The National Health Council (NHC) is pleased to provide comments on the Institute for Clinical and Economic Review’s (ICER) solicitation for comments on the proposed 2020 Value Assessment Framework update. Founded in 1920, the National Health Council (NHC) brings diverse organizations together to forge consensus and drive patient-centered health policy. The NHC provides a united voice for the more than 160 million people with chronic diseases and disabilities and their family caregivers. Made up of more than 125 national health-related organizations and businesses, the NHC's core membership includes the nation’s leading patient advocacy organizations, which control its governance and policy-making process. Other members include health-related associations and nonprofit organizations including the provider, research, and family caregiver communities; and businesses representing biopharmaceutical, device, diagnostic, generic, and payer organizations.
The NHC appreciates the opportunity to comment on ICER’s proposed changes to its 2020 framework. We believe that while much progress has been made in recent years, there is still significant work needed to be done to fully integrate the patient voice into value assessment.
In response to ICER’s proposed value framework updates, the NHC has the following suggestions and comments to ensure the framework is truly patient centered. We note and appreciate that several proposed changes are responsive to our comments submitted on June 10, 2019. Under the general topic areas below, we also offer recommendations on how to strengthen the 2020 framework and provide specific comments on particular sections of the proposed updates.