Your ref: DE00000705127
Dear Joanne Miles,
Thank you for your response of 12 June 2012.
I would be grateful for clarification on a number of statements and assertions you made in your response to me.
1. You say that “Although the total number of prescriptions listed in the Prescription Cost Analysis England 2001 report appear quite high, it is important to remember that these figures do not provide any information about the number of patients involved or how these medicines were used.”
These figures are important and therefore does the Department intend to quantify the number of patients involved and assess how these tranquilliser prescriptions were used? If not, whose responsibility is it to provide research on this if not the Department of Health? If the Department does not intend to research these areas would you provide me with an explanation as to why not?
When answering questions on this issue in 2001, Professor Louis Appleby, Director of Mental Health, Department of Health, stated the importance of finding out this data on BBC Panorama. Why was this not followed up then?
2. You say that “If hypnotics and anxiolytics are prescribed appropriately, for the shortest duration possible and with the total duration of use not exceeding 4 weeks, the risk of patients developing tolerance and dependence are minimised.”
It clearly states in the NAC review commissioned by the Department that in the most recent year analysed, 2006, that over 50% of benzodiazepine and over 30% of z drug prescriptions exceeded this prescribing limit. The cause of this is doctors ignoring guidelines.
As the issuing of more guidelines will have no effect as it has until now and as this is the maximum period the Department deems necessary for patient safety, how does the Department intend to enforce the maximum prescribing limit of 4 weeks?
3. Many people including myself have lost years from their lives enduring multiple withdrawal symptoms to come off these drugs, unsupported by the healthcare system.
Does the Department intend to use the WHO ICD 10 F13.2 definition of dependence in order to redefine addiction, pretend that it does not exist, and abandon victims of these drugs to the whim of local authorities with no funding or direction, even though prescribed tranquilliser addiction outnumbers illicit addiction by a factor of 5 and that they are far worse to withdraw from than heroin?
4. You say that “The increase in the level of prescribing observed could be due to a number of different reasons. From the figures in this report, it is not possible to estimate how many patients are receiving these treatments, if the medicines are being used appropriately or if there is off-label use.”
What action does the Department intend to take in order to:
a) Determine and explain the reasons for high levels of tranquilliser prescribing?
b) Quantify how many patients are receiving these treatments?
c) Assess whether these medicines are being used appropriately?
d) Assess the extent of off-label use?
5. Does the Department accept that all the above are its responsibility and if not, then whose responsibility are they?
6. You stated that “However, you may be interested to know that: – prescriptions for all medicines are going up as the population increases and as we get older. The recent slight rise in the number of prescriptions per head for tranquillisers is significantly less than the national trend;”
In a ten year period from 2001 – 2011, anti-depressant prescriptions have more than doubled from 24,343,000 to 46,678,000. During the same period the population of England, to which the Prescription Cost Analysis refers, has increased from 49,138,831 to 51,446,000. The proportion of people over the age of 65 rose by about 10% during the same period.
Would you please explain why prescriptions for anti-depressants has more than doubled disproportionately to the population figures you claimed were the cause?
Also, we are told that responsible prescribing is increasing. Would you please explain why tranquilliser prescriptions are not reducing as would be expected if this was the case?
7. With regard to services for those addicted to prescribed tranquillisers the Department claims that ““94% of those partnerships who responded positively to the questionnaire reported that there was local service provision in place for those that reported problems in relation to POM/OTC medicines”.
My survey, which the Department was sent recently, provides evidence that 84% of partnerships do not provide services for stand alone tranquilliser prescription.
Would you please explain this massive discrepancy?
8. In my recent letter to Earl Howe, I asked why the Department is using a review on substance misuse as an evidence base for answering questions on involuntary tranquilliser addiction. This question was not answered and I require a response.
9. In a recent email to me from Angela Gillen for the Department, she explained that the Department does not recognise involuntary tranquilliser addiction. Does this mean that the Department considers involuntary tranquilliser addiction to be substance misuse and that those suffering from it should receive substance misuse treatment alongside illicit use? People only taking drugs prescribed by their doctor are not misusing them, do not have present drug seeking behaviour and cannot be described as substance misusers.
10. Would you explain unambiguously how any of the actions arising from the Department’s policy review (commenced July 2009) and the round table have improved services for those damaged by addiction to prescription tranquillisers?