Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No SH SH 1 2 SH 3 Stakeholder Abbott Laboratories Ltd Addenbrookes Hospital, Cambridge University Hospital NHS Trust ARHAI Section number Comments Response This organisation was approached but did not respond This organisation was approached but did not respond Gen Overall this is a well thought through scope. My chief concern relates to only including guidance for children aged over 2 years. I can see no good rationale to the exclusion of children aged under 2 years. For 2005 the incidence of community antibiotic prescribing for children in the UK was 643/1000 children for those aged < 2 years, 690/1000 for the 2-5 year olds, 366/1000 for those 6-10, and 325/1000 for those aged 11-15. Therefore by excluding children aged under 2, the NICE guidance would not cover approximately one third of all community antibiotic prescribing in UK children. The under 2s are in fact the key group to target for NICE guidance. Concerns around potential harm following delayed or non-prescribing are highest in this group, although there is very limited evidence that complications are increased. Influencing families and prescribers behaviour at this young age is likely to considerably influence prescribing for minor infections throughout childhood. The recent introduction of conjugate pneumococcal vaccination within the UK has significantly reduced the risk of serious bacterial infections in the under 2 age group, but this is not widely appreciated by families or GP’s who have seen this as a meningitis vaccination. Viral infections are very common in this age group, and there is good recent published data on the frequency of viral isolates from young children with URTI. NICE clinical guideline 47 on feverish illness in children provides very limited guidance on antimicrobial prescribing for the great majority of children presenting with a fever who will have an URTI. It is therefore very difficult to see why children aged under 2 1 Noted. After detailed consideration and review of current available literature, the technical team agree the exclusion age should be lowered to < 3 months so that it would be in line with the NICE Febrile Illness in Children Guideline. Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No Stakeholder Section number SH 4.0 Association of Medical Microbiologists 4.1.1 SH 4.1 4.3.1 (e) SH 4.2 Association of Medical Microbiologists Association of Medical Microbiologists SH 5 Association of the British Pharmaceuticals Industry,(ABPI) General SH 6 AstraZeneca UK Ltd General Comments should be excluded from this optimal practice guidance. Failure to include this group runs the risk of seriously reducing the impact of this potentially very important NICE guidance for children. After many years of a consistent reduction there is evidence of increased community antibiotic prescribing rates for children. It is therefore illogical to exclude guidance for possibly the most important group within this Scope in terms of antimicrobial resistance. Both the RCPCH and ARHAI would strongly encourage NICE to reconsider the exclusion of children aged under 2 years from this Scope guidance. Both ARHAI and NICE very much welcome the forthcoming guidance and are happy to help in the process. Although we appreciate that this initiative is directed towards children over the age of 2yrs, there is also professional concern amongst our paediatric microbiologists over the use of antibiotics in younger children. Certainly there is a drive within paediatric centres to recognise viral infections and not to routinely prescribe antibiotics for these conditions. Advice over the use of specific analgesics, together with supporting evidence, would be most welcome The AMM and RCPath are very happy to support this initiative, and will actively contribute to further work on the topic. The scope has been widely disseminated and discussed amongst microbiologists, but at this stage we have no further comments other than those made at the Stakeholder meeting, and those outlined above. The ABPI welcomes this guideline recognising that this is a difficult area where guidance would be helpful and appropriate both for health care professionals and patients with self-limiting RTIs. This organisation responded and said that it has no comments to make 2 Response Noted. After detailed consideration and review of current available literature, the technical team agree the exclusion age should be lowered to < 3 months so that it would be in line with the NICE Febrile Illness in Children Guideline. Analgesics will be addressed in the guideline. Noted, thank you Noted, thank you Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No Stakeholder SH SH SH SH SH SH 7 8 9 10 11 12.0 Barts & The London NHS Trust Bayer plc Bedfordshire PCT Bio-Stat Diagnostic Systems Bolton Council British In Vitro Diagnostics Association SH 12.1 British In Vitro Diagnostics Association SH 12.2 British In Vitro Diagnostics Association Section number General 3 4.3.2 Comments This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond BIVDA welcomes the opportunity to respond to the NICE consultation on the draft scope for the guideline on prescribing antibiotics for self-limiting respiratory tract infections. BIVDA believes that there is a need for a national clinical guideline in relation to antibiotic prescribing for RTIs. BIVDA recognises that antibiotic prescriptions in the UK at 34 million per year are 33% higher than the EU average. These costs are considerable and could be reduced by more efficient and appropriate prescribing by GPs. BIVDA also acknowledges the wide variance in prescribing patterns for antibiotics for RTIs. This suggests that there is a particular need for better guidance to GPs and education to patients to encourage a more prudent use of antibiotics. BIVDA believes that inappropriate prescribing of antibiotics has increased the prevalence of antibiotic resistance. Greater resistance amongst patients leads to a growing prevalence in further illness and more eventual cost to the NHS. In the last few years, the growth of antibiotic-resistant bacteria has led to the emergence of a number of superbugs – MRSA and C Difficile in particular – which have had a huge financial cost for the NHS, as well as leading to patient mortalities and a substantial public health concern. BIVDA is extremely concerned that diagnosis has effectively been excluded from the scope of the guideline. We believe that rapid diagnostics – specifically the swab kits to test for Streptococcus A – have a vital role to play in the prescription of antibiotics for RTIs. Streptococcus A is a serious infection which, if not treated by an antibiotic, can lead to much more serious infections, such as rheumatic fever in children. The 3 Response Noted, thank you Noted Due to the restricted nature of a short clinical guideline, it is not possible to include a review of various rapid diagnostic tests for individual RTIs. It should also be noted that this is a fast evolving area with currently Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No Stakeholder Section number Comments exclusion of diagnostics from the scope of this guideline is a wasted opportunity and undermines the central aim of the guideline – “to provide recommendations for good practice that are based on the best available evidence of clinical and cost effectiveness”. The rapid diagnostic test for Strep A is extremely straightforward and enables GPs to differentiate immediately between bacterial and viral aetiologies, thus avoiding inappropriate prescription of antibiotics for viral infections. Tests for bacterial resistance give faster, more accurate microbiology, ensuring that the patient gets the appropriate antibiotic sooner. This minimises use of inappropriate antibiotics, reducing selection for resistance and saving costs. BIVDA is not advocating the use of rapid diagnostic tests for Strep A in every diagnosis for RTIs. Instead we would propose that the guideline make clear that GPs should consider the use of diagnostic tests when prescribing antibiotics for RTI. This would continue to give discretion to the GP, allowing him or her to use a rapid diagnostics test where it was felt there was a particular need to identify beyond doubt whether an infection was bacterial or viral. BIVDA believes that diagnostics play a vital role in prescribing for RTIs, even for those relatively low level RTIs which are covered by the guideline – the common cold, flulike illnesses, earache, sore throat, acute cough and acute sinusitis. Aside from the rapid diagnostic test for Strep A, mentioned above, diagnostic tests can also identify which antibiotics are active against the patient’s infection – giving the doctor the information needed to choose the right antibiotic. Using the right antibiotic is fundamental to successful treatment; using the wrong antibiotic wastes time and money, extends the period of illness and may 4 Response limited data from UK primary care populations. It would be appropriate to offer this specific topic for consideration by the NICE Topic Selection Process as a potential future Technology Appraisal or Clinical Guideline. Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No Stakeholder Section number Comments exacerbate the emergence of resistance, endangering patients. Evidence from France has shown that there was a 48% reduction in the use of antibiotics for pharyngitis after the introduction of a rapid diagnostic test for Strep A. Strep diagnostics tests are currently a prominent part of the strategy being taken forward in France and other European countries to reduce unnecessary antibiotic prescribing, with positive initial results. Given this evidence, it seems inexplicable that NICE are planning to exclude rapid diagnostic tests from the scope of the guideline. BIVDA is aware that the exclusion of rapid diagnostic testing may be due to the reporting schedule and timeframe for the development of this particular guideline. BIVDA would urge NICE to include diagnostic tests. However, if this is not possible, BIVDA would welcome the possibility of a further guideline which would focus on diagnostics, either in relation to RTIs specifically or diagnostics more generally in primary care. For instance, it would be useful to have a guideline on RTIs, lower and upper, which acknowledged the vital role that CRP testing can play in identifying infection. This is currently under used and can be crucial in identifying the early stages of pneumonia and other more serious infections. Progress on developing rapid testing is a growing area in the UK and plays a vital role in appropriate diagnosis and treatment of patients. The cost implications for ignoring rapid diagnostic testing are serious, given the knock on effects of inappropriate prescribing in terms of further illness and more serious conditions. For this reason, BIVDA believes that any cost incurred by further investment in diagnostic testing kits would certainly be justified by cost savings in the longer term. 5 Response Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No SH SH SH 13 14 15 SH 16.0 Stakeholder British Infection Society British National Formulary (BNF) British Paediatric Respiratory Society British Society for Antimicrobial Chemotherapy Section number General Comments BIVDA would welcome the opportunity to discuss with NICE the possibility of including diagnostic testing in this guideline or a future one. This organisation was approached but did not respond This organisation was approached but did not respond This organisation responded and said that it has no comments to make The British Society for Antimicrobial Chemotherapy warmly welcomes and supports this proposal to develop and optimal practice review on the topic “Prescribing of antibiotics for self-limiting respiratory tract infection in adults and children in primary care. Response Noted, thank you The topic is appropriate since there is evidence that antibiotics are prescribed inappropriately for these conditions, that there is wide variation between practices and individual GPS, which is not explained by population variations and that harm (antibiotic resistance and side effects in the individual) results from this. However compared to other European countries there are few with lower antibiotic prescription rates that the UK and the margin for further reduction in antibiotic prescription overall may not be that great. Harm may ensue from inappropriate withholding of antibiotics, especially if an incorrect initial diagnosis is made. SH 16.1 British Society for Antimicrobial Chemotherapy General We consider that the scope and nature of the review process is generally appropriate. In assessing the evidence relevant to prescribing the time of the intervention in relation to the onset of symptoms/disease needs to be taken into account. Too many studies in primary care do not clearly identify this interval and make judgments on the benefit or otherwise of an intervention at time points which are intrinsically inappropriate and as a result bias the assessment. The ease of access to care 6 Noted. The technical team will take this into account when reviewing evidence available. Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type SH SH SH Orde r No 16.2 16.3 16.4 Stakeholder British Society for Antimicrobial Chemotherapy British Society for Antimicrobial Chemotherapy British Society for Antimicrobial Chemotherapy Section number General 4.1.2 4.3.1(a) Comments can significantly affect the timing of supply and administration of a medicine. The scope does not address or make reference to the issue of monitoring of implementation and compliance. WE RECOMMEND THAT REFERENCE IS MADE TO MONITORING OF IMPLEMENTATION AND COMPLIANCE WITH LOCAL PROTOCOLS Will the Guideline apply to the very elderly and nursing home residents? WE RECOMMEND THAT THE GUIDELINE CLEARLY STATES WHETHER THE ABOVE ARE INCLUDED OR EXCLUDED. OUR RECOMMENDATION WOULD BE TO INCLUDE THESE GROUPS. The scope includes 6 topics. Three of these (earache, sore throat and acute cough) are single symptoms; the other three are symptom complexes. WE RECOMMEND THAT THE GUIDELINE GIVES VERY CLEAR RECOMMENDATIONS ABOUT THE DEFINITION OF THESE SYPTOM COMPLEXES AND THE TERM “ACUTE”. SH 16.5 British Society for Antimicrobial Chemotherapy 4.3.1(c) SH 16.6 British Society for Antimicrobial Chemotherapy 4.3.1(e) WE RECOMMEND THAT THE GUIDELINE DEVELOPMENT TEAM CONSIDER THE FREQUENCY IN WHICH, PARTICULARLY WHEN SYMPTOM COMPLEXES ARE USED, THERE IS THE CHANCE TO MIS-DIAGNOSE A CONDITION (EG PNEUMONIA) WHICH REQUIRE IMMEDIATE ANTIBIOTIC THERAPY. WE RECOMMEND THAT A CLEAR DEFINITION OF WHAT SEPARATES “SELF LIMITING” FROM NON SELF LIMITED BE INCLUDED IN THE GUIDELINES WE RECOMMEND THAT PATIENTS NOT RECEIVING ANTIBIOTICS ARE PROVIDED WITH AN ALTERNATIVE 7 Response NICE clinical guidelines do come with implementation tools and audit criteria (as separate documents). Yes. The guideline applies to all adults (including the elderly) with no co-mobidities that will affect the decision to prescribe antibiotics as outlined in section 4.3.2. The guideline will address the definition and basic aetiology of the 5 conditions – earache/sore throat/acute cough/acute rhinosinusitis/acute sinusitis We will consider the evidence of the symptom/sign clusters for each RTI to predict benefit from antibiotics in a primary care population The definition of “self-limiting” will be addressed in the guideline in line with the National Prescribing Centre and current available evidence. The guideline will address the mode of delivery such as brief verbal Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No Stakeholder Section number Comments SUCH AS A DETAILED EXPLANATION, LEAFLET OR ALTERNATIVE DRUG (potential for use of anti-tussives should be included for acute cough). SH 16.7 British Society for Antimicrobial Chemotherapy 4.3.2 SH 16.8 British Society for Antimicrobial Chemotherapy 4.3.2(b) SH SH SH 17 18 19 British Thoracic Society Calderdale PCT CASPE Research SH SH 20 21 SH SH SH SH 22 23 24 25 Cephalon Commission for Social Care Inspection Connecting for Health Cornwall & IoS PCT Daiichi Sankyo UK Department of Health Gen General We are concerned that the exclusions are too broad, and may lead to result in guidance that is not practical to use in general practice and will not result in a change in practice if required. WE RECOMMEND THAT NICE GIVES FURTHER CONSIDERATION TO DEVELOPING GUIDANCE THAT INCLUDES THESE CONDITIONS. Exclusion of patients with ‘co morbidities that affect antibiotic prescription decision’ will significantly limit the usefulness of the Guideline. Such conditions will need to be explicitly stated in the Guideline. This organisation was approached but did not respond This organisation was approached but did not respond On this occasion we have no comments on the proposed scope. This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond The scope for respiratory tract infections in children and adults is from two years of age. A very large proportion of children attend acute paediatric units, and the majority of those admitted are under two years of age. We feel that these do not necessarily need investigation, but need a treatment decision. We are concerned that the guideline proposes to exclude children under two years of age. We accept that there may need to be a cut off in infancy. 8 Response advice, information leaflet and the use of analgesics. We will review role of analgesics but not the use of anti-tussives for acute cough. Given the short time frame of the short clinical guideline process, it is not possible to broaden the scope to cover the reviewing of all evidence on other conditions or co-mobidities related to RTIs. The exclusion of patients with ‘co morbidities that affect antibiotic prescription decision’ will be explicitly stated in the guideline. Noted. Noted. After detailed consideration and review of current available literature, the technical team agree the exclusion age should be lowered to < 3 months so that it would be in line with the NICE Febrile Illness in Children Guideline. Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No SH 26 SH SH 27 28 SH 29.0 Stakeholder Department of Health, Social Security and Public Safety of Northern Ireland Derbyshire County PCT Det Norske Veritas - NHSLA Schemes General Practice Airways Group Section number Comments Response The NICE febrile child guideline has chosen “under three months” as a group to be considered differently. In our opinion, this guideline should also take into account the febrile child guideline. This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond General GPIAG supports the overall emphasis and importance of this topic and its relevance in primary care both at an adult and paediatric level. There is concern however that the title “self limiting respiratory tract infections” is unhelpful. The term “selflimiting” suggests that the decision as to whether or not antibiotics are needed is unproblematic. NICE guidelines need to be clinically relevant. What primary care professionals want to know is: ‘When faced with an adult or child with a respiratory tract infection, will antibiotics be of any use?’. At that point of first contact the professional may not know whether the infection is selflimiting. For the guideline to be of value to primary care professionals, it needs to help them answer this question, and it is not clear that the guideline will do this. The technical team has taken this comment into consideration. The term “self-limiting” is used in the full title so that it would be in line with the National Prescribing Centre and current published literature. However, the technical team will reword the scope in relation to 4.1.1 and 4.1.2. We agree that it is necessary to address the question of which symptom/sign clusters for each condition predict likely benefit or not from immediate prescription of antibiotics in adults and children presenting in primary care with RTIs. The key issue is in section 4.1 : It seems to us that the guideline ought to deal with how you tell the difference between Groups 4.1.1 and 4.1.2 “Self limiting” implies that the condition will improve without intervention, therefore rendering antibiotics unnecessary. This may be true in many medical conditions. It is clear, however, that many conditions have an improved outcome with health care intervention in a variety of ways. (this may 9 We have re-worded section 3 e) and 4.1.1 to take account of this Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No Stakeholder Section number Comments Response be shortened illness – e.g. depression; less long term morbidity or damage e.g. fractures; or improved symptomatology and return to work) There is also a negative implication in focussing on ‘where not to prescribe’ rather than a more general focus on the ‘best or most appropriate’ use of antibiotics when diagnosing and treating RTIs. For these reasons we believe that the short title is more useful than the full guideline title in its current form. The use of ‘minor’ or ‘uncomplicated’ would be preferable to ‘selflimiting’ but these would also require detailed definition. SH 29.1 General Practice Airways Group 3c We believe that a quality review with appropriate dissemination of results and educational packages will have a significant impact on antibiotic prescribing and management of RTI. We also believe that with a programme linked to public health and patient education, the impact could be even greater. The concept of three strategies – none / delayed / immediate is fine, but may be considered simplistic. All of these require a safety net, no matter which strategy is used. Similarly, the level of “sell” on delayed and several other factors will impact on whether or not the patient is in agreement with the shared management strategy. There is considerable work that indicates that even with “immediate treatment”, on many occasions the patient decides to ‘wait and see’. It should also be borne in mind that some patients may be asked to delay filling/starting their prescription, but we have no way of knowing whether they follow these instructions or not, without a detailed audit. It would be good to look at actual practice observation as well as RCT data (real world observational studies). The complex world of communication skills in the consultation 10 Patient information package and patient perspectives will be reviewed as two of the key clinical questions. Different strategies for the delayed management will be reviewed in the guideline i.e. prescription was given immediately but asked to ‘cash in’ later vs. asked patients to come back to the practice to collect the prescription after defined period of time. Both patient and professional’s perspectives and expectations in relation to communication will be addressed in the guideline. An economic evaluation aims to integrate all costs and benefits that Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No Stakeholder Section number Comments Response should not be ignored. It could be argued that the concept of delayed prescription is merely a continuum of patient choice, clinician decision and whether or not the prescription is given at the first or subsequent consultation. relate to the decision problem under consideration. If modelling is necessary and possible, the structure of the model should be consistent with coherent theories of the health conditions under consideration and the likely treatment pathways individuals could follow for the alternative management strategies being evaluated. It would be useful to review the place of telephone advice and the role of NHS Direct on management strategies. Similarly, it is appropriate to look not only at the cost of prescription (albeit important, and a relevant link to resistance) but also the cost of repeat consultations, time lost from work, cost of other alternative prescriptions, if antibiotics are NOT prescribed. Any evidence that the incidence of serious infections such as pneumonia has risen with the secular decline in antibiotic prescribing should be reviewed. Point c appears to indicate that NICE has decided which infections are self-limiting before NICE has reviewed the evidence to determine in which situations antibiotics will NOT be useful, rather than assuring a comprehensive and evidence based review using both RCT and other research methodology. As you correctly identified, any analysis should consider more than just the acquisition cost of antibiotics, and include the cost of repeat consultations and the costs of managing adverse consequences that might arise because antibiotics were not prescribed immediately or not at all. Clearly, the level of detail that can be incorporated into a health economic study will depend in part on the quality and completeness of the evidence available. For the principal cost effectiveness analysis, costs should relate to resources that are under the control of the NHS and Personal Social Services (PSS) where differential effects on costs between the strategies under comparison are possible. However, there will be occasions when non-NHS/PSS costs will be differentially affected by the strategies under comparison. Under 11 Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No Stakeholder Section number Comments SH 29.2 General Practice Airways Group 3d We agree that reduced variation is desirable. Consistency of approach would encourage better public understanding and better clinician adherence to guidelines SH 29.3 General Practice Airways Group 3e SH 29.4 General Practice Airways Group 4a SH 29.5 General Practice Airways Group 4.1.1 The key to many changes in healthcare practice is the influencing of opinion leaders and the general public. The literature associated with influencing prescribing should be considered. Standard treatment with antibiotics is not uncommon with simple URTI when the patient is seen in A&E or albeit briefly by secondary care colleagues and discharged early in real clinical practice. Attention should also be paid to the expectation that patients have developed over time that an antibiotic will be given. What is the evidence base for strategies to help to change this expectation, if the expectation is inappropriate? Patient expectation could be picked up in the context of guidelines implementation at NICE. E.g the production of an explanatory patient leaflet. Hence if this is the exact definition of scope the programme will miss many of the factors impacting on clinical care for patients in primary care. The above issues need consideration (telephone advice, previous practice, influencing factors, methods of prospectively assessing “self limiting illness.” It is not clear why under 2s have been excluded. Appropriate use of antibiotics in this group is just as important as in other groups. 12 Response these circumstances it may be appropriate to consider the implications of taking a broader perspective on costs in a separate analysis to the principal one. Noted Patient information package and patient perspectives will be reviewed as two of the key clinical questions. Patient information package, patient perspectives/expectations, professional perspectives/views will form part of the key clinical questions to be reviewed. After detailed consideration and review of current available literature, the technical team decided to lower the exclusion age to < 3 months so that it would be in line with the Febrile Illness Guideline. Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No Stakeholder Section number SH 29.6 General Practice Airways Group 4.1.2 SH 29.7 General Practice Airways Group 4.3.1a SH 29.8 General Practice Airways Group 4.3.1c SH 29.9 General Practice Airways Group 4.3.1d SH 29.10 General Practice Airways Group 4.3.1e Comments Identification of this group will need to be evidence based, and this in itself is likely to be complex. Immediate antibiotic prescribing (in A&E / Hospital / GP) does not always mean that the condition is not “self limiting” and patients recover despite our treatments. The key issue in primary care is HOW to differentiate between those in 4.1.1 and those in 4.1.2. It is difficult to see how you can clearly eliminate a group when it is the process of identifying who falls within that group that is a key challenge. A review of the symptoms of and evidence for antibiotic use for each of these conditions would be very useful, and would be more impactful for prescribers than guidance for the vaguely defined ‘self-limiting infections’. A common way of categorising RTIs is into upper respiratory tract infections (URTI) and lower respiratory tract infections (LRTI). Primary care practitioners will be looking for guidance in line with these categories. If this distinction is felt to be unhelpful based on the evidence, it should be borne in mind that considerable communication and reeducation may be necessary. Consideration of rhinosinusitis and hoarse voice should also be considered. Practices may be reluctant to take any course of action which leads to the need for the patient to attend a further consultation. Written management plans tailored to the patient, and advice from the pharmacist which reinforces the strategy that the prescriber has advised would be useful. This covers paracetamol / ibuprofen. It would be sensible to consider pseudoephedrine, mucolytics and cough preparations in the same section, along with steam inhalation and other common current self treatments and indeed advised. Guidance on the use of advice about self-care that does not involve prescribing would also be useful. E.g. signs of 13 Response We agree that it is necessary to address the question of which symptom/sign clusters for each condition predict likely benefit or not from immediate prescription of antibiotics in adults and children presenting in primary care with RTIs. The effectiveness of antibiotics for the 5 conditions in 4.3.1 will be reviewed. The GDG will consider if it is useful to differentiate RTI into upper and lower RTI for the purposes of this guideline. For LRTIs the focus is on the management of acute cough, not on other LRTIs. Rhinosinusitis will be covered by the revised scope. This should be addressed by the implementation tools and audit criteria produced separately by NICE. The mode of delivery of the three management strategies will be reviewed. Due to the restricted timeframe for short clinical guideline, it is not possible to include the reviewing of all other possible treatments/medicines for individual RTIs. Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No Stakeholder Section number SH 29.11 General Practice Airways Group 4.3.2a SH 29.12 General Practice Airways Group 4.3.2b SH 29.13 General Practice Airways Group 4.4 SH 30.0 Genzyme Diagnostics 4.3.2 Comments worsening to look for, time off work, rest, advice on comorbidities – e.g. looking after self if have diabetes. We have concerns about the value of the guidance if these areas are excluded. They are central to the decision making process when prescribing antibiotics. To exclude the grey area of viral vs bacterial infections, and not to define ‘self limiting’ in terms of what presents to professionals will severely limit the value of the guideline. Other key factors – agree that asthma / COPD should be excluded. Many patients are smokers, many have diabetes or heart disease; many have previous experiences that influence their treatments. It should be explicit whether smokers / patients with diabetes etc are both included in the research and in the advice, as should the “consent to randomisation rather than intention to treat” and the previous experiences that may result in patients declining to take part in trials. This is excellent and very important. An audit of delayed prescriptions would be useful - and why this course of action was taken, and what the outcome was It will be important to assess the impact (cost, patient outcomes) of not prescribing immediately. “Given the low incidence of streptococcal pharyngitis and the minimal risk of acute rheumatic fever in persons over 20 years of age, it seems reasonable to rely on either a throat culture or a high-sensitivity rapid antigen detection test without confirmation by culture in adults. The high specificity of the rapid tests (very few false positive results) should help prevent the needless use of antimicrobial agents in adults with pharyngitis.” (Bisno AL. N Engl J Med 2001;344:20511) “..antibiotic treatment based only on positive rapid tests or throat culture results can reduce unnecessary use of antibiotics for treatment of pharyngitis.” (McIsaac WJ et al. JAMA 2004;291:1597-95) 14 Response Due to the restricted timeframe for short clinical guideline, it is not possible to include the reviewing of various diagnostic testings for individual RTIs. The technical team will look at this specifically when reviewing the evidence. Noted, thank you, however any economic analysis should aim to consider the full impact of not prescribing antibiotics immediately. Due to the restricted nature of a short clinical guideline, it is not possible to include a review of various rapid diagnostic tests for individual RTIs. It should also be noted that this is a fast evolving area with currently limited data from UK primary care populations. It would be appropriate to offer this specific topic for consideration by the NICE Topic Selection Process as a potential future Technology Appraisal Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No Stakeholder Section number Comments Response or Clinical Guideline. “The GRAPH group evaluated whether guidelines for the treatment of pharyngitis in adults (>25 years of age) based on the use of Strep A (StA) rapid diagnostic tests (RDT) were applicable in general practice.Methods - A pragmatic ''before-after'' study was made to evaluate changes in practice after training. This was done over three periods: period I ''before'' and III ''after'' in which data on GPs' practice (about 100 general practitioners (GPs) from the Bourgogne and Rhone Alpes regions) was collected; period II when GPs underwent training including information on the conclusions of the consensus conference and training to use the Strep A RDT.Results - Data was collected on GPs' practice in around 900 cases of pharyngitis in each period (I et III) between October 1998 and March 1999. After just one training course, RDTs were performed in 93% of cases, with a positive rate of 20.2%. The overall use of antibiotics was reduced by 48.4% (42.6% in period III vs. 82.6% in period I, p<0.001). (Portier H et al. Assessing applicability of guidelines on management of pharyngitis in adults in general practice Medecine et Maladies Infectieuses 2001;31:388-395) The last reference in particular shows that clinical guidelines using rapid diagnostic tests can have a significant impact in correct diagnosis and reduced antibiotic prescribing. SH 31 Health Commission Wales Other multi-country European studies are underway looking at ways of reducing antibiotic prescribing and are including evaluation of the role of rapid diagnostic testing. The exclusion of the key piece of information to best target antibiotics for patients with upper respiratory tract – namely whether the condition caused by a virus or a bacterium – means that clinicians will remain in the dark about whether treatment is likely to work. This organisation was approached but did not respond 15 Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No SH SH SH 32 33 34 SH SH SH SH 35 36 37 38 SH SH SH SH SH 39 40 41 42 43 SH SH 44 45 SH Stakeholder Section number Comments 46.0 Health Protection Scotland Healthcare Commission Heatherwood & Wexham Park Hospitals NHS Trust Institute of biomedical Science Kirklees Primary Care Trust Launch Diagnostics Medicines and Healthcare Products Regulatory Agency (MHRA) Menarini Diagnostics Milton Keynes PCT National Patient Safety Agency National Pharmacy Association National Public Health Service Wales NCCHTA NHS Clinical Knowledge Summaries service NHS Direct 4.3 Consider over the counter therapies and homely remedies, e.g use of anaesthetic throat lozenges for a sore throat, use of cold remedies. SH 46.1 NHS Direct 4.3.1 d) SH 46.2 NHS Direct 3. Consider in relation to the DH Information Prescription strategy due to be rolled out nationally 2008. Currently 20 pilots are exploring how information can be prescribed and best delivered to meet patient’s needs as part of a care pathway. Would be helpful to look at the role of payment and self-care to purchase analgesia and other OTC preparations. se medicines OTC and will obtain medicines on prescription too. SH SH 47 48 NHS Plus NHS Quality Improvement Scotland Response This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond 16 Due to the restricted timeframe for short clinical guideline, it is not possible to include the reviewing of all other possible treatments/medicines for individual RTIs. The technical team will look at this strategy closely. Due to the restricted timeframe for short clinical guideline, it is not possible to include the reviewing of all other possible treatments/medicines for individual RTIs. Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No SH 49 SH SH 50 51.0 Stakeholder North Cumbria Acute Hospitals NHS Trust North Tees PCT PAGB Section number Comments Response This organisation was approached but did not respond General This organisation was approached but did not respond The scope of this guideline should be extended to include consideration and use of people’s behaviour in dealing with self limiting respiratory tract infections before they consult a GP, so that the response in general practice can make more and better use of self care in consultations for respiratory tract infections. PAGB has conducted consumer research over the last 20 years to find out more about the incidence of minor ailments in the community and what people do about them. The latest of these studies was carried out in 2005 by NOP World. According to this study, 82.9% of the adult population experienced respiratory conditions and 88.9% of children had a cold in a 12 month period. This means that 41m adults and 9m children suffered from colds, coughs, sore throats, blocked nose, sinus problems and flu. It is important therefore to examine what they did about these symptoms. The following shows the breakdown of the number of adults experiencing these symptoms: Cold - 34m people (82.3%) Sore throat/cough - 28m people (67.2%) Blocked nose/sinus problems (not related to a cold) - 14m people (34.9%) Flu - 10m people (24.1%). Additionally, the study showed that the vast majority of people either did nothing, waiting for the symptoms to clear up, or used an OTC medicine. This is the type of behaviour that should be encouraged further and before people abandon it for a primary care consultation. Consequently, 17 Noted. While acknowledging that health seeking behaviour prior to consulting a health care practitioner is extremely important with reference to self-limiting RTIs a Clinical Guideline’s remit is to address the interaction between health care practitioner and patient, not antecedents of the consultation. However, the guideline will address the need to identify and address patient’s ideas, concerns and expectations with regard to need for antibiotic prescription. Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type SH SH Orde r No 51.1 51.2 Stakeholder PAGB PAGB Section number 3 c) 4.3.1 b) Comments the guideline could provide valuable advice on the management of RTIs at home and at work when this is possible and reference to primary care when this is needed. The scope of the guideline could be extended to cover the use of community wide health campaigns that give people information about looking after their symptoms and signposting them to the relevant parts of the NHS such as the community pharmacist, NHS Direct, walk in centre and general practice in a step wise approach where the GP is the final step when self care is no longer the optimal solution. We would argue that there is a fourth management strategy which stands alone and is also cross cutting. The strategy is referral to self care and the pharmacist. Since the main response for non complex RTIs is self care and self medication, patients’ pre-existing behaviour can be endorsed and encouraged, even recommended further. In addition, no matter which of the three different antibiotic management strategies is employed, the self care strategy can be added to it thereby making it a cross cutting strategy. The scope could be extended to cover self care and referral to the pharmacist and the means of communicating to people that they should choose this option rather than going to their GP. The long term benefit of reinforcing this kind of behaviour would be to instil in people the action of first-line self care in dealing with self limiting RTIs as the cultural norm, thus ensuring the cultural shift from primary care dependence to independent action. Asking patients about their previous self care behaviour needs to be included in the scope for this section as it provides an understanding of the extent to which people are prepared to try self care and why they abandon it for the primary care consultation, particularly one with the GP, resulting in nearly 8m consultations a year for self limiting respiratory conditions among the adult population and 1m consultations for children with colds. However, the majority 18 Response Noted. While acknowledging that health seeking behaviour prior to consulting a health care practitioner is extremely important with reference to self-limiting RTIs a Clinical Guideline’s remit is to address the interaction between health care practitioner and patient, not antecedents of the consultation. However, the guideline will address the need to identify and address patient’s ideas, concerns and expectations with regard to need for antibiotic prescription. The guideline will address the need to identify and address patient’s ideas, concerns and expectations with regard to need for antibiotic prescription. Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No SH SH SH 52 53 54 SH SH SH SH Stakeholder Section number Comments Response of people handle their respiratory tract symptoms either by waiting till they get better or by treating them with OTC medicines without needing to visit their GPs and at no cost to the NHS. But those that do seek out the GP cost the NHS £1.4b a year in GP time. Since two-thirds of consultations result in prescriptions the dispensing cost is a further £60m. The issuing of a prescription reinforces help seeking behaviour and this becomes even more entrenched if the prescription is for an antibiotic. Since most people will have tried self care and self medication before presenting to the surgery a few self care aware questions in history taking will help in reinforcing self care behaviour rather than dependency on the GP. This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond 55 56 57 58.0 PERIGON Healthcare Ltd Powys Local Health Board Primary Care Pharmacists Association PRIMIS+ Q-Med UK Ltd Respironics UK Rotherham PCT 1. SH 58.1 Rotherham PCT 3a, 3b SH 58.2 Rotherham PCT 3b This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond The PCT feels that the title of the proposed guideline should be “ Guidance on the appropriate use of antibiotics for selflimiting respiratory tract infections in adults & children in primary care” These paragraphs should be reversed in that the introductory paragraph, 3a, supporting the clinical need for the guideline should not focus on cost, but should focus on the points currently in 3b, i.e. that inappropriate prescribing has the potential to cause drug- related adverse events, to increase the prevalence of antibiotic resistant organisms & to increase primary care consultation rates for minor illness. Should state the antibiotic prescribing costs, i.e. these should be secondary to the patient & resistance factors above. 19 This particular short clinical guideline is part of the Optimal Practice Review (OPR) programme, hence the title is suitable for its purposes. For more information on the OPR programme please visit the NICE website. This particular short clinical guideline is part of the Optimal Practice Review (OPR) programme, hence the content of the scope is suitable for its purposes. For more information on the OPR programme please visit the NICE website. This particular short clinical guideline is part of the Optimal Practice Review (OPR) programme, hence the content Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No Stakeholder Section number Comments SH 58.3 Rotherham PCT 4.1.1. The PCT suggests that the guideline should cover adults & children, as defined in the guideline, but that there should be no lower age limit. SH 58.4 Rotherham PCT 4.1.2 Should dentists be included if sinusitis is covered in the guideline? SH 58.5 Rotherham PCT 4.3.1 d SH 59 SH 60.0 Royal Brompton & Harefield NHS Trust Royal College of General Practitioners Easy access to appropriate patient leaflets is essential, for successful implementation. This organisation was approached but did not respond 4.3.1c The text ‘For patients likely to have a self-limiting RTI, and therefore not suitable for immediate antibiotic treatment, the following antibiotic management strategies will be considered’ Response of the scope is suitable for its purposes. For more information on the OPR programme please visit the NICE website. After detailed consideration and review of current available literature, the technical team decided to lower the exclusion age to < 3 months so that it would be in line with the NICE Febrile Illness Guideline. The guideline addresses rhinosinusitis which is managed by primary medical care. Patient information leaflet will be addressed in the guideline. The scope has been revised based on this suggestion. I think the reasoning should be clearer since defining aninfections as self limiting is arguably an indication for no offer of antibiotics. The following might be clearer: ‘For patients where antibiotics are not indicated immediately the following management strategies will be considered’ SH 60.1 Royal College of General Practitioners 3 e) Similar considerations apply to the text: there is a need for guidance on • ‘which RTIs can be treated as ‘selflimiting’ and are therefore not suitable 20 The scope has been revised based on this suggestion. Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No Stakeholder Section number Comments • Response for immediate antibiotic treatment ‘ which antibiotic management strategies could be offered once a decision has been made that the patient is likely to have ‘self-limiting’ RTI and ‘ The reasoning could perhaps be more definite: there is a need for guidance on • ‘which RTIs do not require immediate antibiotic treatment ‘ • which antibiotic management strategies could be offered once a decision has been made that the patient does not need immediate antibiotics SH 61.0 Royal College of Midwives General SH 61.1 Royal College of Midwives 4.3.1 (d) SH 62.0 Royal College of Nursing General SH 62.1 Royal College of Nursing General The Royal College of Midwives welcomes this guideline and strongly supports the clinical need as stated in the scope. If the mode of delivery strategy is by way of a patient information leaflet, as opposed to brief verbal advice from the practitioner, will the leaflet include advice on how the patient will asses if the RTI is self-limiting? Respiratory Tract Infection is commonly referred to as Upper or Lower RTI. The guidance will need to indicate when it is referring to upper, lower or both Why is the cut off age two years as many one year olds present with upper respiratory tract infections? 21 Noted Evidence on brief verbal advice from practitioners will also be reviewed in the guideline. The effectiveness of antibiotics for the 5 conditions will be reviewed, and as the guideline does not address all conditions within RTI, the classification of URTI and LRTI is not relevant within this guideline. After detailed consideration and review of current available literature, the technical team decided to lower the exclusion age to < 3 months so that it would be in line with the Febrile Illness Guideline. Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No Stakeholder Section number SH 62.2 Royal College of Nursing General SH 62.3 Royal College of Nursing SH 62.4 Royal College of Nursing Section 4.2 Section 4.3 SH 62.5 Royal College of Nursing SH 63 Royal College of Paediatrics and Child Health Section 4.4 Gen Comments This should prove a useful document. However it would be useful to address what antibiotics should be prescribed in terms of regimens as this is an area where there are potential cost savings, and also an area where there is inappropriate prescribing Nurse-led community clinics should also be included Perhaps it would be useful to also include guidance on what ‘worsening symptoms’ warrant the commencement of the deferred antibiotic prescribing. A useful key outcome measure would be the amount of delayed prescriptions that were used Overall this is a well thought through scope. My chief concern relates to only including guidance for children aged over 2 years. I can see no good rationale to the exclusion of children aged under 2 years. For 2005 the incidence of community antibiotic prescribing for children in the UK was 643/1000 children for those aged < 2 years, 690/1000 for the 2-5 year olds, 366/1000 for those 6-10, and 325/1000 for those aged 11-15. Therefore by excluding children aged under 2, the NICE guidance would not cover approximately one third of all community antibiotic prescribing in UK children. The under 2s are in fact the key group to target for NICE guidance. Concerns around potential harm following delayed or non-prescribing are highest in this group, although there is very limited evidence that complications are increased. Influencing families and prescribers behaviour at this young age is likely to considerably influence prescribing for minor infections throughout childhood. The recent introduction of conjugate pneumococcal vaccination within the UK has significantly reduced the risk of serious bacterial infections in the under 2 age group, but this is not widely appreciated by families or GP’s who have seen this as a meningitis vaccination. Viral infections are very common in this age group, and 22 Response Due to the restricted timeframe for short clinical guideline, it is impossible to include the reviewing of antibiotic regimens for individual RTIs. Yes. This is included i.e. Walk-in centres Noted. The guideline will advise under what situations the deferred prescription should be started. This will be one of the outcome measures to be reviewed. After detailed consideration and review of current available literature, the technical team decided to lower the exclusion age to < 3 months so that it would be in line with the NICE Febrile Illness Guideline. Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No Stakeholder Section number Comments Response there is good recent published data on the frequency of viral isolates from young children with URTI. NICE clinical guideline 47 on feverish illness in children provides very limited guidance on antimicrobial prescribing for the great majority of children presenting with a fever who will have an URTI. It is therefore very difficult to see why children aged under 2 should be excluded from this optimal practice guidance. Failure to include this group runs the risk of seriously reducing the impact of this potentially very important NICE guidance for children. After many years of a consistent reduction there is evidence of increased community antibiotic prescribing rates for children. It is therefore illogical to exclude guidance for possibly the most important group within this Scope in terms of antimicrobial resistance. Both the RCPCH and ARHAI would strongly encourage NICE to reconsider the exclusion of children aged under 2 years from this Scope guidance. Both ARHAI and NICE very much welcome the forthcoming guidance and are happy to help in the process. SH 64.0 Royal College of Pathologists 4.1.1 Although we appreciate that this initiative is directed towards children over the age of 2yrs, there is also professional concern amongst our paediatric microbiologists over the use of antibiotics in younger children. Certainly there is a drive within paediatric centres to recognise viral infections and not to routinely prescribe antibiotics for these conditions. After detailed consideration and review of current available literature, the technical team decided to lower the exclusion age to < 3 months so that it would be in line with the NICE Febrile Illness Guideline. SH 64.1 Royal College of Pathologists 4.3.1 (e) Advice over the use of specific analgesics, together with supporting evidence, would be most welcome SH 64.2 Royal College of Pathologists General The AMM and RCPath are very happy to support this initiative, and will actively contribute to further work on the topic. The scope has been widely disseminated and discussed amongst microbiologists, but at this stage we The use of analgesics will be addressed within this particular guideline. Noted, thank you 23 Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type SH Orde r No 65.0 Stakeholder Royal College of Physicians of London Section number Point 3 Comments have no further comments other than those made at the Stakeholder meeting, and those outlined above. The topic is appropriate since there is evidence that antibiotics are prescribed inappropriately for these conditions. Also that there is wide variation between practices and individual GPs, which is not explained by population variations and that harm (antibiotic resistance and side effects in the individual) results from this. Response Noted. Comparison to other European countries shows that there are few with lower antibiotic prescription rates than the UK and suggests that the margin for further reduction in antibiotic prescription overall may not be that great. Harm may ensue from inappropriate withholding of antibiotics, especially if an incorrect initial diagnosis is made. SH 65.1 Royal College of Physicians of London Point 4.1.2 Will the Guideline apply to the very elderly and nursing home residents? SH 65.2 Royal College of Physicians of London Point 4.3.1a SH 65.3 Royal College of Physicians of London Point 4.3.1c The scope includes 6 topics. Three of these (earache, sore throat and acute cough) are single symptoms, the other three are symptom complexes. The Guideline must give very clear recommendations about the definitions of these symptom complexes and the term ‘Acute’. It also will need to consider the frequency in which, particularly when symptom complexes are used, there is the chance to mis-diagnose a condition (e.g. pneumonia) which requires immediate antibiotic therapy. What separates ‘self limiting’ from non self limiting must be clearly defined. SH 65.4 Royal College of Physicians of London Point 4.3.1e Patients not receiving antibiotics must be provided with an alternative such as detailed explanation, leaflet or alternative drug - potential for use of anti-tussives should be included 24 Yes. The guideline applies to all adults (including the elderly) with no further co-mobidities that will affect the decision to prescribe antibiotics. The guideline will address the definition and basic aetiology of the 4 conditions listed in 4.3.1 The definition of “self-limiting” will be addressed in the guideline in line with the National Prescribing Centre and current available evidence. This will be addressed within the guideline under the section “the mode of delivery” of antibiotic management Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No Stakeholder Section number SH 65.5 Royal College of Physicians of London Point 4.3.2b SH SH SH SH SH SH 66 67 68 69 70 71 SH 72.0 Royal Society of Medicine SACAR Salford PCT Sanofi-Aventis Schering-Plough Ltd Scottish Intercollegiate Guidelines Network (SIGN) Sedgefield PCT 4.3.1d SH SH SH 73 74 75.0 SH 76 SH SH SH 77 78 79 SH SH 80 81 SH SH SH SH 82 83 84 85 SH 86 Sefton PCT Sheffield PCT Sheffield Teaching Hospitals NHS Foundation Trust Social Care Institute for Excellence (SCIE) Solihull PCT South Staffordshire PCT Specialist Advisory Committee on Antimicrobial Resistance (SACAR) Trafford Primary Care Trust University Hospital of South Manchester NHS Foundation Trust University of Wales, Bangor Warrington Primary Care Trust Welsh Assembly Government Welsh Scientific Advisory Committee West & East & North Hertfordshire 4.4c Comments Response for acute cough Exclusion of patients with ‘comorbidities that affect antibiotic prescription decision’ will significantly limit the usefulness of the Guideline. Such conditions will need to be explicitly stated in the Guideline. This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond strategies. The exclusion of patients with ‘co morbidities that affect antibiotic prescription decision’ will be explicitly stated in the guideline. This should also consider how the Rx is given (I hope to publish soon on a non-URTI topic regarding different methods of giving delayed Rxs- most doctors give the prescriptions to patients and tell them to wait) This organisation was approached but did not respond This organisation was approached but did not respond This section should have consideration of allergy status of patient (adverse effects) This organisation was approached but did not respond Noted. This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond 25 Yes. This will be addressed. Respiratory tract infection – antibiotic prescribing. Scope consultation: 30 July – 28 August 2007 Type Orde r No SH 87 SH SH SH 88 89 90 Stakeholder PCTs West Midlands Ambulance Service NHS Trust WhippsCross Hospital NHS Trust Wyeth Pharmaceuticals Yorkshire Ambulance Service Section number Comments This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond This organisation was approached but did not respond 26 Response
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