ICER stated, "To succeed in our mission, we constantly listen to patients and other stakeholders. This draft contains proposed updates to our Value Assessment Framework that are a direct result of the thoughtful input we have received, and of our ongoing conversations with all stakeholders.”
Despite the conciliatory language, nothing's changed. It's all smoke and mirrors and process, a me-too version of ICER's anti-patient framework. Cuba has changed more under Raul Castro.
The update proposals will be open to further public comment for 60 days. But it doesn’t take even 6 hours to see that ICER’s clever combination of confusing statistics, assumptions and price controls remain dangerous and discriminatory.
1. ICER will to ignore the value of new medicines to employers, caregivers, families, and patients.
2. ICER will continue to use the quality-adjusted life year (QALY) to measure the value of treatment for all patients. A QALY, often used in the UK where the availability of cancer therapeutics is limited by cost, equals one year in perfect health. That means anyone who is ill is measured as LESS than a QALY, diminishing the value of their treatment. ICER uses the QALY, despite acknowledging that the QALY can vastly underestimate and devalue the quality of life and ignores patient perspectives.
3. ICER claims that estimating rebates taken off of list drug prices will more accurately reflect cost. It ignores the fact that rebates are pocketed by the PBMs and insurers funding ICER. So under ICER's framework, health plans and PBMs pocket rebates and the out of pocket share of the list price of a drug that patients must pay.
4. ICER still maintains that given the additional benefit these new drugs provide is worth no more than $150, 000 for each additional year of life, an arbitrary ceiling on the cost of new therapeutics, no matter how much they achieve.
6. ICER still assumes health systems shouldn't spend more than $900 million a year on each new medicine without cutting spending somewhere else.
7. ICER still assumes that new drugs will drive up insurance costs and crowd out pothole repair. In fact, new medicines reduce the cost of treating disease over time and promote greater productivity and tax revenue. New therapeutics can save money AND save lives!
In short, ICER is therefore still a tool for discriminating against the sick. The new ICER is the bad old ICER: