OBJECTIVES: It is often assumed that the objective of health care is solely to maximise health using available resources. This is the principle underpinning NICE’s use of cost-effectiveness analysis based on incremental cost per QALY gained. Yet research on local NHS decision-making shows that cost per QALY is far from the only consideration. Similarly, many national NHS policy initiatives are driven primarily not by QALY gain, but by ‘process-of-care’ and other considerations. The DH is required to undertake and publish Impact Assessments (IAs) identifying the costs and benefits expected from all new policy implementation. We analyse all IAs carried out in 2008-2009 to identify the benefits considered by the DH as relevant to its decision making. METHODS: The stated benefits of each policy were extracted from the relevant IA. A combination of methods was used to categorise these. RESULTS: 51 IAs were analysed, 8 of which mentioned QALY gains as a benefit. 162 benefits other than QALY gains were identified. Apart from improving health outcomes, common types of benefit included reducing costs, improving quality of care, and enhancing patient experience and empowerment. CONCLUSIONS: Many of the policies reviewed were implemented on the basis of benefits unrelated to health outcome. The methods being used to apply a monetary valuation to QALY gains (in IA cost-benefit calculations) are not consistent across IAs, or with NICE’s stated threshold range. We consider the implications for NHS decision making and NICE guidance, and the meaning of allocative efficiency in the NHS.