On 19th April, the UK government’s Advisory Committee on Borderline Substances (ACBS) published an open consultation on proposed changes to their policy on liquid, ready-to-drink (RTD) oral nutrition supplements (ONS). 
 
In this article, we take a look at the committee’s proposal, its potential impact on healthcare professionals and ONS manufacturers, and how you can get involved in the consultation. 

Who are the ACBS? 

The ACBS is a government committee responsible for advising on the prescription of borderline substances in NHS primary care settings. The term ‘borderline substances’ refers to nutritional or dermatological products that have been designed to help manage certain medical conditions. 
 
Manufacturers submit applications for borderline substances to the ACBS, who will evaluate their efficacy, safety, and pricing. Those that are approved and recommended for use within the NHS are listed in Part XV of the Drug Tariff – a document produced by the NHS that includes information on what drugs can be reimbursed against an NHS prescription form. 

What is the consultation about? 

The ACBS has launched a consultation on proposed changes to their policy on RTD ONS. These changes include: 
 
1. The standardisation of pack sizes to 125ml and 200ml in an attempt to improve prescribing and reduce prescribing errors. 
 
2. Restricting the presentation of the same RTD ONS formulation to only one size per product. 
 
3. Restricting the clinical indications of RTD ONS providing 1kcal/ml to the management of intestinal failure only, excluding prescription to supplement nutritional intake. 
 
4. Removing RTD ONS products that are manufactured to provide a patient’s additional nutritional requirements in a single bottle, unless they: are presented in 125ml or 200ml size, provide a minimum of 500kcal per bottle, and provide all other nutrients in appropriate amounts. 
 
5. Removing the use of the words ‘complete’ and ‘fibre’ in brand names and product descriptions. 

What are the potential impacts of the proposed changes? 

The changes proposed as part of the consultation have the potential to impact clinical practice considerably. Concerns that could be raised in response to the consultation include: 
 
● Reduction of choice, impacting dietitians’ ability to exercise professional judgement in choosing the best products and volumes for their individual patients’ needs. 
 
● A wish to view the evidence underpinning the proposed policy changes. 
 
● Increased workload and risks to patient safety as a result of the removal of front-of-pack labelling information or brand name changes. 
 
● Impact on patient preferences and subsequent consequences for their care. 
 
● Suppression of the industry’s ability to innovate in response to patient needs. 
 
We specialise in medical nutrition communications. Thus, the proposed changes and their potential impacts are particularly relevant to HRS Communications’ clients. 
Accordingly, we have been supporting many of our clients with communicating information about the consultation. We have worked in conjunction with the British Specialist Nutrition Association (BSNA) – the trade association representing manufacturers of RTD ONS products – to produce a deep dive article into this topic which has just been published in the Complete Nutrition (CN) magazine and can be downloaded HERE. 

How can I get involved? 

Clinicians, manufacturers, and other interested parties can have their say about the proposed policy changes by completing and submitting the relevant survey on the consultation website. 
 
You can also contact the ACBS Secretariat directly by email (acbs@dhsc.gov.uk), or by post (ACBS Secretariat: Room 2S07, Department of Health and Social Care, Quarry House, Leeds, LS2 7UE). Dietitians may also support any response to the consultation made by their BDA specialist group. 
 
The survey closes at 11.45 on 1st August 2021. The ACBS will consider any responses and may amend the proposed policy accordingly. The final policy will include the ACBS’ considerations to representations and will be published at a suitable time. 
Our team is well-connected in the world of nutrition. We offer a range of services which help to increase your brand awareness amongst healthcare professionals (HCPs). Find out more here or please contact us at info@hrscommunications.com
 
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