Latest ICER Report Relies on Incomplete Evidence, Inadequate Analyses

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When making health care policy decisions, it’s crucial to rely on sound, high-quality data and evidence as the basis for those decisions. That’s why it’s troubling to see a new report from the Institute for Clinical and Economic Review (ICER) that used incomplete evidence and inadequate analyses.

ICER admits in its “Unsupported Price Increase” report that its analysis is incomplete and that it cannot conduct a formal review of therapies and their prices: “ICER does not have the capacity to perform full economic analyses on the nine therapies evaluated in this report, nor would the time needed to develop full ICER reports (at least eight months) provide information in a useful timeframe for the public and policymakers.”

Simply put, if it cannot conduct a formal economic review, then ICER cannot accurately assess whether the price of a therapy was fair—or even underpriced--in the first place. While ICER labels some price increases as “unsupported by new clinical evidence,” it is not within scope to evaluate whether some are “supported” by new clinical evidence, making this a one-sided, biased report.

In most cases, ICER also did not conduct broader searches for relevant studies and clinical information about the handful of medicines it chose to review, limiting the types of evidence included in its analysis. While ICER set an unreasonably high bar for the types of evidence it would consider, it set a low bar for the pricing data it utilized.

The ICER report is a snapshot in time, focusing only on individual therapies in a two-year period. Instead, the report should provide a longer view of how prices, costs and health spending fluctuate over years. Peer-reviewed studies have shown that therapies can be cost-effective over the long-term, particularly if they improve a patient’s quality of life and reduce hospital stays.

It’s important to understand that there are multiple drivers of health spending, and we are not minimizing the role of pharmaceuticals. But finger-pointing and micro-focusing on one aspect of health care are not conducive to having a broader dialogue or getting to the root of health spending issues.

Even worse, flawed information can lead to flawed policy decisions, and that won’t benefit patients or society.