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 Treatment-Resistant Depression (TRD). The letter offers criticism of ICER's model for inaccurately accounting for the cost burden of TRD, as well as ICER's misleading estimates on mortality rates associated with the disease. Chairman Coelho encouraged ICER to abandon discriminatory value assessment metrics such as the Quality-Adjusted-Life-Year (QALY), and instead focus on outcomes that truly matter to patients. "As the National Alliance on Mental Illness (NAMI) highlighted in its November comment letter to ICER, individuals with treatment resistant depression (TRD) are in desperate need of treatments that offer fast, effective relief," wrote Chairman Coelho. "The ICER model fails to capture the value of the treatment’s immediate impact. For patients, the ability to quickly get back to work and their families is invaluable."
In a letter to the Institute for Clinical and Economic Review (ICER), Partnership to Improve Patient Care (PIPC) Chairman Tony Coelho offered feedback on ICER's draft evidence report
on a treatment for Secondary Progressive Multiple Sclerosis (SPMS). The letter aligns with the National Multiple Sclerosis Society's position that ICER should discontinue the current review for siponimod due to the FDA approval for siponimod and the subsequent approval for cladribine, meaning that ICER’s scope of its draft evidence report is no longer sufficient. "ICER has once again missed the mark by showing callous disregard for patients," wrote Chairman Coelho. "Instead of working to engage with MS patients and taking their preferences and needs into consideration in evaluating a treatment designed for MS patients, ICER instead has chosen to rely on dated studies and mechanisms that are widely considered flawed."
The Partnership to Improve Patient Care (PIPC) submitted a comment letter to the Innovation and Value Initiative (IVI) on their first oncology-specific Open-Source Value Platform (OSVP) model focused on non-small cell lung cancer (NSCLC). PIPC Chairman Tony Coelho complimented the detail and comprehensiveness of the IVI's model, noting the tremendous value that open-source models offer. However, Chairman Coelho strongly encouraged IVI not to utilize the flawed quality-adjusted-life-year metric in its multi-criteria decision analysis (MCDA) component. "As QALYs are assigned by both quality as well as quantity of life, an incremental QALY assessment would prioritize providing treatment to a non-disabled population with a longer theoretical life expectancy, and otherwise perfect health, over a population with a disability or chronic condition," wrote Chairman Coelho. "It is our hope that IVI chooses to be innovative in moving beyond the QALY."
As detailed in a recent letter from PIPC, CancerCare, and over 40 other advocacy organizations, there is widespread opposition to the use of third party value assessments, especially those relying on quality-adjusted-life-years (QALYs) and similar metrics, as the basis for denying or restricting access to care in the State of New York. The letter makes clear that patients and people with disabilities oppose one-size-fits-all definitions of value being used to create arbitrary thresholds in state healthcare systems, especially when they rely on discriminatory methods, such as the quality-adjusted-life-year (QALY).
The Partnership to Improve Patient Care (PIPC) has released a public opinion poll by Morning Consult regarding the use of cost-effectiveness assessments to determine value of coverage and treatment costs. The survey demonstrates that voters resoundingly reject the main tenets of cost-effectiveness analyses with 82 percent of American voters objecting to their use in determining health care coverage and reimbursement decisions. These types of measures, which are often used outside of the U.S. to limit patient access to medicines, have been frequently criticized as discriminatory by patients and persons with disabilities. Increasingly, policymakers and payers have proposed to use these same tools to limit coverage for Medicare and Medicaid beneficiaries.
Click here to view a blog post and infographic on the poll by PIPC Chairman Tony Coelho.
The Partnership to Improve Patient Care (PIPC) has joined CancerCare and cadre of leading advocacy organizations in a letter demonstrating widespread opposition to the use of third party value assessments, especially those relying on quality-adjusted-life-years (QALYs) and similar metrics, as the basis for denying or restricting access to care in the State of New York. The letter signed by over 40 organizations made it clear that patients and people with disabilities oppose one-size-fits-all definitions of value being used to create arbitrary thresholds in state healthcare systems, especially when they rely on discriminatory methods, such as the quality-adjusted-life-year (QALY).
PIPC Encourages Senate HELP Committee to Pursue Patient-Centered Approaches to Lower Health Care Costs
In a letter to Senate Health, Education, Labor, and Pensions (HELP) Chairman Lamar Alexander, PIPC Chairman Tony Coelho outlined several patient-centered policy approaches aimed at facilitating informed decision-making and reducing health care costs. Specifically, Chairman Coelho listed: (1) reauthorization of the Patient-Centered Outcomes Research Institute (PCORI); (2) avoiding the use of QALYs or similar value metrics; and (3) empowering patients to make informed health care decisions as avenues to pursue when considering policies to lower health care costs. "Health care stakeholders – ranging from patients, providers, and innovators – understand that a value-based health care system that truly supports advancements in personalized and individualized medicine must be built on a foundation of patient-centeredness," wrote Chairman Coelho. Patient-centered, evidence-based health care can lower overall spending by ensuring patients are able to receive timely treatment that is right for them, avoiding downstream costs, and improving patient outcomes."
PIPC Submits Comment Letter to ICER on International Collaborative to Develop New Methods to Guide Value-Based Pricing of Potential Cures
In a letter to the Institute for Clinical and Economic Review (ICER), the Partnership to Improve Patient Care (PIPC) offered suggestions to ICER on the development of new methods to guide value-based pricing of potential cures. The letter encourages ICER to acknowledge the long-term health benefits and cost savings resulting from curative therapies, and work with foreign collaborators to develop more patient-centered methods for value assessment that do not impede access. "While there is no single alternative method that succeeds on all domains at present, we are encouraged that several other organizations and approaches are underway in developing value assessment models that better reflect principles of patient-centeredness," wrote PIPC Chairman Tony Coelho. "We applaud ICER for recognizing the need to improve affordability for patients, and hope you take this opportunity to learn from the ongoing efforts of others to develop patient-centered methods for value assessment that incorporate a range of evidence to determine coverage and care decisions, and reject a single, one-size-fits-all measure of value."
In a comment letter to the Department of Defense (DoD), Partnership to Improve Patient Care (PIPC) offered feedback on the interim final rule concerning the TRICARE Pharmacy Benefit Programs. The letter encourages DoD to avoid adopting "one-size-fits-all" value metrics, and promote a TRICARE program that mitigates discrimination against people with disabilities and serious chronic conditions.“…We recommend the creation of an infrastructure for patient and beneficiary engagement in uniform formulary development under Tricare, to give members of the military and their families a voice in the determination of the value of treatments under the program, and throughout Tricare,” wrote PIPC Chairman Tony Coelho. “We also recommend the incorporation of incentives for health care providers to use shared decision-making tools and decision aids that will enhance the ability for patients and their physicians to assess the highest value treatment for that individual patient. In this way, Tricare can deliver on the intent of this program to deliver high value care by arming beneficiaries with information to improve health decisions instead of putting hurdles in front of the care they need.”
PIPC joined organizations representing patients, people with disabilities, family members, caregivers, veterans, seniors, providers, and others in response to the Advance Notice of Proposed Rulemaking released by the Center for Medicare & Medicaid Services (CMS) to utilize an “International Pricing Index” (IPI) to set reimbursement for medicines in Medicare Part B. The letter highlights concerns that this new policy would import QALY-based standards to key U.S. health programs. "Addressing health care costs, including drug prices, is an important and meaningful effort that should center on achieving outcomes that matter to those being served by health systems (patients, people with disabilities, veterans, seniors and other marginalized communities) such as improved quality of care and lower out-of-pocket costs," the letter states. "We are hopeful the Administration will reconsider their plan to import international cost-effectiveness standards into the U.S. and instead advance patient-centered, non-discriminatory approaches and establish meaningful protections for our communities in future demonstrations."