The Partnership to Improve Patient Care (PIPC) submitted a comment letter to the Institute for Clinical and Economic Review (ICER) on its draft evidence report for bladder cancer treatments. PIPC Chairman Tony Coelho criticized ICER for continuing to conduct studies prematurely, as well as assessing the value-based price of these drugs in the absence of sufficient evidence. Chairman Coelho also noted that the mixed data sources for measures of effectiveness in the report are likely to lead to biased estimates in ICER's model. "Bladder cancer can present many challenges to a patient’s quality of life, and there are currently very few treatment options for patients with high-risk non-muscle invasive bladder cancer that is unresponsive to BCG," wrote Chairman Coelho. "It is critical that new treatments are evaluated carefully when there is appropriate available evidence."

As healthcare costs in the United States have continued to grow, there has been an increasing desire to move towards “value-based” care in which patients and payers would be paying for the “value” of the treatment patients receive. This idea has been gaining particular momentum as policymakers look for strategies to curtail spending on pharmaceuticals. While there is merit in paying for services and treatments that work and eliminating wasteful spending, it is important to step back and consider to whom “value” is being provided. As the ultimate beneficiary, we would advocate that the measure of “value” in a healthcare setting should focus on value to the patient, but currently, we are concerned that the trend is to look towards “value” to the payer by prioritizing reduced cost over care outcomes for patients in the form of cost-effectiveness analyses. 

​Cell and gene therapies (C&GTs) are revolutionary advancements that offer potentially life-altering therapies – and in some cases even cures – for patients with rare and severe diseases. Around the globe, various health technology assessment (HTA) and value assessment organizations are attempting to estimate the health and economic value of new C&GTs to better inform healthcare decision making. These organizations most commonly employ cost-effectiveness analysis (CEA), which seeks to determine whether the costs of a given therapy are justified by its benefits; that is, whether it is a “good buy.”

Tony Coelho sent a personal letter to the National Academies of Sciences, Engineering, and Medicine to amplify the comments submitted by the disability community in response to the Discussion Draft of the Preliminary Framework for Equitable Allocation of COVID-19 Vaccine, commissioned by the Centers for Disease Control and the National Institutes of Health. He stated, "In my experience as a longtime disability rights advocate and an original of the Americans with Disabilities Act, I view this as a process that is aligned with our mantra of 'Nothing About Us Without Us' and therefore urge you to outreach directly to our disability community as you wrestle with difficult questions related to vaccine allocation even after the comment deadline.” He highlighted letters submitted by the Consortium for Citizens with Disabilities, the Association of University Centers on Disabilities, the American Association of People with Disabilities, and Not Dead Yet.

In a letter to the Institute for Clinical and Economic Review (ICER), Partnership to Improve Patient Care (PIPC) Chairman Tony Coelho provided feedback on ICER’s draft evidence report for Ulcerative Colitis (UC) treatments. Chairman Coelho criticized ICER for its use of the quality-adjusted-life-years (QALY) metric, noting that ICER fails to capture the true meaning of “value” for patients in its assessment. The letter also knocks ICER for neglecting to account for the heterogeneity of the UC patient population. “UC is a condition that impacts a very heterogeneous patient population, and treatment can vary greatly from patient to patient,” wrote Chairman Coelho. “For this reason, it is imperative that ICER account for this heterogeneity within its model and consider improving its methods.”

In a letter to the Institute for Clincial and Economic Review (ICER), Partnership to Improve Patient Care Chairman (PIPC) Chairman Tony Coelho provided feedback on ICER's draft evidence report for Non-alcoholic Steatohepatitis (NASH). Chairman Coelho criticized ICER's model for continuing to rely on the discriminatory quality-adjusted-life-years (QALY) metric, writing that it is an inappropriate metric to accurately show health gains for NASH patients. The model also makes inaccurate assumptions about liver transplant procedures. "ICER’s model exacerbates the shortcomings of the QALY by discounting the future health gains incorrectly," the letter states. "NASH is a complex condition, and it is important ICER holistically capture the complexity and the impact the disease has on individual patients and public health."

More than 50 leading groups representing patients and people with disabilities joined the Partnership to Improve Patient Care’s (PIPC) comment letter to the Institute for Clinical and Economic Review (ICER) regarding its assessment of remdesivir and other treatments for the novel coronavirus (COVID-19). The letter offers strong criticism of ICER’s use of flawed methodologies in its assessment, noting that ICER has chosen to completely ignore vast array of stakeholder feedback it has received over the last five years on its framework and processes. The groups reiterate that it’s imperative that discriminatory assessment tools like the quality-adjusted-life-years (QALY) metric are not used in determining the price of treatments, especially during public health emergencies such as COVID-19. “We have consistently raised the red flag that ICER’s value assessments are methodologically flawed and not fit for the purpose of making decisions related to coverage, reimbursement and incentive programs by policymakers and payers,” the letter states. “ The latest assessment from ICER validates our concerns.”

More than 60 leading patient advocacy and disability groups signed onto the Partnership to Improve Patient Care’s (PIPC) outreach letter to the Institute for Clinical and Economic Review’s (ICER) new Vice President for Patient Engagement Yvette Venable. The undersigned groups applauded the creation of this new position, and look forward to working with Ms. Venable to ensure that ICER develops and implements a robust patient engagement framework. “As organizations that have worked across the spectrum of health care – including life sciences innovation, payer decision-making and value assessment – with missions to improve the quality of life for patients and people with disabilities, we hope that you will engage with us and take advantage of our real-world patient engagement experiences and lessons learned,” the letter states. “Do not hesitate to reach out to us and to the experts in this field described above as you consider patient engagement frameworks that may be fit for use within ICER.”

​In a letter to the Patient-Centered Outcomes Research Institute (PCORI), Partnership to Improve Patient Care (PIPC) Chairman Tony Coelho offered input on the next 10 years of PCORI. Chairman Coelho framed PIPC’s recommendations around three core principles: relevance, timeliness, and trust. Specifically, he encouraged PCORI to: (1) create a national agenda for research priorities; (2) expand collection of and access to patient-centered outcomes; (3) advance use of patient-centered outcomes in value assessment; and (4) promote patient-centered methodologies. “This is a crucial moment to build on PCORI’s success for another 10 years,” wrote Chairman Coelho. “Success, we believe, will entail effectively connecting PCORI and its research strengths to the current, pressing needs of our health care system and the patients and caregivers it serves.