ASH Clinical News ACN_4.13_full issue_Web | Page 64

FEATURE Drug Prices and tisagenlecleucel, which may provide long-term value for patients but have high prices that drive up health-care costs in the short term. With its reports, ICER hopes to pub- licize these questions and develop policy recommendations for health-care stake- holders. In the case of CAR T-cell therapies, the agency suggested that pharmaceutical manufacturers, insurers, and providers meet prior to FDA approval to discuss a drug’s potential role in therapy and payment ar- rangements. This partnership would “reduce unnecessary delays in delivering care to patients by addressing financial uncertain- ties for insurers and providers.” 15 “Without federal government nego- tiations over drug prices, we have to be honest and more responsible when talking about drug prices and how they relate to the value of the drug because we want to create incentives that reward companies for creating drugs that help patients,” Dr. Pearson said. “Yet we can’t continue to have increasing drug prices and just assume that the system can absorb them. That is not going to work.” Innovative Drug-Pricing Schemes When Novartis first launched tisagenle- cleucel for pediatric ALL with a $475,000 price tag, the drug company also an- nounced an “outcomes-based” payment model: CMS would not pay for tisagenle- cleucel unless the patient responds to the treatment within 30 days of administra- tion. 16 Yet, one year later, CMS backed out of the outcomes-based payment deal without a public explanation. This value-based pricing model that prices a drug based on its direct benefit to a patient is one solution to relieve the ever- increasing anxiety about drug prices in the U.S. “The beauty of value-based pricing is that, if the drug is priced in accordance with value and the benefit it confers to a patient, then everyone should be able to have access to it,” Ms. Kaltenboeck said. She would like to see more manu- facturers engage in value-based pricing, particularly for anticancer drugs. “We should know how much a patient and the health-care system are paying and how much benefit a patient experiences. In our system, drugs are continually priced up, and, tragically, patients get priced out.” Ms. Kaltenboeck is seeing more health-care stakeholders exploring value- based pricing but acknowledged that this kind of innovation will likely come in small, incremental steps. Companies such as Regeneron and Novartis have priced several of their new drugs in line with ICER’s recommendations. Novartis, after receiving a second FDA approval for tisagenlecleucel for the treatment of adults with large B-cell lymphoma, priced the therapy at $373,000 – lower than the $475,000 price tag for the pediatric ALL indication – because the efficacy gains are not as pronounced for the adult popu- lation. This pricing scheme is the first example of a type of value-based pricing called indication-based pricing. Still, both manufacturers and insur- ance companies are hesitant to engage in value-based pricing. “Drug companies typically have not been very excited about this scheme because of the risk of not get- ting paid; payers typically just want drug companies to lower their prices because they don’t want to deal with the complexi- ties of tracking patients’ outcomes,” said Dr. Lakdawalla. A Call for Transparency A central issue in the drug-pricing debate is transparency – which is lacking in the U.S. “Drug and insurance companies want rules that apply to everyone equally and that are transparent and will sustain an innovative health-care system,” said Dr. Pearson, but that’s not likely to happen. “With no regulation by the government, the U.S. has created a bit of a monster: It’s not a system that truly rewards drug value. The consequence is that patients are the ones who suffer from high prices that trickle down to them.” Dr. Lakdawalla agreed. “The issue is figuring out how to align price with value. Prices are completely unmoored from value and the first step is to create a more transparent pricing system.” The argument for maintaining con- fidential rebates is that “not everyone in the system can receive the rebate, and publicizing it would create a situation where everyone would want to receive the same discount, which drug companies wouldn’t be able to provide,” Dr. Lak- dawalla explained. Unfortunately, the U.S. drug-pricing system has become opaque, he noted. “With so little transparency, it is diffi- cult for employers buying health care to make decisions about how much to pay for drugs because they have no idea how much individual drugs cost.” “And, as consumers, we deserve to understand the actual prices of drugs that we are paying for,” he added. For Dr. Lakdawalla, pricing and rebate transparency would be a crucial first step to improving the U.S.’ decen- tralized, non–government-controlled health-care system. “Pricing transpar- ency is not sufficient to fix the system, but I think it’s a necessary step for the simple reason that we can’t have so many players making good, clinically rational decisions if they don’t know the most ba- sic facts, like the actual cost of the drug.” —By Anna Azvolinsky ● REFERENCES 1. The New York Times. In cancer are, cost matters. Accessed October 2, 2018, from https://www.nytimes.com/2012/10/15/opinion/a- hospital-says-no-to-an-11000-a-month-cancer-drug.html. 2. The New York Times. Sanofi halves price of cancer drug Zaltrap after Sloan-Kettering rejection.” Accessed October 2, 2018, from https:// www.nytimes.com/2012/11/09/business/sanofi-halves-price-of- drug-after-sloan-kettering-balks-at-paying-it.html. 3. Gordon N, Stemmer SM, Greenberg D, Goldstein DA. Trajectories of injectable cancer drug costs after launch in the United States. J Clin Onc. 2017;36:319-25. 4. Gorkin L, Kantarjian H. Targeted therapy: generic imatinib — impact on frontline and salvage therapy for CML. Nat Rev Clin Oncol. 2016;13:270-2. 5. DiMasi JA, Grabowski HG, Hansen RW. . Innovation in the pharmaceutical industry: new estimates of R&D costs. J Health Econ. 2016;47:20-33. 6. Department of Health and Human Services. “Average sales prices: Manufacturer reporting and CMS oversight.” Accessed October 2, 2018, from https://oig.hhs.gov/oei/reports/oei-03-08-00480.pdf. 7. PhRMA. Follow the dollar: understanding how the pharmaceutical istribution and payment system shapes the prices of brand medicines.” Accessed October 2, 2018, from http://phrma-docs. phrma.org/files/dmfile/Follow-the-Dollar-Report.pdf. 8. Lakdawalla D, Yin W. Insurer bargaining and negotiated drug prices in Medicare Part D. Rev Econ Stat. 2015;97:314-31. 9. National Institute for Health and Care Excellence. “Appraisal consultation document: Axicabtagene ciloleucel for treating diffuse large B-cell lymphoma and primary mediastinal B-cell lymphoma after 2 or more systemic therapies.” Accessed October 2, 2018, from https://www.nice.org.uk/guidance/GID-TA10214/documents/ appraisal-consultation-document 10. Gilead press release. ”Yescarta® (axicabtagene ciloleucel) receives European marketing authorization for the treatment of relapsed or refractory DLBCL and PMBCL, after two or more lines of systemic therapy.” Accessed October 2, 2018, from http://www.gilead.com/news/press-releases/2018/8/ yescarta-axicabtagene-ciloleucel-receives-european-marketing- authorization-for-the-treatment-of-relapsed-or-refractory-dlbcl-and- pmbcl-after-two-or-more-lines-of-systemic-therapy. 11. Novartis press release. “Novartis receives European Commission approval of its CAR-T cell therapy, Kymriah® (tisagenlecleucel).” Accessed October 10, 2018 from https://www.novartis.com/news/ media-releases/novartis-receives-european-commission-approval- its-car-t-cell-therapy-kymriah-tisagenlecleucel. 12. NHS press release. “NHS England strikes deal for ground breaking cancer treatment in a new European first.” Accessed October 10, 2018 from https://www.england.nhs.uk/2018/10/nhs-england-strikes-deal-for- ground-breaking-cancer-treatment-in-a-new-european-first/. 13. Kaiser Health News. “Cascade of costs could push new gene therapy above $1 million per patient.” Accessed October 2, 2018, from https://khn.org/news/-cascade-of-costs-could-push-new-gene- therapy-above-1-million-per-patient/. 14. Reuters. “U.S. Medicare sets outpatient rate for Yescarta reimbursement.” Accessed October 2, 2018, from https://www. reuters.com/article/us-cancer-medicare-yescarta/u-s-medicare- sets-outpatient-rate-for-yescarta-reimbursement-idUSKCN1HC2N3. 15. Institute for Economic and Clinical Review. “Chimeric antigen receptor T-cell therapy for B-cell cancers: effectiveness and value.” Accessed October 2, 2018, from https://icer-review.org/wp-content/ uploads/2017/07/ICER_CAR_T_Final_Evidence_Report_032318.pdf. 16. Centers for Medicare and Medicaid Services. “CMS: Innovative treatments call for innovative payment models and arrangements.” Accessed October 2, 2018, from https://www.cms.gov/newsroom/ press-releases/cms-innovative-treatments-call-innovative- payment-models-and-arrangements. ASH Advocates for Affordable Therapies The American Society of Hematology (ASH) is continuing to advocate for reasonable drug prices and supporting policies that would expand access to treatments for people with hematologic conditions. Advocating for New Payment Models When the revolutionary chimeric antigen receptor (CAR) T-cell therapies for treating hematologic malignancies gained regulatory approval in the U.S., the costs reached unprec- edented levels. More gene therapies are on the horizon, as are questions about who is going to pay for these expensive treatments. In June 2018, ASH submitted comments on the Centers for Medicare and Medicaid Services’ (CMS’) “CY 2019 Hospital Inpatient Prospective Payment System” proposed rule. As the CMS was working on finalizing its payment policy for CAR T-cell therapies, the Society urged CMS “to develop an innovative payment solution to protect patient access.” 1 ASH proposed an alternative reimburse- ment model in which CMS would pay for CAR T-cell products separately as a “pass-through” at actual acquisition or invoice cost, rather than covering it with a New Technology Add-on 62 ASH Clinical News Payment, or NTAP. ASH’s proposal would have the “added benefit of being site-neutral, elimi- nating financial incentives to treat patients in settings that may not be medically appropri- ate,” the Society explained. Ultimately CMS granted NTAPs to the two approved CAR T-cell products, but the Society will continue to explore alternative, sustain- able models for bringing these innovative, expensive therapies to patients. Stepping Up Against Step Therapy Earlier this year, CMS issued guidance allowing Medicare Advantage plans to implement “step therapy” for physician- administered and other Part B drugs. 2 Step therapy stipulates that patients must start (and fail) a less expensive (and often less effective) treatment option before being prescribed a more expensive, and frequently more effective, option. CMS intends the new policy to “encourage patients to choose high-value medications,” but members of the medical community pushed back against this “fail-first” approach. 3 In a letter to CMS Administrator Seema Verma, MPH, ASH joined more than 90 medi- cal organizations in calling on CMS to retain a 2012 policy that prohibits these plans from using step therapy on Part B benefits. 4 The dissenting organizations argued that, rather than giving Medicare an opportunity to negotiate better discounts for patients (as CMS claimed it would), the policy would erect more barriers between patients and needed therapies. “For cancer patients, selecting the proper personalized treatment as quickly as possible can be critical to survival,” the organizations wrote in the letter. “Delays in getting appropri- ate treatments can mean prolonged symptom- atic periods and irreversible damage, making a ‘fail first’ approach to treatment inappropriate.” The proposed policy is effective begin- ning January 2019, though details about its implementation are limited. REFERENCES 1. American Society of Hematology, “Letter to Ms. Seema Verma, RE: CMS-1694-P; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2019 Rates,” June 25, 2018. 2. CMS.gov, “Medicare Advantage Prior Authorization and Step Therapy for Part B Drugs.” Accessed October 11, 2018, from https://www. cms.gov/newsroom/fact-sheets/medicare-advantage-prior- authorization-and-step-therapy-part-b-drugs. 3. CMS.gov, “Speech: Remarks by Administrator Seema Verma at the Financial Times Pharma Pricing and Value Summit.” Accessed October 11, 2018, from https://www.cms.gov/newsroom/press-releases/ speech-remarks-administrator-seema-verma-financial-times- pharma-pricing-and-value-summit. 4. FierceHealthcare, “AMA leads nearly 100 medical groups calling on CMS to rethink step therapy for Part B drugs.” Accessed October 11, 2018, from https://www.fiercehealthcare.com/payer/american- medical-association-cms-step-therapy-part-b-drug-prices. November 2018