Methodological problems in the method used by IQWiG within early benefit assessment of new pharmaceuticals in Germany

The Organic Turn: Coping With Pandemic and Non-pandemic Challenges by Integrating Evidence-, Theory-, Experience-, and Context-Based Knowledge in Advising Health Policy

The COVID-19 pandemic has posed an extraordinary challenge for public health and health policy. Questions have arisen concerning the main strategies to cope with this situation and the lessons to be learned from the pandemic. This conceptual paper aims to clarify these questions via sociological concepts. Regarding coping strategies used during the pandemic, there is a strong tendency for health policymakers to rely on expert knowledge rather than on evidence-based knowledge. This has caused the evidence-based healthcare community to respond to urgent demands for advice by rapidly processing new knowledge. Nonetheless, health policymakers still mainly rely on experts in making policy decisions. Our sociological analysis of this situation identified three lessons for coping with pandemic and non-pandemic health challenges: (1) the phenomenon of accelerating knowledge processing could be interpreted from the organizational innovation perspective as a shift from traditional mechanistic knowledge processing to more organic forms of knowledge processing. This can be described as an "organic turn." (2) The return of experts is part of this organic turn and shows that experts provide both evidence-based knowledge as well as theoretical, experiential, and contextual knowledge. (3) Experts can use theory to expeditiously provide advice at times when there is limited evidence available and to provide complexity-reducing orientation for decisionmakers at times where knowledge production leads to an overload of knowledge; thus, evidence-based knowledge should be complemented by theory-based knowledge in a structured two-way interaction to obtain the most comprehensive and valid recommendations for health policy.

The impact of additive or substitutive clinical study design on the negotiated reimbursement for oncology pharmaceuticals after early benefit assessment in Germany

BACKGROUND

We analysed the impact of clinical study design for oncological pharmaceuticals on the subsequent price negotiations after early benefit assessment between pharmaceutical companies and the German National Association of Statutory Health Insurance Funds. The analysis was conducted for all oncology pharmaceuticals that underwent the early benefit assessment in Germany since its introduction in 2011 up to September 2016.

METHODS

It was differentiated between additive (new therapy in addition to baseline therapy) and substitutive study designs (baseline therapy to be replaced). The study design was derived from the dossiers of the pharmaceutical companies submitted to the Federal Joint Committee. Subgroup specific costs in case of granted added benefit were calculated as annual therapy costs and compared with the costs of the appropriate comparators to quantify price premiums. Further price influencing factors were analysed in univariate and multivariate regression analysis considering the budget impact for the statutory health insurance as well.

RESULTS

The mean and the median of the additive premiums for substitutive designs (€50,477.68 and €49,841.24) were higher than for additive designs, if the comparator was different to best supportive care (€48,750.00 and €42,820.44). The mean multiplicative premium for the substitutive designs was 15.07 versus 2.29 for the additive designs. EU-Prices and target population size had a significant effect on the reimbursement. The adjusted R-square in the log Premium OLS-regressions reached 0.708 when including all explanatory variables and considering interaction between target population and annual costs of the comparator.

CONCLUSIONS

Study design as an additional important influencing factor of the negotiations next to those stated in the framework agreement was identified and verified. Therefore, study design should be considered by pharmaceutical companies and by decision makers and payers within strategic price planning as a potential predictor. For some specific categories the number of cases was small. Further analyses should be performed when more oncology pharmaceuticals have passed the early benefit assessment.

Different interpretation of additional evidence for HTA by the commissioned HTA body and the commissioning decision maker in Germany: whenever IQWiG and Federal Joint Committee disagree

BACKGROUND

The purpose of this study was to analyse the impact of commissioned addenda by the Federal Joint Committee (FJC) to the HTA body (IQWiG) and their agreement with FJC decisions and to identify potential additional decisive factors of FJC.

METHODS

All available relevant documents up to end of 2017 were screened and essential content extracted. Next to descriptive statistics, differences between IQWiG and FJC were tested and explored by agreement statistics (Cohen's kappa and Fleiss' kappa) and ordinal logistic regression.

RESULTS

Most of the 90 addenda concerned oncological products. In all contingent comparisons, positive changes in added benefit or evidence level on a subpopulation basis (n = 124) prevailed negative ones. Fleiss' ordinal kappa for agreement of assessments, addenda, and appraisals reached a moderate strength for added benefit (0.474, 95%-CI, 0.408-0.540). Overall agreement between addenda and appraisals on a binary nominal basis is poor for added benefit (Cohen's kappa 0.183; 95%-CI: 0.010-0.357) ranging from "less than by chance" (respiratory diseases) to "perfect" (neurological diseases). The OR of the selected regression model showed that i) mortality, ii) unmet need, the positions of iii) the physicians' drug commission and iv) medical societies, and v) the annual therapeutic costs of the appropriate comparative therapy had a high influence on FJC's appraisals deviating from IQWiG's addenda recommendation.

CONCLUSIONS

IQWiG's addenda have a high impact on decision-maker's appraisals offering additional analyses of supplementary evidence submitted by the manufacturers. Nevertheless, the agreement between addenda and appraisals varies, highlighting different decisive factors between IQWiG and FJC.

Varying results of early benefit assessment of newly approved pharmaceutical drugs in Germany from 2011 to 2017: A study based on federal joint committee data

BACKGROUND

Since January 2011, the Federal Joint Committee (FJC) conducts early benefit assessments (EBA) of newly approved pharmaceutical drugs compared to appropriate standard therapies. The FJC commissions the Institute for Quality and Efficiency in Healthcare (IQEH) to prepare preliminary reports. We aimed to evaluate the extent, impact, and reason for different judgments on added benefit of both institutions.

METHODS

We searched EBA data on the FJC website and included completed procedures from 2011 to 2017. We conducted a quantitative analysis of the difference between FJC and IQEH on divergent judgments, a quantitative analysis of the impact of EBA on market withdrawal, and a qualitative analysis to identify potential factors contributing to divergent judgments.

RESULTS

FJC rated an added benefit in 30% (139 of 457) and IQEH in 22% (101 of 457) matching research questions (P = 0.004). In the aftermath of EBA, 28 pharmaceutical drugs were withdrawn from the German market. We identified three potential factors that might have contributed to the divergent judgments. IQEH used a unique threshold concept to define the rating, FJC conducted additional public hearings, and FJC showed more flexibility with adherence to stringent criteria and interpretation of results.

CONCLUSIONS

FJC and IQEH differed significantly in their early benefit assessment. In response to negative EBA decisions, pharmaceutical companies withdrew a considerable number of medicines from the German market. The present work uncovers the subjectivity and possible variance inherent in benefit assessment, as the two institutions observe the same rules of procedure.