Was It Worth Introducing Health Economic Evaluation of Innovative Drugs in the French Regulatory Setting? The Case of New Hepatitis C Drugs

Coverage and Pricing Recommendations of the French National Health Authority for Innovative Drugs: A Retrospective Analysis From 2014 to 2020

OBJECTIVES

This study provides a retrospective analysis of the recommendations of the French National Health Authority on the reimbursement and pricing of innovative drugs.

METHODS

The analysis includes drugs subjected to both economic and clinical evaluations in France from 2014 to 2020. Ordered logistic and quantile regressions are used to estimate the factors associated with the clinical value (SMR), the clinical added value (ASMR), and the incremental cost-utility ratio (ICUR) of innovative drugs. All variables used in the regression analyses are extracted from the Clinical and Economic Opinions for the 146 observations.

RESULTS

Regression analyses indicate that 2 of the 5 official criteria, the efficacy-adverse events balance of the drug and its function, are significantly associated with the SMR rating. The ASMR is positively associated with the disease severity, the quality-adjusted life-year (QALY) gain provided by the drug, and the validation of the ICUR in the Economic Opinion. At the first quartile of the ICUR distribution (approximately €50 000/QALY), higher ICUR levels are observed for drugs with a smaller target population and for drugs claimed as more innovative. Higher ICUR levels are also observed for pediatric drugs and for drugs with no therapeutic alternative at the third quartile of the distribution (approximately €240 000/QALY).

CONCLUSIONS

Not all official criteria of the SMR are associated with actual ratings obtained. Regarding the ASMR, the results support the idea of a convergence between the 2 independent clinical and economic appraisal processes. Finally, the factors influencing the ICUR level vary across the distribution of ICUR.

Challenges raised by the economic evaluation of CAR-T-cell therapies. The review by the French National Authority for Health

Since 2013, the process of pricing of innovative drugs by the French National Health Insurance has considered both cost-effectiveness and budget impact. CAR-T cell therapies were first subject to economic evaluation from 2019 in France. We aim to describe the process and results of the economic evaluation of tisagenlecleucel and axicabtagene ciloleucel as well as the challenges these evaluations raised. Evaluations submitted by the firms were reviewed by HAS and submitted to the Committee of Economic Evaluation and Public Health (CEESP). The CEESP issued opinions related to: (1) the methodological quality of economic evidence and, (2) the cost-effectiveness and budget impact of the drugs. The CEESP invalidated the estimated incremental cost-utility ratios (ICUR) of tisagenlecleucel due to the insufficient clinical evidence and methodological quality to extrapolate the long-term progression of the disease after treatment and compare tisagenlecleucel with alternatives. The CEESP concluded that tisagenlecleucel was not proven cost-effective. The estimated ICUR of axicabtagene ciloleucel at €114,509/QALY vs. chemotherapies was associated with an acceptable level of methodological quality despite being based on a weak indirect comparison and limited data on quality of life. The CEESP considered axicabtagene ciloleucel ICUR to be "very high" and questioned the societal/community willingness-to-pay of the claimed price. The primary source of uncertainty surrounding the ICUR estimates of both drugs was the lack of hindsight on effectiveness. The economic evaluation of CAR-T cell therapies highlights the risk of inefficient resource allocation driven by limited clinical data. It calls for payment schemes accounting for this risk and effective collection of post-marketing data.