicians should be highlighted, as addiction psychiatrists, specialising in alcohol, with specific in our previous comment, we think this responsibility for screening for depression and other will be best dealt with in the specific psychiatric disorders, especially suicidal ideation, to provide commissioning guidance for alcohol an integrated acute hospital service. Moreover, which NICE is currently developing. psychiatrists and gastroenterologists, hepatologists and other specialists need to work collaboratively, rather than in isolation. 541 SH RCP & BSG 35. All General general Staff competency. There are a number of references that Thank you. However, the 04 ―staff should be competent to assess and manage patients‖. recommendation of specific systems for Examples are sections 1.2.1.6 on page 13, 1.3.1.5 on page competency appraisal is outside the 16 and 1.3.3.2 on page 18 (NICE/Short). The scope of the guideline. These are for the recommendations fall short of initiating any competency relevant training and regulatory bodies to assessment processes. The recommendations are not develop. specific enough. There should be national, standardised, competency qualifications. Current frameworks, such as DANOS, are not relevant to the acute hospital setting, including alcohol specialist nurses and ward staff. If standardised care is to be achieved, there has to be a national competency framework in situ, which will also support the grading and banding of staff. 542 SH RCP & BSG 35. All General general Service Delivery. Should there be national standards? If Thank you for your comment. We agree 05 not, and given GP local needs assessment commissioning, national standards would be helpful. this will inevitably lead to inequitable care. Only 1 in 18 NICE is developing national quality dependent drinkers receive care, the figures ranging from 1 standards for alcohol dependence as a PLEASE NOTE: Comments received in the course of consultations carried out by the Institute are published in the interests of openness and transparency, and to promote understanding of how recommendations are developed. The comments are published as a record of the submissions that the Institute has received, and are not endorsed by the Institute, its officers or advisory committees. 2 of 136 in 12 in London to 1 in 27 in the North West of England and separate exercise from this guideline. 1 in 102 in the North East. These quality standards are due for publication in 2011 and should be helpful in supporting implementation of these clinical guidelines. 543 SH RCP & BSG 35. All General general Pharmacological Interventions. eg Section 7 page Thank you for your comment. We agree 06 338(Full). Many GPs regard these as specialised drugs, that implementation of pharmacotherapy which should only be prescribed and initiated by alcohol for alcohol use disorders is currently sub- specialists. Who will carry the budget for this? Community optimal, which is why we have highlighted alcohol teams have no proper drug budget. There would their efficacy in this guideline. The limited need to be local agreement. implementation is partly due to lack of historical budgets for pharmacotherapy in specialist alcohol services, but also due to lack of awareness of their effectiveness. Our hope is that this guideline will improve availability and uptake of pharmacotherapies. It is not in our scope to make specific recommendations about NHS budgets. 538 SH RCP & BSG12 35. All General General We are grateful for the opportunity to comment. Overall, we Thank you. NICE is currently developing 01 believe this to be very good, definitive and exhaustive specific commissioning guidance for guidance. The recommendations will need to be considered alcohol which will deal with the matter you in the light of the new Government White Paper, with its raise. emphasis on GP commissioning. This will be particularly relevant regarding service and drug budgets. 549 SH Royal College of 37. All General General It would be helpful if more explicit reference could be made Thank you for your comment. We have Midwives 01 throughout the document to the other NICE guidance on frequently referenced the other two alcohol-related problems. alcohol guidelines throughout this guideline. 564 SH Royal College of 42. All General General It is very positive to see some guidance for alcohol Thank you for your comment. Nursing 06 treatment, that is mainly clear, easy to read and also relatively easy to implement across all services. 657 SH The Children‘s Society 14. All General General We welcome the references in this guidance to the impact of Thank you for your comment. 01 a person‘s harmful drinking on their family and in particular on children. We would like to acknowledge this as a significant contribution towards improved outcomes for 1 Royal College of Physicians & British Society for Gastroenterology 2 The British Association of the Liver (BASL) were also named on this response, but were not a registered stakeholder when the consultation closed. PLEASE NOTE: Comments received in the course of consultations carried out by the Institute are published in the interests of openness and transparency, and to promote understanding of how recommendations are developed. The comments are published as a record of the submissions that the Institute has received, and are not endorsed by the Institute, its officers or advisory committees. 3 of 136 children affected by parental alcohol misuse. 662 SH Turning Point 30. All General General Turning Point broadly supports these guidelines and we are Thank you for your comment. 01 satisfied that this document is well informed by a deep breadth of academic research that fully accounts for the wide ranging effects and reasons for alcohol dependence and harmful use. 663 SH Turning Point 30. All General General In particular we support the document‘s notion that Thank you for your comment. 02 treatment should be accessible and suitable treatment should be provided to everyone who needs it through investment in more and better quality services. We would add that at the same time, there should be targets to reduce waiting times and improve the efficiency of services by considering how to integrate them. One implication of improving the right to immediate and accessible treatment is that both acute trusts and rehab organisations will become overburdened with demand and they must therefore in turn be enabled with better capacity.
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