The National Health Council (NHC) is pleased to provide comments on the Institute for Clinical and Economic Review’s (ICER) solicitation for feedback on the, “Value Assessment Methods for Single or Short-Term Transformative Therapies (SSTs).” Founded in 1920, the 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 diverse, 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.
We envision a society in which all people have access to quality health care that respects personal goals and aspirations and is designed around the patient experience to promote their best possible health outcomes. We agree with ICER that methods adaptations are necessary for value assessment of SSTs.
Many of these new therapies have the potential to cure or substantially modify diseases, giving patients hope of a better life. They also come with significant upfront costs with the potential for significant downstream savings. Unfortunately, the organization that pays for the treatment today will rarely be the organization that realizes the future savings without innovative contracting and financing mechanisms. Thus, traditional value assessment may not truly capture the value of products with longer-term, downstream advantages, creating the need for adapted approaches. Therefore, we appreciate ICER’s effort to capture these issues and provide suggested solutions.
Below, we provide our comments on the set of proposed adaptations and recommendations to ICER the proposals. Our comments follow the organization of ICER’s August 6, 2019 document.