Considerations When Using ICER's Value Assessments

A physician meets with a veteran.

This week we read with great interest an article posted on the Health Affairs Blog that directly responded to National Pharmaceutical Council Chief Science Officer Dr. Robert Dubois’ Sept. 17 commentary expressing our concerns about the partnership between the U.S. Department of Veterans Affairs Pharmacy Benefits Management (PBM) Services and the Institute for Clinical and Economic Review (ICER).

The article, written by VA PBM staff, sheds light on how the VA intends to use ICER’s value assessment framework in their work to “promote access to high-value drugs.” They note that ICER’s assessments are just one part of their process, and outline the VA's efforts to utilize real-world evidence, encourage high-value care and use many different data inputs, such as factors that are important to veterans and their families, as key considerations in their health care coverage decision-making. All of these are positive considerations, and we appreciate the clarity they provide in the article.

However, we need to point out that NPC has been engaged on the issue of value assessment and with ICER for several years, focusing on defining and assessing value in a patient-centered way. Our concerns, as we have clearly expressed in numerous blog posts and comments to ICER, are with the ICER framework’s underlying methodologies, including the budget threshold impact and heavy focus on the health system perspective, among others. Value assessments should be one among many inputs in health care decision-making, and hopefully, as the VA asserts, the ICER value assessment will be among a variety of those inputs and not a sole deciding factor. We would welcome a broader dialogue with VA on these issues.

As we’ve noted previously, “Value assessment frameworks have the potential to be effective tools for advancing patient care and achieving better clinical, economic and humanistic outcomes. Used effectively, frameworks could provide transparency and enhance the use of value in the VA decision-making process.” We believe that can still be the case. That’s why it’s important to be aware of the limitations with ICER's and other frameworks so they can be used and considered appropriately, in conjunction with other inputs.