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Assessing innovation of end-of-life treatments
             appraised by NICE

                     Presenting Author: Adam Hutchings1
    Co-Authors: Michael Harris2, Louisa Pericleous2, Anthony Batty3,
    Andrew Briggs4, Anne Prenzler5, Michael Lees2, Max Lebmeier2


   1. GMAS, London, UK 2. Bristol-Myers Squibb, Uxbridge, UK 3. Bresmed, Sheffield, UK
             4. University of Glasgow, UK 5. University of Hannover, Germany
Background (1)


      •      European governments have created sophisticated rules, assessment mechanisms
             and negotiation processes to determine the selling terms of new medicines.
      •      These systems constitute a ‘reward framework’ to incentivise manufactures to
             research drugs of value to society
      •      Innovation is frequently considered to be a key attribute to be encouraged
      •      In the UK, encouraging innovation is part of the remit of NICE1
      •      NICE has stipulated that higher ICER thresholds are acceptable for ‘step-change’
             innovations2:


                   ‘The innovative nature of the technology, specifically if the innovation adds
                      demonstrable and distinctive benefits of a substantial nature which may
                           not have been adequately captured in the QALY measure.’ (NICE
                                                                            Methods Guide)


1.   NHS. Directions and Consolidating Directions to the National Institute for Health and Clinical Excellence. 2005 http://www.nice.org.uk/niceMedia/pdf/DirectionFromSecretaryOfState2005.pdf
2.   National Institute for Health and Clinical Excellence. Guide to the methods of technology appraisal. June 2008.
Background (2)


      •       This is evident in NICE’s ‘End of Life’ guidance issued in 20091
      •       In situations where all of the criteria described below are met, Appraisal Committees
              can chose to recommend the use of treatments outside the Institute’s normal ICER
              threshold

                 End of Life Criteria                                                                        Definition
                                                         The treatment is licensed or otherwise indicated, for small patient
                Rarity
                                                         populations

                Alternative                              No alternative treatment with comparable benefits is available
                treatment                                through the NHS

                                                         The treatment is indicated for patients with a short life expectancy,
                Life expectancy
                                                         normally less than 24 months

                                                         There is sufficient evidence to indicate that the treatment offers an
                Survival benefit                         extension to life, normally of at least an additional 3 months,
                                                         compared to current NHS treatment


1.   National Institute for Health and Clinical Excellence. Appraising life-extending, end of life treatments. January 2009.
Study Objectives


1. To explore how in practice NICE has recognised innovation within the End of Life
   guidance

2. To identify which aspects of innovation NICE is rewarding within the End of Life
   guidance

3. To examine the nature of the relationship between the appraisal decision and the
   degree to which products are deemed to meet the End of Life criteria
Study Methods


•   Review of all End of Life drugs appraised by NICE between January 2009 until April
    2012
•   Data for each criteria collected for each drug from NICE Guidance documents
                                                        Metric
         Rarity      •   Number of eligible patients in England and Wales




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Results: End of Life treatments
              Drug                                                            Indication                                                  Base Case ICER                           ICER Range‡                            NICE Decision

           Sunitinib                   First line advanced/metastatic renal cell carcinoma (RCC)                                                 £49,300                      £49,300 - £105,000                                Positive

       Lenalidomide                               Relapsed/refractory multiple myeloma (MM)                                                      £43,800                      £ 22,589 - £69,000                                Positive

                                          Second line advanced/metastatic renal cell carcinoma
          Sorafenib                                                                                                                              £65,929                       £65,929 -£368,830                               Negative
                                                                (RCC)
       Temsirolimus                    First line advanced/metastatic renal cell carcinoma (RCC)                                                £102,000                      £49,690- £253,443                                Negative

           Sunitinib                                 Gastrointestinal stromal tumours (GIST)                                                     £31,800                       £27,365 - £90,500                                Positive

     Topotecan (oral)                       Second line relapsed small cell lung cancer (SCLC)                                                   £33,851                       £26,833 - £33,900                                Positive

         Trabectedin                          Second line advanced soft tissue sarcoma (STS)                                                     £34,500                       £28,712 – £80,000                                Positive

          Sorafenib                        First line advanced hepatocellular carcinoma (HCC)                                                    £52,600                       £28,105 - £76,592                               Negative

                                       Maintenance for advanced/metastatic non-small cell lung
        Pemetrexed                                                                                                                               £47,000                      £33,732 - £105,826                                Positive
                                                         cancer (NSCLC)
       Ofatumumab*                     Relapsed/refractory Chronic lymphocytic leukaemia (CLL)                                                   £60,500                       £24,635 - £81,500                               Negative

       Trastuzumab                             First line IHC3+ metastatic gastric cancer (GC)†                                                  £45,000                      £37,180 to £99,797                                Positive

          Pazopanib                                    Advanced renal cell carcinoma (RCC)                                                       £38,900                      £21,625 to £72,274                                Positive

                                       Intermediate/high-risk myelodysplastic syndromes (MDS);
         Azacitidine                    chronic myelomonocytic leukaemia (CML); acute myeloid                                                    £47,200                       £32,823 - £71,522                                Positive
                                                            leukaemia (AML)

         Everolimus                                   Second line renal cell carcinoma (RCC)                                                     £51,700                       £33,749- £253,051                               Negative

        Trabectedin*                         Relapsed, platinum-sensitive ovarian cancer (OC)                                                    £94,800                      £24,869 - £113,432                               Negative
         Ipilimumab                                            Malignant melanoma (MMel)                                                         £59,456                                      -                                     TBC

†IHC3 positive patients only; *Trabectedin in OC and Ofatumumab in CLL were – considered ‘marginal’ for fulfilling End of Life criteria when interpreted strictly; ‡ Range of plausible ICERs under different scenarios quoted by NICE in guidance
Results: Rarity

                                                 Estimated size of eligible patient population in UK 1

                                                                 Positive decision
                                                                 Negative decision




1.   All data obtained from NICE Guidance documents for respective appraisal
Results: Life Expectancy

                                                                                             NICE estimate of patient prognosis
                Pivotal Study Control Arm Survival                        1
                                                                                             based upon expert advice1




                                                                               Positive decision
1.   All data obtained from NICE Guidance documents for respective appraisal   Negative decision
Results: Survival Benefit


   •     Median and mean survival benefit was                          Ratio of survival benefit / control arm life survival 1
         higher for those End of Life treatments
         recommended by NICE compared with those
         that were not recommended.

   Survival gain                                           Not
                           Recommended*
     months                                           Recommended*

       Median                  4.7 (7.35)                  2.4 (3.5)

       Mean                        4.3                          1.7
           *Numbers in brackets account for adjustment for crossover



   •     Survival benefit relative to control survival
         appeared to show a relationship with NICE
         decision

   •     Adjusting for patient crossover created
         greater uncertainty around survival benefit




*In trials where patients didn’t cross between treatment arms
Results: Other Variables


•   Availability of alternative treatments: all End of Life treatments met criteria, even
    when existing treatments available (e.g pazopanib and sunitinib)
•   Duration of survival data available at the time of the NICE appraisal varied from 10
    months (everolimus) to 56 months (ipilimumab).
•   Duration of data at the time of NICE appraisal appears potentially relevant to the
    decision, with those recommended by NICE having an average of 43 months of data
    at the time of the appraisal vs 22 months for those rejected.
•   Trial design and comparator choice were not obviously associated with NICE
    appraisal decision: of the two treatments with only uncontrolled data, one had been
    accepted (trabectedin in STS) and one rejected (ofatumumab).
•   A strong association was seen between the ICER level and the NICE decision, with
    products with ICER > £50,000 per QALY more likely to be rejected than those with
    ICERs <£50,000.
Conclusions and Discussion


•   End of Life guidance recognises innovation and informs on the elements that
    constitute innovation
•   NICE currently taking dichotomous approach to End of Life criteria, with no evident
    relationship between the extent to which drugs meet the criteria and the ICER
    threshold
•   Rarity and availability of alternative treatments appear less important in determining
    decision
•   Criteria that appear most important in determining decision are:
     – Base case ICER
     – Life expectancy in patient population
     – Additional survival benefit
•   Relative survival benefit – additional survival over control arm survival – also
    appeared to show a trend between those products that were accepted versus
    rejected

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Assessing innovation of end-of-life treatments appraised by NICE

  • 1. Assessing innovation of end-of-life treatments appraised by NICE Presenting Author: Adam Hutchings1 Co-Authors: Michael Harris2, Louisa Pericleous2, Anthony Batty3, Andrew Briggs4, Anne Prenzler5, Michael Lees2, Max Lebmeier2 1. GMAS, London, UK 2. Bristol-Myers Squibb, Uxbridge, UK 3. Bresmed, Sheffield, UK 4. University of Glasgow, UK 5. University of Hannover, Germany
  • 2. Background (1) • European governments have created sophisticated rules, assessment mechanisms and negotiation processes to determine the selling terms of new medicines. • These systems constitute a ‘reward framework’ to incentivise manufactures to research drugs of value to society • Innovation is frequently considered to be a key attribute to be encouraged • In the UK, encouraging innovation is part of the remit of NICE1 • NICE has stipulated that higher ICER thresholds are acceptable for ‘step-change’ innovations2: ‘The innovative nature of the technology, specifically if the innovation adds demonstrable and distinctive benefits of a substantial nature which may not have been adequately captured in the QALY measure.’ (NICE Methods Guide) 1. NHS. Directions and Consolidating Directions to the National Institute for Health and Clinical Excellence. 2005 http://www.nice.org.uk/niceMedia/pdf/DirectionFromSecretaryOfState2005.pdf 2. National Institute for Health and Clinical Excellence. Guide to the methods of technology appraisal. June 2008.
  • 3. Background (2) • This is evident in NICE’s ‘End of Life’ guidance issued in 20091 • In situations where all of the criteria described below are met, Appraisal Committees can chose to recommend the use of treatments outside the Institute’s normal ICER threshold End of Life Criteria Definition The treatment is licensed or otherwise indicated, for small patient Rarity populations Alternative No alternative treatment with comparable benefits is available treatment through the NHS The treatment is indicated for patients with a short life expectancy, Life expectancy normally less than 24 months There is sufficient evidence to indicate that the treatment offers an Survival benefit extension to life, normally of at least an additional 3 months, compared to current NHS treatment 1. National Institute for Health and Clinical Excellence. Appraising life-extending, end of life treatments. January 2009.
  • 4. Study Objectives 1. To explore how in practice NICE has recognised innovation within the End of Life guidance 2. To identify which aspects of innovation NICE is rewarding within the End of Life guidance 3. To examine the nature of the relationship between the appraisal decision and the degree to which products are deemed to meet the End of Life criteria
  • 5. Study Methods • Review of all End of Life drugs appraised by NICE between January 2009 until April 2012 • Data for each criteria collected for each drug from NICE Guidance documents Metric Rarity • Number of eligible patients in England and Wales • T h e a v a i l a b i l i t
  • 6. Results: End of Life treatments Drug Indication Base Case ICER ICER Range‡ NICE Decision Sunitinib First line advanced/metastatic renal cell carcinoma (RCC) £49,300 £49,300 - £105,000 Positive Lenalidomide Relapsed/refractory multiple myeloma (MM) £43,800 £ 22,589 - £69,000 Positive Second line advanced/metastatic renal cell carcinoma Sorafenib £65,929 £65,929 -£368,830 Negative (RCC) Temsirolimus First line advanced/metastatic renal cell carcinoma (RCC) £102,000 £49,690- £253,443 Negative Sunitinib Gastrointestinal stromal tumours (GIST) £31,800 £27,365 - £90,500 Positive Topotecan (oral) Second line relapsed small cell lung cancer (SCLC) £33,851 £26,833 - £33,900 Positive Trabectedin Second line advanced soft tissue sarcoma (STS) £34,500 £28,712 – £80,000 Positive Sorafenib First line advanced hepatocellular carcinoma (HCC) £52,600 £28,105 - £76,592 Negative Maintenance for advanced/metastatic non-small cell lung Pemetrexed £47,000 £33,732 - £105,826 Positive cancer (NSCLC) Ofatumumab* Relapsed/refractory Chronic lymphocytic leukaemia (CLL) £60,500 £24,635 - £81,500 Negative Trastuzumab First line IHC3+ metastatic gastric cancer (GC)† £45,000 £37,180 to £99,797 Positive Pazopanib Advanced renal cell carcinoma (RCC) £38,900 £21,625 to £72,274 Positive Intermediate/high-risk myelodysplastic syndromes (MDS); Azacitidine chronic myelomonocytic leukaemia (CML); acute myeloid £47,200 £32,823 - £71,522 Positive leukaemia (AML) Everolimus Second line renal cell carcinoma (RCC) £51,700 £33,749- £253,051 Negative Trabectedin* Relapsed, platinum-sensitive ovarian cancer (OC) £94,800 £24,869 - £113,432 Negative Ipilimumab Malignant melanoma (MMel) £59,456 - TBC †IHC3 positive patients only; *Trabectedin in OC and Ofatumumab in CLL were – considered ‘marginal’ for fulfilling End of Life criteria when interpreted strictly; ‡ Range of plausible ICERs under different scenarios quoted by NICE in guidance
  • 7. Results: Rarity Estimated size of eligible patient population in UK 1 Positive decision Negative decision 1. All data obtained from NICE Guidance documents for respective appraisal
  • 8. Results: Life Expectancy NICE estimate of patient prognosis Pivotal Study Control Arm Survival 1 based upon expert advice1 Positive decision 1. All data obtained from NICE Guidance documents for respective appraisal Negative decision
  • 9. Results: Survival Benefit • Median and mean survival benefit was Ratio of survival benefit / control arm life survival 1 higher for those End of Life treatments recommended by NICE compared with those that were not recommended. Survival gain Not Recommended* months Recommended* Median 4.7 (7.35) 2.4 (3.5) Mean 4.3 1.7 *Numbers in brackets account for adjustment for crossover • Survival benefit relative to control survival appeared to show a relationship with NICE decision • Adjusting for patient crossover created greater uncertainty around survival benefit *In trials where patients didn’t cross between treatment arms
  • 10. Results: Other Variables • Availability of alternative treatments: all End of Life treatments met criteria, even when existing treatments available (e.g pazopanib and sunitinib) • Duration of survival data available at the time of the NICE appraisal varied from 10 months (everolimus) to 56 months (ipilimumab). • Duration of data at the time of NICE appraisal appears potentially relevant to the decision, with those recommended by NICE having an average of 43 months of data at the time of the appraisal vs 22 months for those rejected. • Trial design and comparator choice were not obviously associated with NICE appraisal decision: of the two treatments with only uncontrolled data, one had been accepted (trabectedin in STS) and one rejected (ofatumumab). • A strong association was seen between the ICER level and the NICE decision, with products with ICER > £50,000 per QALY more likely to be rejected than those with ICERs <£50,000.
  • 11. Conclusions and Discussion • End of Life guidance recognises innovation and informs on the elements that constitute innovation • NICE currently taking dichotomous approach to End of Life criteria, with no evident relationship between the extent to which drugs meet the criteria and the ICER threshold • Rarity and availability of alternative treatments appear less important in determining decision • Criteria that appear most important in determining decision are: – Base case ICER – Life expectancy in patient population – Additional survival benefit • Relative survival benefit – additional survival over control arm survival – also appeared to show a trend between those products that were accepted versus rejected