That is the title of a new FTI Consulting white paper co-authored with Kyi-Sin Than. The abstract is below.
In October 2023, ICER released a special assessment aimed at influencing CMS drug price negotiations for two direct-acting oral anticoagulants (DOACs) selected in the first round of Inflation Reduction Act (IRA) price negotiations in 2024: Eliquis® (apixaban) and Xarelto® (rivaroxaban), both indicated for treating patients with non-valvular atrial fibrillation (NVAF). Our evaluation found that ICER’s approach suffered from six key limitations:
- ICER relied on the equal value of life years (evLY) gained framework, which does not
fully consider morbidity improvements of new treatments. - ICER evaluated treatment benefits from a narrow perspective, ignoring broader value
to society. - ICER did not take into account the value Eliquis® and Xarelto® brought to individual
patients and paid limited attention to IRA special population subgroups. - ICER evaluated treatment value based on a single indication, despite DOACs
demonstrating health benefits for multiple patient populations across various
indications. - ICER failed to incorporate the benefits of improved patient convenience as well as how
convenience could help alleviate health inequities. - ICER considered a narrow evidence base, ignoring real-world evidence studies which
could inform real-world treatment value.
These methodological gaps highlight the need for a more inclusive and multidimensional
evaluation framework that better aligns with patient-centered care, societal values, and
equitable objectives as set forth by the IRA.
You can read the full white paper here.
