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."