ICER Watch: Where Is the Patient?
Andrea Ferris, President and Chairman of LUNGevity Foundation, writes that LUNGevity does not normally provide comments on these types of documents, however, they felt it important as an organization representing patients to weigh in on this report. Ferris writes, “ICER models could potentially be used as the basis for CMS reimbursement, and we need to ensure that patients have a voice in what is important to them.”
Among LUNGevity’s concerns with the ICER scoping document:
- Patients and lung cancer clinicians were not included in the development of the scoping document and it therefore does not reflect or represent how treatments are being used or what patients value.
- No differentiation by histology—while both non-small cell lung cancer, patients with squamous histology may respond differently than adenocarcinoma
- Lung cancer is not one cancer—subpopulations need to be addressed—you cannot evaluate lung cancer as a whole. It is a collection of rare diseases. Clinical trials are designed to address a homogeneous population so variables can be minimized, but they can fail to address the changing treatment environment and the changing biology of the disease.
- Does not take into account the rapidly changing field of lung cancer treatments including sequencing of drugs or combinations that are now being studied. The scoping document and resulting report will not reflect how medicine is being practiced now or in the future. Furthermore, the comparators being used may no longer be reflective of the comparisons or tradeoffs that HCPs are making with determining a treatment regimen for their patient.
This section of the Daily Rise has been updated from an earlier version to represent the correct views and tone of LUNGevity’s letter to ICER.