Critique of ICER’s Special Assessment to Inform CMS Drug Price Negotiation: Eliquis and Xarelto

That is the title of a new FTI Consulting white paper co-authored with Kyi-Sin Than. The abstract is below.

In October 2023, ICER released a special assessment aimed at influencing CMS drug price negotiations for two direct-acting oral anticoagulants (DOACs) selected in the first round of Inflation Reduction Act (IRA) price negotiations in 2024: Eliquis® (apixaban) and Xarelto® (rivaroxaban), both indicated for treating patients with non-valvular atrial fibrillation (NVAF). Our evaluation found that ICER’s approach suffered from six key limitations:

ICER relied on the equal value of life years (evLY) gained framework, which does not
fully consider morbidity improvements of new treatments.ICER evaluated treatment benefits from a narrow perspective, ignoring broader value
to society.ICER did not take into account the value Eliquis® and Xarelto® brought to individual
patients and paid limited attention to IRA special population subgroups.ICER evaluated treatment value based on a single indication, despite DOACs
demonstrating health benefits for multiple patient populations across various
indications.ICER failed to incorporate the benefits of improved patient convenience as well as how
convenience could help alleviate health inequities.ICER considered a narrow evidence base, ignoring real-world evidence studies which
could inform real-world treatment value.

These methodological gaps highlight the need for a more inclusive and multidimensional
evaluation framework that better aligns with patient-centered care, societal values, and
equitable objectives as set forth by the IRA.

You can read the full white paper here.