The BPC along with many other partner organisations submitted a response to the NICE guidance for treatment of depression in adults. The methodological concerns we raised in our first response have still not been addressed in the revised version and so, along with our partners, we maintain that the guideline is not fit for purpose and if published will seriously impede the care of millions of people in the UK suffering from depression, potentially even causing clinical harm.
Under NICE’s own rules, a second consultation can occur exceptionally if “information or data that would significantly alter the guideline were omitted from the first draft, or evidence was misinterpreted in the first draft and the amended interpretation significantly alters the draft recommendations” . Both conditions have been met in this case. Stakeholders identified wide ranging and fundamental methodological flaws in the draft and offered recommendations for addressing these. In spite of acknowledging the serious omissions and misinterpretations through issuing a second consultation, these key issues have not been addressed in the new draft.
The quality assurance process in the stakeholder response document and in the overall process appear to fall short of acceptable scientific standards and lack scientific integrity. Our position, therefore, is that a full and proper revision of the guideline must take place allowing sufficient time for the guideline group to properly address the concerns listed in this statement. These issues relate both to the omission of large amounts of data as well as the potentially significant material impact on the recommendations that would arise from their inclusion. If these issues are not adequately addressed, the treatment recommendations cannot be relied on.
The draft guideline in its current form poses a serious threat to patient choice and will result in patients being offered a limited selection of treatments, which may not be the treatments that have the best chance of relieving their suffering (which in turn will contribute to poor cost effectiveness in the long term).
The partner organisation include: Association for Family Therapy and Systemic Practice, British Association for Counselling and Psychotherapy, British Psychoanalytic Council, British Psychological Society, British Psychotherapy Foundation, MIND, National Survivor User Network, Psychotherapy Foundation, Royal College of Psychiatrists, Society for Psychotherapy Research UK, South London and Maudsley NHS Foundation Trust, Tavistock and Portman NHS Foundation Trust, Tavistock Relationships, UK Council for Psychotherapy, University of Essex
Our full joint statement can be found here.