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The role of NICE, and of the NICE committee, in the evaluation of health technologies
Marta Soares, Senior Research Fellow, Centre for Health Economics Kuopio, Finland, August 2018 (some of the slides developed by Susan Griffin)
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Outline About NICE Technology Appraisal NICE Committee
Value judgements Decisions Only in Research Impact of NICE
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About NICE
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Role of NICE in England and Wales
Established in 1999 to: Reduce unwarranted variation Set quality standards Accelerate uptake of good value innovation (mandatory funding) Ensure additional resources are spent efficiently
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“Probably not, but it’s worth a bloody good try.”
Will NICE work? “Probably not, but it’s worth a bloody good try.” Frank Dobson, Health Secretary, who established NICE in 1999, when asked whether he thought it would work.
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Role of NICE in England and Wales
Established in 1999 to: Reduce unwarranted variation Set quality standards Accelerate uptake of good value innovation (mandatory funding) Ensure additional resources are spent efficiently Considerations Comparative clinical effectiveness Cost-effectiveness - £/QALY (£20-30k threshold) Social values and equity impact Issues Only select technologies appraised No direct role in price setting or negotiation (indirect influence via patient access schemes) Multiple stakeholders/highly political
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NICE….what is it now ? The National Institute for Health and Care Excellence (NICE) provides national guidance and advice to improve health and social care It does this by: Producing evidence-based guidance and advice for health, public health and social care practitioners. Developing quality standards and performance metrics for those providing and commissioning health, public health and social care services; Providing a range of information services for commissioners, practitioners and managers across the spectrum of health and social care.
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Centres & support services
Clinical Practice Clinical Guidelines Medicines and Prescribing Centre Safe staffing guidelines Health Technology Evaluation Technology Appraisals Surgical interventions Devices and Diagnostics PASL Scientific Advice R&D Health & Social Care Quality Standards NICE pathways Prevention Accreditation Public involvement Implementation Business, Planning & resources NICE International The MPC (formerly the NPC) will take over responsibility for the BNF contract. NHS Evidence is a service that enables access to authoritative clinical and non-clinical evidence and best practice through a web-based portal. It helps people from across the NHS, public health and social care sectors to make better decisions as a result. Evidence Resources Communication Evidence Resources Communication 8
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Incorporating consideration of relevant social value judgements
Drug development Under controlled conditions and compared to placebo: Is the drug safe? Does the drug do more good than harm? Regulatory approval In routine clinical practice and compared with existing treatments: Do the additional clinical benefits justify the expected additional cost? NICE/HTA Use in healthcare system Incorporating consideration of relevant social value judgements
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Technology Appraisals
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NICE Technology Appraisals
Technology appraisal one branch of NICE Entails assessment of clinical and cost effectiveness of health technologies Medicines, surgical procedures, medical devices, diagnostic techniques, health promotion activities NICE decision carries legal mandate Ensure all patients have access to cost-effective treatments
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Topic selection Only issue guidance for selected technologies
Topics identified by DH based on: Health benefit across all patients for whom it is indicated Impact on NHS resources if given to all eligible patients Impact on other outcomes of interest, e.g. health inequalities Inappropriate national variation in use Institute able to add value by issuing national guidance
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Defining the scope Sets out the decision problem
The disease area, patients, technologies covered by the appraisal and the questions it aims to answer Intervention and comparators Must be licensed for use in UK Ideally include current NHS practice Indication(s) Scope may be narrower than license Identifies consultees Clinical and patient groups, manufacturers and comparator manufacturers
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Evaluation of health technologies
Single Technology Appraisal (STA) Evaluation undertaken by company Critiqued by independent academic centre (Evidence Review Group) Multiple Technology Appraisal (MTA) Evaluation by independent academic centre (Assessment Group) Additional evaluations invited from manufacturers Fast Track Appraisal (FTA) Less resource-intensive, NHS funding within 30 calendar days of guidance Company base case ICER<£10,000 and most plausible ICER<£20,000 Simple cost comparison if ≥ health benefits & ≤ cost compared to existing NICE recommended technologies for same indication NICE and ERG determine eligibility with consultee input NICE technical team provide report to Committee
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Reference Case “Because the methodology of technology appraisal continues to develop, there remain areas of controversy and uncertainty, particularly in relation to the methods of cost-effectiveness analysis. However, it is important that the methods used to inform the Appraisal Committee's decision-making are consistent. For this reason, the Institute has adopted the approach of using a 'reference case' for cost-effectiveness analysis; this was chosen as most appropriate for the Appraisal Committee's purpose” Describes preferred methods Supported by Decision Support Unit Technical Support Documents
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Reference Case (Cost-Effectiveness)
Use of the QALY central Health service perspective for costs Reference case is prescriptive and generic No intention to limit methods development of innovative techniques Reference case ≠ standardisation
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NICE Appraisal Process
Independent Assessment reports Patient organisation submissions Manufacturer submissions Appraisal committee Expert witnesses Professional submissions Patient witnesses 17
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Appraisal committee
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Technology Appraisal Committee
Independent advisory committee drawn from: Academia, NHS, patient and carer organisations, manufacturers Reflect spread of interests and expertise Tasks Consider evidence Come to conclusions about cost effectiveness Come to conclusions about impact on other outcomes of interest (e.g. health inequalities) Follow NICE’s principles on appropriate threshold (end of life, uncertainty) Issue guidance
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Committees in action Four TAC, meet once per month
Discuss up to six topics in one day Most appear over at least two meetings Documents sent out in advance Seen early by NICE, chair, vice chair, lead team Prepare pre-meeting briefing (PMB) Documents include final scope, PMB, submissions from company(s), submission from independent academic centre, consultee comments
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Public gallery for Part 1
Committee meeting Public gallery for Part 1 12-24 Committee members NICE staff Clinical and patient experts (not ATA) Manufacturer Independent academic centre
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Evidence considered Prior to the meeting At the meeting
Submissions from company(s) and independent academic group Consultees comments At the meeting Opportunity to put questions to experts, manufacturers and independent academic centre Clinical and patient expert testimony
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Role of Committee Consider generalisability to NHS in England and Wales Come to conclusions about most appropriate value judgements, analytical choices, assumptions Request further evidence Lead team to ERG/AG in advance of meeting Questions during meeting Specify further analyses during committee meetings Form guidance
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Value judgements subjective statement of opinion rather than a fact that can be tested by looking at the available evidence. Normative statements are subjective statements – i.e. they carry value judgments
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Value judgements When conducting economic evaluation we are required to make a series of value judgements Scope sets out decision problem but may not define population for CEA NICE Reference Case (methods guides) sets out preferred approach but is not exhaustive Further, evaluation may depart from scope and/or methods guide
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Who should make value judgements?
The results can be sensitive to these What evidence is ‘relevant’ How does evidence relate to setting (generalisability) How should we combine the evidence using decision model (structural uncertainty) How should we analyse the evidence (model uncertainty) Committee must form a view about most appropriate approach and on what impact on the ICER will be if approach inadequate
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Considerations EVIDENCE SCOPE What subgroups are relevant?
Are presented subgroups valid? Are comparators represented? Patients Comparators EVIDENCE Has appropriate evidence been characterised in economic evaluation? How does evidence relate to UK? Baseline risk Clinical effectiveness Health related quality of life Resource use METHODS Has Ref Case been followed? Is model structure appropriate? Have parameter values been estimated appropriately? Statistical analysis Decision model
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Value judgements - scope
Why might evaluation depart from scope? Clinical trials for interventions include only subset of population Company targets high risk subgroup Comparators not used in certain patients Characterisation of comparator E.g. best supportive care, current practice, watchful waiting Dose/schedule differs from that used in practice
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Value judgements - evidence
Clinical trials conducted outside UK Clinical trial does not match license Which trials to include Other evidence from different settings Evidence out of date
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Value judgement - methods
Departure from Reference Case should only occur if unavailable Reference Case cannot cover all options Often no ‘right’ answer E.g. Survival analysis for extrapolation Scientific approach but no statistical test Structure of decision model
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Decisions
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Conclusions What is most plausible ICER?
Across whole population In subgroup(s) Is current evidence sufficient? What is appropriate threshold? Range £20-£30,000 Do End of Life criteria apply? Survival extension > 3 months for life expectancy < 24 months Threshold up to £50k
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Decisions Decision reached by consensus MTA process
Anonymous vote only if consensus not reached MTA process Evaluate set of mutually exclusive alternatives Yes to one implies no to others Single Technology Appraisal and ATA Evaluate single product Recommended as an option No decisions about cost-effectiveness of other comparators
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Types of decisions Recommend Optimise Only in research
In line with marketing authorisation NHS legally obliged to fund and resource within 3 months as standard Optimise Recommended only in subgroup of licensed population Only in research Recommended for use within CDF Not recommended
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Only in Research Requires judgement that
Current evidence insufficient Reasonable prospect of technology being CE On balance benefits outweigh cost of research Complex considerations at end of assessment of cost effectiveness Committee not routinely provided with supporting evidence Value of information Feasibility and costs of further research
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NICE vs. research funders
Secretary of State for Health Funding Topic selection National Institute for Health Research (NIHR) Health Technology Assessment Programme Commissioned academic team Assessment NICE Secretariat Technology Appraisal Committee Appraisal Topic referral Topics Technology Assessment Report Guidance to the NHS and implementation initiatives The Health Technology Assessment (HTA) programme, set up in 1993, is part of the National Institute for Health Research (NIHR) and is the largest single national research programme for the NHS. It funds the production of independent research information about the effectiveness, costs and broader impact of healthcare treatments and tests for those who plan, provide or receive care in the NHS. Technology Assessment reports are commissioned by the HTA programme on behalf of NICE to inform its national clinical guidance to the NHS. Assessment reports are prepared by on-contract academic or specialist centres within the UK. HTA spend by the NIHR in 2010/11 = £49.7 million Adapted from Walley, T. (2007) MJA; Overview of Health technology assessment in England: assessment and appraisal187: 283–285 36
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Cancer Drugs Fund Requires judgement that
Current evidence insufficient Reasonable prospect of technology being CE Managed Access Scheme agreed between company and NHS England Data Collection Arrangement to detail evidence required CDF Commercial Agreement to determine price Drug becomes available immediately in CDF while further evidence is collected Further data collection not necessarily via CDF Review in approximately 2 years
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Consultation YES – Recommended and within license requires no consultation In all other cases Appraisal Consultation Document issued for consultation Consider responses and further analyses and/or evidence at second meeting Ultimately issue guidance Opportunity for appeal Failed to act fairly or exceeded powers Decision is perverse in light of evidence submitted
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Impact of NICE
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NICE decisions 1 March 2000 to 31 March 2018 Recommendation categories
Single Technology Appraisal Multiple Technology Appraisal Total Recommended 165 (50%) 270 (61%) 435 (56%) Optimised 88 (27%) 88 (20%) 176 (23%) CDF 13 (4%) - 13 (2%) Only in Research 5 (2%) 23 (5%) 28 (4%) Not Recommended 58 (17%) 60 (14%) 118 (15%) 329 (100%) 441 (100%) 770 (100%) Up to 31 March 2018, EoL was considered in 115 pieces of guidance, of which 59 resulted in positive recommendations. 142 Patient Access Schemes in place 40
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Impact of NICE Independent body Rationing made explicit and public
Hitting the headlines “Betrayal of 20,000 cancer patients: Rationing body rejects ten drugs (allowed in Europe) that could have extended lives” Opportunity for public to take part Consultation View Committee meeting
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Impact of NICE on health
In principle approve technology only if generate more health than displaced Evidence suggests this is not the case and ICERs>£30k not rejected Dakin et al. Health Economics 2014; Further, empirical threshold may be lower than £20-£30,000 range Claxton et al. Health Economics 2015;24(4):1-7
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Some references and websites
BBC Documentary ‘The Price of Life’ Claxton K, et al. Informing a decision framework for when NICE should recommend the use of health technologies only in the context of an appropriately designed programme of evidence development. Health Technol Assess 2012;16(46) Collins M, Latimer N. NICE’s end of life decision making scheme: impact on population health. BMJ 2013;346:f1363 Dakin H, et al The influence of cost-effectiveness and other factors on NICE decisions. DOI: /hec.3086', Health Economics Claxton K, et al. Causes for concern: is nice failing to uphold its responsibilities to all nhs patients? Health Econ 2015;24:1-7
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The role of NICE, and of the NICE committee, in the evaluation of health technologies
Marta Soares, Senior Research Fellow, Centre for Health Economics Kuopio, Finland, August 2018
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