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PHARMAC responds to Richard Milne on discounting health
benefits and costs
Associate Professor Richard Milne's recent viewpoint article
(http://www.nzma.org.nz/journal/118-1214/1443/)1
on the use of discount rates gives a good summary of the situation in New
Zealand of what is an important if technical issue.
PHARMAC has consulted in the past with the public on what
discount rate to use; in June 1998 it consulted with a range of suppliers and
clinician groups about how to account for both costs and benefits when reviewing
drug subsidies, which included which discount rate to use (after which PHARMAC
decided on 10% ). PHARMAC continues to review the discount rate it uses each
year, and will be consulting widely again within the next twelve months.
PHARMAC has historically used a discount rate loosely tied
to that used by the New Zealand health sector for evaluating capital
investments—referred to as the capital
charge.2 As of 1 July this year, the capital
charge in the health sector was reduced to 8% . PHARMAC has, likewise, adjusted
its discount rate from the previous 10.0%3 down
to 8.0%. While many may view this as a move in the right direction, others may
see it as neither enough nor for the right reasons.
So, what are the issues? Richard Milne compares New
Zealand’s discount rate with that of other health sectors
internationally—which seem to use rates closer to 5% rather than 10% .
However, the results of this comparison depend on which sectors you compare. An
alternative, and arguably more appropriate approach, is to compare
PHARMAC’s rate with other public sector bodies within New Zealand, which
gives a different picture.
In New Zealand we understand there are currently two public
sector agencies that rely heavily on cost benefit analysis to guide their
decision making (others tend to use it on an
ad hoc basis). These agencies are
PHARMAC and Land Transport New Zealand (the amalgamation of Transfund and the
Land Transport Safety Authority (LTSA) in late 2004). Both agencies use discount
rates nearer 10% (rather than 3 or 5% ); Land Transport NZ uses
10.0%,4 as originally required by the NZ
Treasury for public sector infrastructure investment and following a review in
1998.5
Being consistent with health sectors internationally means
potentially being inconsistent with other government sector bodies in New
Zealand. We think it reasonable to analyse all public sector investments in
health and safety (Vote Health, ACC, Land Transport NZ road safety, OSH, etc)
using a similar rate, and do not see why investments in pharmaceuticals should
be considered a special case.
Good synopses around other issues can be found in the report
of the Washington Panel (the ‘Gold
report’)6,7 and a NZ Treasury working
paper,8 both cited by Richard Milne. They
separately argue for the riskless cost-of-capital to government as a proxy for
social preference rates, which is currently 4 to 6% in the New Zealand context.
The 3% rate suggested for both the United States and in turn
the World Health Organisation arose from the ‘Gold report’, which
argued for the riskless cost of capital proxy—which for the previous
decade for the US economy happened to average 3% . New Zealand’s economy
now is very different from that of United Kingdom and the US in past years; it
makes little sense for New Zealand to blindly use the rates used by the UK and
the US.
Further, basing the discount rate used on the riskless cost
of capital suggests that the opportunity cost of capital provides a reasonable
proxy for societal time preferences. This may not be true. In addition, the
appropriate rate may not be found through analysis of rates actually used
(implicitly) but rather by surveying what rates society wishes be used. There
are many examples of health related behaviour suggesting that New Zealanders
actually have a very high preference for health now at the expense of health in
the future. But we acknowledge that when investing for the future there may be
good justification for using lower rates—but where discrimination is
inevitable regardless of the rate
set.9
In reality, cost effectiveness, which relies on discounting,
is but one of PHARMAC’s eight formal decision
criteria;10 total costs, need, and other
factors are also important.11 As Richard Milne
indicates, there is no Treasury requirement for PHARMAC or indeed the rest of
the health sector or any other sector to use any particular discount
rate.12 We agree with him that it is time to
reconsider discounting, and his implied calls for a sector-wide approach to rate
setting.
More fundamentally however, we call for greater use of cost
effectiveness analyses to help inform funding decisions within the New Zealand
health sector, and indeed other public sectors. We believe—as does Richard
Milne—that all health sector decisions need to better incorporate issues
of relative capacity to benefit, opportunity cost and relative value-for-money.
Indeed, the systematic use of economic analysis as part of decision-making in
the health sector—which will include greater understanding and use of
discounting—should broaden the debate about discount rates.
It is up to the sector as a whole to decide on the discount
rate.12 Richard Milne has usefully signposted
and added to this debate.
Conflict of
interest: Scott Metcalfe is externally contracted to work with PHARMAC
for public health advice. Matthew Brougham, Peter Moodie and Rachel Grocott
declare no conflicts.
Scott Metcalfe
Public Health Physician Wellington Matthew
Brougham
Manager, Assessment and Analysis PHARMAC Wellington Peter Moodie
Medical Director PHARMAC Wellington Rachel Grocott
Senior Analyst, Hospital Pharmaceutical Assessment PHARMAC Wellington References and
Endnotes:
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