Managed entry agreements for pharmaceuticals: the european experience
HTA and beyond: Risk sharing
agreements
Mexico City, 7 November 2014
Advance-HTA Capacity building workshop
Increasing cost of new medicines Presence of a significant degree of uncertainty
at the time of making coverage decisions
Need for innovative solutions to make new
drugs available while ensuring the long-term financial sustainability of healthcare systems
Constructing RSAs – Likely sources of uncertainty
• Uncertainty around clinical evidence
More robust clinical evidence is needed about who is likely to benefit
• Uncertainty around cost-effectiveness
Average cost-effectiveness is higher than country's WTP
• Uncertainty around budget impact
Budget impact is too high if all potentially eligible patients are
• Uncertainty around price
Not clear how pricing strategy results in a price that is significantly
• Uncertainty around eligible patient population
Not clear who is likely to benefit most
Not clear how many patients exist in this indication
Risk Sharing and Managed Entry Agreements
• Uncertainty around clinical evidence
More robust clinical evidence is needed about who is likely to benefit
• Uncertainty around cost-effectiveness
Average cost-effectiveness is higher than country's WTP
• Uncertainty around budget impact
Budget impact is too high if all potentially eligible patients are
• Uncertainty around price
Not clear how pricing strategy results in a price that is significantly higher
Uncertainty around eligible patient population
Not clear who is likely to benefit most
Not clear how many patients exist in this indication
Combination
Financial
Options flow diagram
Insurer adopts: no new
Insurer adopts with
Insurer refuses to
evidence required
additional evidence
Manufacturer has
option to reapply
negotiation. No pre-
with more evidence
specified agreement
Use only in research
Source: Adapted from Towse, 2011
Coverage with Evidence Development
• Product is covered or reimbursed when used
under controlled circumstances:
– RCTs – Utilisation Management Schemes (UMS) – Evidence-providing Registries
– Coverage of CRC agent by Medicare via RCT and
– Coverage of prostate cancer "vaccine" by Medicare
via building evidence-providing registry
Conditional Coverage
• Price and reimbursement are (temporary)
granted but failure to achieve set targets can result in price and reimbursement changes and/or rebates
– Pfizer on statins in the UK – France: Acomplia
Outcome Guarantee
• Rebates or free product are given by the
manufacturer when outcomes are not achieved for individual patients
• Presupposes ability to monitor eligible
• Example: Bortezomib case in UK through NICE
Price and Volume (Budget) Agreements
• Agree a price for a specific volume • A penalty is foreseen when a new drug is overshooting a pre-
set budget (PxQ)
• Penalty can take the form of
– Rebate or payback – Lower price for volume above agreed limit – Lower future price
• Variety of payback clauses
– Supplier is fully accountable – Prescriber and supplier are jointly accountable – Rebate/Payback to be shared among suppliers
• Examples: Australia, France, Italy, Austria, Portugal
Risks addressed by individual scheme types
Main objectives of MEAs
BI: Budget impact CE: Cost-effectiveness
Source: Ferrario & Kanavos, 2013
Common elements of MEAs
PVAs: Price-volume agreements pp: per person
Source: Ferrario & Kanavos, 2013
Therapeutic classes
ATC groups (according to ATC-index 2011)
A: Alimentary tract and metabolism
B: Blood and blood forming organs
C: Cardiovascular system
D: Dermatologicals
G: Genito urinary system and sex hormones
H: Systemic hormonal preparations,
excl. sex hormones and insulins
J: Anti-infectives for systemic use
L: Antineoplastic and immuno-modulating
agents
M: Musculo-skeletal system
N: Nervous system
R: Respiratory system
S: Sensory organs;
V: Various
ATC_Mix: There was one case in Italy where a
particular AIFA-note contained medicines from
different ATC-groups.
Source: Ferrario & Kanavos, 2013
The average duration of MEAs varies between
EU Member States, ranging from one year in Belgium (renewable) to up to four years in the Netherlands or for an indefinite period of time subject to review (France, Malta, UK).
Main instruments linked to MEAs
Examples of instruments used
Sales and expenditure
Total: 198
databases
Patient registries
Total: 119
-
Czech Republic: 21
Total: 64
Online systems for
Total: 11
Actors involved in implementing MEAs
Main stakeholders involved
• Insurers, drug assessment agencies, and physicians
Responsibility for negotiating the agreement with the
• Insurers (e.g. NIHDI in Belgium), drug assessment agencies
(e.g. AIFA in Italy, TLV in Sweden) or DoH (UK)
Responsibility for filling in the patient registries
• Physicians usually in collaboration with other stakeholders
(e.g. monitoring registries in Italy are managed by AIFA; an advisor physician from the National Health Insurer controls the implementation of MEAs in Belgium)
Responsibility for data provision
• Manufacturers
Taxonomy: A framework for analysing
and evaluating MEAs
Managed entry schemes
Financial schemes
Performance-based agreements
Total cost
Total cost per
Utilisation in the
Evidence regarding
real life
decision uncertainty
patients
Performance based
Coverage with evidence
development
Discounts
guarantees
Utilisation
Patient
elegibility with
conditional
treatment
continuation
Initial discount
Treatment interruption if drug
Discount or free doses
Reimbursement if drug
is not effective according to
after the agreed
free initial doses
is not effective
pre-established targets
threshold is reached
Reassessment which may
Discount if drug is
Cap on number of doses/total
lead to price change,
not effective or
cost reimbursed per patient
conclusion of new
less effective than
after which the manufacturer
agreements, or new
assumes the cost
reimbursement decision
Negotiating a MEA from an insurer's perspective:
Value Proposition
A strong Value Proposition will be insurer-centric
in nature, and will contain compelling evidence that – Showcases all dimensions of value (medical/therapeutic-, patient
reported outcome- and economic benefits)
– Reflects the full impact of the innovation to insurers and HTAs and – Translates the clinical profile into a compelling cost/effectiveness
• Using comprehensive and good quality evidence Leveraging critical value dimensions with a view
to constructing tailor-made RSA plans
Insurer-centric Value Proposition (1)
• Critical elements that insurers may require include:
– Differentiation relative to standard of care
Although superiority might be shown against BSC
on all primary- and secondary endpoints, it may
deter payers from considering the improvement as
being major
– Relevant comparator (head-to-head)
A placebo-controlled trial is often seen as a
weakness. Payers prefer to see H2H trials. In the
absence of H2H data payers would need to see
data for detailed indirect comparison across the
primary and secondary endpoints that incorporate
any difference in trials.
Insurer-centric Value Proposition (2)
– Quality of evidence
Example overall survival: The non-significant claim on
overall survival will negatively impact the value
perception. Without a clear statistical superiority claim for
overall survival, insurers will consider new therapies at
most comparable to existing ones despite new therapies
showing considerable additional benefits on other
attributes
– Data collection
If time horizon is not long enough to capture full clinical-
and economic impact of disease insurers may demand
long-term (real life) data
– Comparative efficacy/effectiveness
Measures of effect in "real-life" conditions: Clinical- and
cost effectiveness data in real-world vs. a clinical setting
– Cost effectiveness data
Additional evidence requirements
• Insurers may require additional data besides the pivotal trial
results through follow up studies or registries in order to
reduce uncertainties including
H2H comparative data that demonstrate better any treatment
Data that reflect (more) statistically significant outcomes (e.g.
Address uncertainties in clinical-and cost effectiveness in real
world (e.g. PRO metrics)
Collect real world (effectiveness) data
Value is multi-dimensional…
Comparative presentation of value drivers: A checklist
Drug 1 vs. Drug 2
Value drivers
Efficacy
Overall Survival (OS)
Overall Survival (OS)
Skeletal Related Effects (SRE)
Skeletal Related Effects (SRE)
Objective Response Rate (ORR)
Radiographic Progression Free Survival (rPFS)
Modified Progression Free Survival (mPFS)
Biomarker Response
Time to treatment discontinuation (TTTD)
Patients proportion
Radiographic Progression Free Survival (rPFS)
Patient proportion free of
Biomarker Progression
Patient proportion free of
Skeletal Related Effects (SRE)
Biomarker Progression
Innovation
Mechanism of Action (MoA)
Patient convenience
Special instructions
Direct medical costs
Outpatient visits
Cost effectiveness
Cost minimisation
Health Insurer's Point of View
Health Insurers may be willing to confirm the content of the
Value Proposition or willing to build their own version
reflecting or adjusting for their own perspective.
• Most of the data should be available through the peer
review literature
• -If not published their credibility might be questioned • -Insurers might conduct their own systematic literature review(s) to • ensure all critical evidence is incorporated
• Other sources might be required for the collection of real
world effectiveness data and resource use (cost of illness)
• Registries and observational studies •
Shape volume expectations
Volume expectations
Expectations on volume are needed to inform
• Follow-on products: epidemiological data on
disease prevalence should be available
• -WHO, CDC, national databases, peer review literature
• First-in-class: data on disease prevalence might
not be available
• -Conduct primary data collection activities such as • observational and descriptive studies, e.g. national registries
Performance based RSAs
Choose clinically meaningful endpoints that are
• Objective • Patient/disease relevant • Operational (i.e. practical and measurable) • "Cheap" to monitor • Can be monitored within a specified amount of time
Potential endpoints include biomarker response
to treatment (i.e. response rate), biomarker
progression following treatment (i.e. disease
progression), radiographic exams, etc.
Financial based RSAs
Simpler than performance based agreements Make use of confidential discounts between the
manufacturer and the payer
Sales cap based on price-volume agreement Based on the grounds of budget impact
Potential options include the application of single
discounts, multiple discounts (e.g. 100% discount for the first 3 mo, 50% discount for the next 3 mo, ending up paying full price), and revenue or sales caps
Source: http://www.advance-hta.eu/PDF/MexicoWorkshop/Presentations/16-HTA-and-Beyond.pdf
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