NPC Submits Comments to Institute for Clinical and Economic Review on Its Value Assessment Framework

NPC Submits Comments

The National Pharmaceutical Council (NPC) today submitted comments to the Institute for Clinical and Economic Review (ICER) about ways to improve its value assessment framework. Among our detailed and constructive comments, NPC highlighted the need for the following changes:

  • Full transparency and reproducibility of economic models
  • Formal inclusion of patient-centered factors into the framework so they can be meaningfully considered in the value assessment
  • A reevaluation of the appropriateness and approach to budget impact assessment and its relevance in calculating value-based price benchmarks
  • Elimination of the “alarm bell” threshold, which does not involve a comprehensive consideration of the health care system, does not consider societal values, and does not adequately measure affordability

As NPC has noted, value assessments are a new and evolving field, and potentially can have a tremendous impact on patient access to needed and innovative treatments. Given that the field is in its infancy, more work remains to be done before ICER—or other frameworks—are ready for widespread adoption and use by stakeholders. Since one framework cannot meet the needs of all stakeholders, we look forward to continuing to have constructive dialogues with all developers to evolve value frameworks in a thoughtful, inclusive and patient-centered way.

View NPC's comments (PDF).

NPC also will bring together health care stakeholders on September 29 in Washington, DC, for a conference, “Assessing Value: Promise and Pitfalls,” to explore value assessment frameworks. View the agenda and register for the conference on NPC’s website.