Our feedback to ICER on the NSCLC scoping document is intended to contribute our company’s perspective on the value that Immuno-Oncology agents, such as Opdivo, provide to patients impacted by NSCLC. We encourage ICER to incorporate the points we outlined in our response, including:
- Removing the evaluation of PD-1 inhibitors for the treatment of first-line NSCLC from scope due to lack of randomized clinical data in this population among all manufacturers included in the review
- Accounting for patients with driver mutations in the analysis
- Separating assessments by histology (squamous and non-squamous) to account for difference in responses to treatment
- Reflecting consistent and relevant patient populations among product comparisons
- Maintaining consistency regarding long-term treatment duration assumptions (despite the lack of clinical trial stopping rules)
- Including indirect measures of value (like quality of life) in the modeled assessment
- Fully and proactively disclosing ICER’s modeling approach
- Excluding budget impact in the assessment as it is not a measure of patient value
