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Analysis of regenerative medicine
technologies worldwide: How have
they been assessed by HTAs on a
           global basis?

          Plenary Session

                                                 Eric Faulkner, MPH
                                           Director, Global Market Access, Quintiles

                                        Adjunct Assistant Professor, Eshelman School of
                                     Pharmacy, University of North Carolina at Chapel Hill
                                      Executive Director, Genomics Biotech and Emerging
                                             Medical Technology Institute, NAMCP



  January 2012
The Value of Innovation is a Matter of
DEGREE in Healthcare Reimbursement

INNOVATION: a new idea or method: a new invention or way of doing something*


              What evidence of comparative effectiveness?
                   What value vs. alternatives?

                               Is it cost-effective?

                              Short vs. long term effect?
                                                               Is it safe?

                                      Marginal vs. transformative?

                                                                         Does it work?

                                                        New mechanism of action?


                                               *Source: Encarta World English Dictionary. Image source: www.bing.com
                                           2
Value: The Devil is in the Detail
 Building Value: The Devil                     is in the Detail




                                                   How much is      Easy to
                                According to        enough?       say…harder
                                  whom?                           to measure

                                         VALUE = outcomes
                                 What are the                 costs
                                best models &
                                 approaches?
                                              coststhe
                                                 What is
                                               right balance?
                                                                    What
                                                                   benefits vs.
                                                                  alternatives?

                                                  How do we get
                                                     there?
  *Image source: www.bing.com
Value: A Gem is the Sum of its Facets
 Value: A Gem is the Sum of its                                                               Facets


                                                                  Because value is multi-
                                                               dimensional…it is often difficult
                                                                      capture all facets


                                                                                              Sustainability of
                                                             Time to recovery
                                                                                             health or recovery    Budget impact &
                                   Survival                    and return to
                 Unmet Need




                                                                                               and nature of      cost-effectiveness
                                                             normal activities
                                                                                                recurrences


                                                            Disutility of care or
                                                            treatment process                   Long-term           Comparative
                              Degree of health
                                                              (e.g., diagnostic              consequences of         impact vs.
                                or recovery
                                                             errors, ineffective                 therapy            alternatives
                                                                    care)

                  PARTICULARLY true for regenerative medicine…
Adapted from: Michael Porter. What is value in healthcare? NEJM 2010. Image source: www.bing.com
Health Decision Makers View Regenerative
Medicine as a “True Innovation”
     Regenerative medicine ranked comparably with molecular diagnostics and
  personalized medicine as a true innovation, but decision makers were less certain
                           regarding cost offset potential

       Technology Type                                    Greatest Potential to                                   Greatest Potential to
                                                          Improve Care Quality                                    Provide Cost Offsets
                                                         (% respondents; n=121)                                (% respondents; n = 120)

Small molecule drugs                                                        14.0                                                   14.2
                                                                                                      The
Personalized medicine                                                       27.3                                                   17.5
                                                                                                 Regenerative
                                                                                                   Medicine
Cellular therapies and                                                      20.7                  Dilemma…                          9.2
regenerative medicine
                                                                                                  Promise vs.
Molecular diagnostics                                                       24.0                     Cost                          15.0
                                                                                                   Concerns
Diagnostic imaging                                                           9.1                                                    5.0

Nanotechnology                                                              16.5                                                   10.0
 Source: Survey of payers, hospital administrators and manufacturers from the National Association of Managed Care Physicians membership survey evaluation 2009-10.
Cell Therapies & Regenerative Medicine:
What is Different?
               Issue                      Cell         Conventional            Implications
                                      Therapies &       Biologics
                                      Regenerative
                                       Medicines
 Well understood & accepted             Not well, at        No        • Payers and physicians may
 by payers and physicians                 present                       place higher scrutiny on value
                                       perceived as                     demonstration
                                        truly novel                   • Commercialization may
                                                                        involve additional educational
                                                                        efforts and/or complexities
 Involves multiple procedural             Often           Rarely      • More like reimbursement for a
 steps that may be separately                                           device/procedure
 reimbursable                                                         • Failure to achieve
     (including in cell extraction,
                                                                        reimbursement of any
   purification and processing, and                                     component part may
   administration that may include                                      jeopardize reimbursement of
                imaging)                                                the entire procedure
 HTA will focus on the cost-               Yes           Not often    • Requires HEOR data
 effectiveness of the entire                             applicable     collection regarding the entire
 procedure                                                              procedure
Cell Therapies & Regenerative Medicine:
What is Different?

             Issue                    Cell       Conventional            Implications
                                  Therapies &     Biologics
                                  Regenerative
                                   Medicines
 May involve multiple billing         Yes            No         • Lack of appropriate
 codes /tariffs and/or payment                                    codes/tariffs or payment may
 centers for reimbursement of                                     limit or preclude access and
 the full procedure                                               uptake
 May involve requirements for         Yes         Sometimes     • This is a top HTA criticism of
 longer-term data collection to                                   most cell therapies in global
 demonstrate value (including                                     markets to date
 post-market follow-up data)
 Strong potential to be more         Often        Sometimes     • Higher cost means that
 costly than standard of care                                     therapies must demonstrate
 (SOC) alternatives                                               significant outcome
                                                                  improvements vs. SOC
                                                                  comparators
 May enable a disease cure or         Yes           Rarely      • Can alter the balance of
 prolonged therapeutic effect                                     benefit-cost tradeoffs in value
                                                                  assessment
Can we Learn from HTAs Re: Value
Demonstration for Regenerative Medicine?



                                     The Good




*Image source: www.photobucket.com
Global Evaluation of Regenerative Medicine
Health Technology Assessments (HTAs)

• Purpose of the study: Evaluate all available HTAs on cell
  and gene therapies in key global HTA markets to:
   – See how early regenerative medicine technologies have been
     handled
   – Identify key HTA criticisms that impacted reimbursement &
     commercial potential
   – Derive lessons for upcoming technologies in the space

• Included review of 48 HTAs and reimbursement policies
  from Australia, Canada, France, Spain, Sweden, the UK
  and US
   – No HTAs available from Germany and Italy on the topic
   – Did not include evaluation of Brazil, Russia, S. Korea, China, Japan
   – Many are nonredundant…so harder to see trends on same technology
     across markets
   – Excluded traditional cell replacement therapies for cancer indications
     (e.g., bone marrow, peripheral blood)


*Image source: www.bing.com
Evidentiary Criticisms in HTA
Differences Among Markets

         Evidence Consideration                            AU        CA         FR        DE          IT        ES        SE      UK   US

 Insufficient evidence of value                             S          S        NA         NA        NA          S            Y   S     S

 Insufficient number/quality of studies                     S          S        NA         NA        NA          Y            Y   S     S

 Lack of comparative data                                   S          S        NA         NA        NA          Y            Y   S     S

 Lack of long term data (>1 year)                           Y          Y         N         NA        NA          Y            Y   Y     S

 Inconclusive or inconsistent outcomes                      S          N        NA         NA        NA         NA            N   S     S

 Focus on surrogate outcomes                                S          S        NA         NA        NA          S            Y   N     S

 Inappropriate endpoints                                    S          S         N         NA        NA          Y            Y   S     S

 Concerns regarding safety                                  N          N         Y         NA        NA          N            N   N     S

 Insufficient efficacy                                      S          S        NA         NA        NA          Y            Y   S     S

 Insufficient cost-effectiveness                            S         NA         N         NA        NA          N            Y   N     N

Y = yes, in all assessments (yellow); S = some (green); N = no (red); NA = not available. Abbreviations: AU = Australia, CA = Canada, FR =
France, DE = Germany, IT = Italy, ES = Spain, SE = Sweden, UK = United Kingdom, and US = United States. *Note: due to the limited number of
assessments in some markets and variability of information reported in HTAs and reimbursement policies, results should be interpreted with
caution.
                        N = 48 HTAs and reimbursement policies from Australia, Canada, France, Spain, Sweden, the UK and US
Evidentiary Criticisms in HTA
Differences Among Markets

         Evidence Consideration                            AU        CA         FR        DE          IT        ES        SE        UK     US

 Insufficient evidence of value                             S          S        NA         NA        NA          S            Y      S      S

 Insufficient number/quality of studies                     S         S       NA      NA             NA          Y            Y      S      S
                                                                        Aside from the US,
 Lack of comparative data                                   S        Australia had the most
                                                                      S       NA      NA             NA          Y            Y      S      S
                                                                                                                                     Spain and
                                                                        HTAs (n=15). Many
                                                                                                                                   Sweden had few
 Lack of long term data (>1 year)                           Y        were horizon scanning
                                                                      Y        N      NA             NA          Y            Y      Y      S
                                                                                                                                   HTA reviews on
                                                                       reports and virtually
                                                                                                                                    regenerative
 Inconclusive or inconsistent outcomes                      S         N all rejected the
                                                                              NA      NA             NA         NA            N     medicineS
                                                                                                                                     S       and
                                                                      technology based on
                                                                                                                                    premature to
 Focus on surrogate outcomes                                S         S      level of NA
                                                                              NA                     NA          S            Y      N      S
                                                                                                                                  draw conclusions
                                                                     evidence/maturity and
                                                                                                                                      on payer
 Inappropriate endpoints                                    S         S some due to
                                                                               N      NA             NA          Y            Y      S      S
                                                                                                                                     position +
                                                                      insufficient marginal
                                                                                                                                    perspectives
                                                                         improvement to
 Concerns regarding safety                                  N         N        Y      NA             NA          N            N      N      S
                                                                      address unmet need
 Insufficient efficacy                                      S          S        NA         NA        NA          Y            Y      S      S

 Insufficient cost-effectiveness                            S         NA         N         NA        NA          N            Y     N       N

Y = yes, in all assessments (yellow); S = some (green); N = no (red); NA = not available. Abbreviations: AU = Australia, CA = Canada, FR =
France, DE = Germany, IT = Italy, ES = Spain, SE = Sweden, UK = United Kingdom, and US = United States. *Note: due to the limited number of
assessments in some markets and variability of information reported in HTAs and reimbursement policies, results should be interpreted with
caution.
                        N = 48 HTAs and reimbursement policies from Australia, Canada, France, Spain, Sweden, the UK and US
Evidentiary Criticisms in HTA
Differences Among Markets

         Evidence Consideration                            AU        CA         FR        DE          IT        ES        SE      UK   US

 Insufficient evidence of value                             S          S        NA         NA        NA          S       Y       S      S
                                                                                                            Many US HTAs were
 Insufficient number/quality of studies                     S          S        NA         NA        NA    noncoverageY
                                                                                                                 Y        policies
                                                                                                                                 S      S
                                                                                                            for technologies not
                                                                                                             yet on the market.
 Lack of comparative data                                   S          S        NA         NA        NA          Y       Y       S      S
                                                                                                           Main reason is likely
                                                                      UK HTAs did not                        to prevent broader
 Lack of long term data (>1 year)                           Y         Y        N      NA             NA          Y       Y       Y      S
                                                                      generally include                    hospital use through
                                                                       traditional cost-                           existing
 Inconclusive or inconsistent outcomes                      S         N        NA     NA             NA          NA      N       S      S
                                                                   effectiveness analysis                      reimbursement
                                                                    seen in NICE review                       mechanisms for
 Focus on surrogate outcomes                                S         S        NA     NA             NA          S       Y       N      S
                                                                    (at this point). Many                         “unproven
                                                                     technologies were                          technologies”
 Inappropriate endpoints                                    S         S        N      NA             NA          Y       Y       S      S
                                                                     early stage, “home
 Concerns regarding safety                                  N         Nbrew”,Y  and/orNA             NA          N            N   N     S
                                                                     required physician
 Insufficient efficacy                                      S         Sapproval to use
                                                                               NA     NA             NA          Y            Y   S     S

 Insufficient cost-effectiveness                            S         NA         N         NA        NA          N            Y   N     N

Y = yes, in all assessments (yellow); S = some (green); N = no (red); NA = not available. Abbreviations: AU = Australia, CA = Canada, FR =
France, DE = Germany, IT = Italy, ES = Spain, SE = Sweden, UK = United Kingdom, and US = United States. *Note: due to the limited number of
assessments in some markets and variability of information reported in HTAs and reimbursement policies, results should be interpreted with
caution.
                        N = 48 HTAs and reimbursement policies from Australia, Canada, France, Spain, Sweden, the UK and US
Case: Autologous Chondrocyte Implantation
for Knee Cartilage Defects

                                                                       Key Takeaways:
    RECOMMENDATION:
                                      Clinical Rationale:        • Technologies reviewed as
NOT recommended, except in
                                                                   a bundle
 context of ongoing clinical
                                  • Few RCTs; small sample       • Limited discrimination
          studies
                                    sizes; poor trial design &     between major
                                    controls                       technologies
     Economic Rationale:          • Inconsistent study           • Poor study design =
                                    designs and outcomes           increased potential for
 • Insufficient evidence to         reported                       rejection
   produce robust cost/QALY       • Inconsistent evidence of
 • Methods for mapping QoL to       clinical effectiveness
                                                                      Implications for
   economics not sound            • Proportion of post-            Regenerative Medicine:
 • Long-term NICE model took        procedural complications
   into account cost of knee      • Limited long-term            • Value demonstration for
   replacement + QoL for 50 yrs     outcomes data; when            QoL-driven indications is
 • ICER for mosaicplasty            available, similar to          difficult; align with payer
   dominated ACI in modeled         standard of care               expectations
   sceanarios                     • No comparison with           • Focus on quality design
 • Inconsistent model results       conservative management
                                                                 • Prepare for long-term
   based on “poor” evidence                                        follow-up
Case: Pancreatic Islet Cell Transplant After
Pancreatectomy

    RECOMMENDATION:                                                  Key Takeaways:
                                     Clinical Rationale:
    Recommended, but with
                                                               • Poor study designs and
   stipulations for educating
                                 • Only case series were         even safety can be
patients on procedure risk and
                                   available, with study         overlooked if:
  stipulations on treatment
            selection              designs that NICE would       – Population is small with
                                   generally not consider          high unmet need
                                   under “normal”
                                                                 – Outcomes are
                                   circumstances
                                                                   transformative or
                                 • 24% to 85% of patients          exceptional
     Economic Rationale:           were insulin-free at 6-18
                                   months
 • Extremely small, niche        • In one study 75%
   population with                                                  Implications for
                                   remained insulin-free up
                                                                 Regenerative Medicine:
  – High unmet need                to 5 years
  – Limited budget impact        • Accepted despite serious
                                                               • Payers recognize clear,
                                   potential AEs, including
 • No economic review included     vein thrombosis, liver
                                                                 transformative outcomes
   in the assessment               failure, pancreatic         • Expect greater scrutiny for
                                   infarct, and sepsis           marginal, poorly
                                                                 differentiated outcomes
Case: Limbal Stem Cell Transplantation for
Limbal Cell Deficiency

                                                                          Key Takeaways:
    RECOMMENDATION:
                                         Clinical Rationale:
 Recommended, for patients                                          • Accepted despite high
 with nonpterygium limbal cell       • Out of 873 citations, only     procedural costs because:
deficiency (ocular disorder) but       9 studies met inclusion       – Population is limited with
weak evidence for treatment of         criteria, suggesting that       high unmet need
     pterygium recurrence              rigorous study design is      – Therapy provided clear
                                       required (only RCTs)            clinical benefits
                                     • Long-term defined as         • Safety concerns
     Economic Rationale:               follow-up at least 6           overlooked b/c of benefits
                                       months post-procedure
                                       (not as rigorous as most
 • Considered budget impact,           regen. med assessments
   but not cost-effectiveness
                                     • Improvement in visual             Implications for
 • Costs estimated at >$8,000          acuity and visual function     Regenerative Medicine:
   to >$33,000 Cdn per eye,            deemed clinically
   depending on requirements           significant
   for follow-up and                                                • Value scrutiny more like
   retransplantation, with overall   • Concerns regarding risks       drugs than medical devices
   costs of ~$58,000                   of long-term                 • RCT-level data and
                                       immunosuppression with         appropriate outcomes are
                                       allogeneic transplants         key to acceptance
Case: Autologous Cell Transplant for
Myocardial Infarction

                                                                       Key Takeaways:
    RECOMMENDATION:                    Clinical Rationale:

  Further research required to                                   • Focus on surrogate
                                   • Review based on 10 RCTs       outcomes = perception not
determine long-term efficacy and
                                     and 4 noncomparative          ready for “prime time”
   safety (horizon scan report
                                     trials
              2007)                                              • For high risk + high volume
                                   • All studies at the time       + high cost = highest level
                                     evaluated surrogate           of payer scrutiny
                                     outcomes (e.g., LVEF) vs.
     Economic Rationale:
                                     changes in morbidity and
                                     mortality
 • Limited cost impact analysis
                                   • Lack of long-term data on
   evaluated incremental                                             Implications for
                                     “hard” and/or clinically
   costs of relevant procedure                                    Regenerative Medicine:
                                     discernable health
   steps via codes/payment
                                     outcomes
   rates in the Australian
                                                                 • Understand what payers
   system                          • Insufficient evidence on
                                                                   view as most important
                                     short- and long-term
 • Did NOT account for cost                                        value outcomes
                                     safety given risks
   of cells as a commercial
                                     associated with the         • Evidence threshold for
   product, but as part of a
                                     procedure                     high risk/high cost
   hospital procedure
                                                                   indications will be HIGH
Case: Vaccines for Prostate Cancer

                                                                           Key Takeaways:
    RECOMMENDATION:
                                                                     • The pricing of Provenge
No recommendation rendered;                                            drew significant attention to
most patients on Provenge who            Clinical Rationale:           cellular therapies
     progressed received                                             • Some payers may have
chemotherapy, so overall value      • All prostate cancer vaccines     heighted concerns or
  proposition is not yet clear        other than Provenge were         sensitivities re: cost of
    Economic Rationale:               viewed as investigational        future therapies
                                    • Although Provenge did not
• Not considered, although the        prevent cancer progression,
  $93K cost of Provenge was                                               Implications for
                                      it was noted to improve          Regenerative Medicine:
  extremely                           overall survival (OS)
  controversial, involving a
  potential Medicare National       • Outside of TEC assessment      • The higher the cost of a
  Coverage Determination              the level of OS improvement      new therapy, the greater
  (NCD) and involvement of US         was questioned, which is         the level of payer
  Congress members                    common for many oncology         scrutiny
                                      agents today as payers
• In the US, despite costs, it is     focus on the balance of        • Similar acceptance
  difficult/impossible not to         benefits vs. costs               potential for non-oncology
  cover an oncology                                                    indications in the US is
  agents, but harsh                                                    less certain
  reimbursement limits can
  apply
Several US Payers Maintain Preemptive
   Noncoverage Policies for Regen. Therapies

 Sample target indications currently not covered by leading
 US payers:
   –   Myocardial infarction                                                              –    Polymyositis
   –   Congestive heart failure                                                           –    Autoimmune cytopenia
   –   Multiple sclerosis                                                                 –    Diabetes mellitus (type I)
   –   Systemic lupus erythematosus                                                       –    Systemic vasculitis
   –   Systemic sclerosis                                                                 –    Celiac disease
   –   Rheumatoid arthritis                                                               –    Crohn's disease
   –   Juvenile rheumatoid arthritis                                                      –    Oncology (select
                                                                                              indications/applications)
   –   Idiopathic thrombocytopenic purpura
   –   Dematomyositis

                                                   Implications for Regenerative Medicine:

     • US payers are concerned about unproven, hospital-based cell therapies
     • Policies will change as evidence for tested products matures in the marketplace


Source: Indications identified through evaluation of multiple US MCO coverage policies.
Percentage of HTAs that Noted Key
Evidentiary Criticisms
                     Consider                                        Long-term                  Clearly
                    comparator                                       data will be             characterize                     Rigorous
                                                                      required.                  safety                      outcomes are
                                                                    Plan for post-                                                key
                                                                     market data
                                                                      collection




                  Insufficient     Lack of        Lack of      Inconclusive Inappropriate Concerns            Insufficient        Insufficient
                  #/quality of   comparative     long-term           or       endpoints   regarding             efficacy             cost-
                    studies         data            data       inconsistent                 safety                               effectiveness
Study design                                       (>1yr)         studies
quality is key.
 Device-like
  studies =
                             N = 48 HTAs and reimbursement policies from Australia, Canada, France, Spain, Sweden, the UK and US
     high
  rejection
                           N = 48 HTAs and reimbursement policies from Australia, Canada, France, Spain, Sweden, the UK and US
  potential
Percentage of HTAs that Noted Key
Evidentiary Criticisms
                                                                                  Ex-US HTAs
                                                                                  did not focus
                                                         Almost 50%
                                                                                   as much on
                                                           of HTAs
                                                                                      safety
                                                          noted that
                                                         studies did
                                                         not include
                                                           the right
                                   Some                   endpoints
                                outcomes
                                were either                                                                                         CE not
                                 unclear,                                                                                        mentioned
                               surrogate or                                                                                       b/c some
                                  various                                                                                         were early
                                outcomes                                                                                        HTAs and/or
                                   were                                                                                         technologies
                                 reported                                                                                       were subject
                                                                                                                                   to a less
                                                                                                                                   rigorous
                                                                                                                                    review
      Insufficient     Lack of    Lack of          Inconclusive Inappropriate Concerns            Insufficient        Insufficient
      #/quality of   comparative long-term               or       endpoints   regarding             efficacy             cost-
        studies         data        data           inconsistent                 safety                               effectiveness
                                   (>1yr)             studies




                 N = 48 HTAs and reimbursement policies from Australia, Canada, France, Spain, Sweden, the UK and US


               N = 48 HTAs and reimbursement policies from Australia, Canada, France, Spain, Sweden, the UK and US
Access Recommendations from HTA Review
Bodies/Payers

       Recommendations                                          Recommendations
         from All HTAs                Approximately              from US HTAs &
           Reviewed                  60% of all HTAs            Coverage Policies
                                      recommended                   Reviewed
                                    either rejection of
                                      the technology
                                       due to one or
 40%                                    more of the
                                        evidentiary
                                         criticisms                                   40%
                                        presented

                                     The majority of
                              60%   the noncoverage       60%
                                    policies in the US
                                         were for
                                    technologies that
                                      have not yet
                                       entered the
        Rejected   Accepted               market                Rejected   Accepted
What does the Climate Look Like for Value
   Demonstration in Regenerative Medicine?

                               • Regenerative medicine is “on the payer radar”
                                    – The “storm” has been sighted & decision makers are watching carefully
                               • Despite the promise, there is a “perfect storm” of factors converging that
                                 make global value demonstration more complex…particularly for ground
                                 breaking technologies
                                    – Driven by novelty, resource allocation pressures, and market health reform
                               • Early indicators may suggest storms ahead, but the key to success is
                                 planning and preparation. Focus on:
                                    – Solid study designs; appropriate patient targeting and sample size
                                    – Understanding the outcomes that matter on an indication-by-indication
                                      basis
                                    – Plans for longer-term data collection beyond the pivotal study
                                    – Characterizing benefits/cost balance vs. alternatives; economics matter
                               • Remember…for payers, saying “no” is easier than saying “yes”
                                    – Have your emergency kit well prepared to weather climate changes in HTA


. Image source: www.bing.com                                       22
Many Other Issues Required To Understand
   Value Drivers for Regenerative Medicine
                                                                                         •Are available codes//tariffs sufficient for key procedure
         •Payers will look at the balance of outcomes                                     steps?
          relative to cost of entire procedure
                                                                                         •Do we need a new code/tariff? If so, what timing and info
         •How will evidence development differ from                                       required?
          conventional therapies?
                                                                          Coding/
                                                       Evidence
                                                                           Tariff
                                                           &
                                                       Outcomes                                             • What outcomes are important in
                                                                                                             avoiding reimbursement rejection?
                                                                                                            • What are the key reimbursement
                                                                                              Coverage
  •Autologous or allogeneic?                                                                                 limitations that we can expect for the
                                                                                                             therapy?
  •Type or cell and persistence?             Cell
                                           Therapy
  • How are process for cell
   collection, preparation, and
                                          Approach           Reimbursement
   administration reimbursed?                                  and Market                                     •Is payment level appropriate to
                                                                 Access                                        support access for each step?
                                                                                                Payment       •What are our options for address
• What are HTA agency and payers
                                                                                                               inappropriate payment?
                                             Payer &
perspectives on cell therapies?
                                              HTA
•How have payers and HTA agencies            Trends
 handled initial cell therapy entrants?
                                                                                    Site of        •How does site of care influence
•What key criticisms of the value                             Patient                Care           reimbursement potential for the therapy?
 proposition have been cited for cell                         Access
 therapies?                                                                                        •Is special expertise required to provide the
                                                                                                    therapy?
                                                                                                   • Are Centers of Excellence required?
                                   • How flexible will payers be regarding patient access?

                                   • Are there subpopulations that are best to target?
                                   •What information will physicians require for adoption vs.
                                    conventional therapies?

                                                                                                                                                      23
Need for Reimbursement Planning is More
Pronounced for Regenerative Medicine
                                                       If uncertainties exist/to
                          Landscape, seconda                   confirm
                             ry, & primary              HEOR/reimbursement
                               research                       approach


 Clinical & Economic             Market                                                   Implement Pivotal
                                                             Early Payer
                                 Access                                                        Study
Value Demonstration            Environment
                                                               Maker
                                                             Engagement
Plan (HEOR strategy)            Research



                                                                                         Ancillary clinical and
  Market Forecast &                                                                       economic studies
   Business Plan                        Manage the
                                       Moving Target
                                        Not new…just more
       Market                               acute focus
  Access, Pricing &    • Due to novelty, even more reason to characterize decision
   Reimbursement         requirements
                                                                                             Reimbursement
      Strategy         • Understand endpoints,/outcomes trial requirements, patient          Submissions &
                         considerations                                                         Launch

                       • Identify appropriate comparator and perspectives on available
 Launch/Commercial       alternatives
      Strategy
                       • Understand how the procedure will fit into market
                         reimbursement system

                       • Decision maker reactions to TPP and costs
Reimbursement and Market Access:
   Putting it All Together
                               • Multiple regenerative medicine technologies are moving into
                                 clinical development, but:
                                 o They are truly novel and not yet understood/accepted by HTA, payer and physician
                                   decision makers: EDUCATE

                                 o Reimbursement and commercial strategy is more complex due to combination
                                   procedure/surgery and cellular component; technologies can touch more than one
                                   payment system; EVALUATE – “measure twice & cut once”

                                 o Manufacturing, distribution and market access channels are more complex than
                                   conventional biopharmaceuticals; NAVIGATE

                                 o Early analysis of HTAs suggests that regenerative medicines will have to
                                   demonstrate strong clinical, economic and long-term follow-up data;
                                   DEMONSTRATE

                                 o “Front-loaded” cost model and “episode of care” view can complicate economic
                                   and cost-effectiveness analysis; VENERATE – clearly understand economic
                                   drivers

                                 o Need for strong educational efforts and clear communication of value
                                   proposition; COMMUNICATE – “multifaceted value…let me count the ways…”

                               • Reverse engineer product plans targeting reimbursement
                                 requirements to optimize commercial potential so the pieces fit
. Image source: www.bing.com                                          25
Eric Faulkner
             Director, Global Market Access
             Quintiles
Thank You!
             4820 Emperor Blvd.
             Durham, NC 13979
             919-998-7266 (office)
             919-381-8306 (mobile)
             Eric.Faulkner@quintiles.com

             Executive Director, Genomics, Biotech and
             Emerging Medical Technology Institute
             National Association of Managed Care Physicians

             Assistant Professor, Eshelman School of
             Pharmacy, Institute for Pharmacogenomics and
             Individualized Therapy
             University of North Carolina at Chapel Hill

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Phacilitate Cell Gene Therapy 2012 Faulkner Worldwide Hta Analysis

  • 1. Analysis of regenerative medicine technologies worldwide: How have they been assessed by HTAs on a global basis? Plenary Session Eric Faulkner, MPH Director, Global Market Access, Quintiles Adjunct Assistant Professor, Eshelman School of Pharmacy, University of North Carolina at Chapel Hill Executive Director, Genomics Biotech and Emerging Medical Technology Institute, NAMCP January 2012
  • 2. The Value of Innovation is a Matter of DEGREE in Healthcare Reimbursement INNOVATION: a new idea or method: a new invention or way of doing something* What evidence of comparative effectiveness? What value vs. alternatives? Is it cost-effective? Short vs. long term effect? Is it safe? Marginal vs. transformative? Does it work? New mechanism of action? *Source: Encarta World English Dictionary. Image source: www.bing.com 2
  • 3. Value: The Devil is in the Detail Building Value: The Devil is in the Detail How much is Easy to According to enough? say…harder whom? to measure VALUE = outcomes What are the costs best models & approaches? coststhe What is right balance? What benefits vs. alternatives? How do we get there? *Image source: www.bing.com
  • 4. Value: A Gem is the Sum of its Facets Value: A Gem is the Sum of its Facets Because value is multi- dimensional…it is often difficult capture all facets Sustainability of Time to recovery health or recovery Budget impact & Survival and return to Unmet Need and nature of cost-effectiveness normal activities recurrences Disutility of care or treatment process Long-term Comparative Degree of health (e.g., diagnostic consequences of impact vs. or recovery errors, ineffective therapy alternatives care) PARTICULARLY true for regenerative medicine… Adapted from: Michael Porter. What is value in healthcare? NEJM 2010. Image source: www.bing.com
  • 5. Health Decision Makers View Regenerative Medicine as a “True Innovation” Regenerative medicine ranked comparably with molecular diagnostics and personalized medicine as a true innovation, but decision makers were less certain regarding cost offset potential Technology Type Greatest Potential to Greatest Potential to Improve Care Quality Provide Cost Offsets (% respondents; n=121) (% respondents; n = 120) Small molecule drugs 14.0 14.2 The Personalized medicine 27.3 17.5 Regenerative Medicine Cellular therapies and 20.7 Dilemma… 9.2 regenerative medicine Promise vs. Molecular diagnostics 24.0 Cost 15.0 Concerns Diagnostic imaging 9.1 5.0 Nanotechnology 16.5 10.0 Source: Survey of payers, hospital administrators and manufacturers from the National Association of Managed Care Physicians membership survey evaluation 2009-10.
  • 6. Cell Therapies & Regenerative Medicine: What is Different? Issue Cell Conventional Implications Therapies & Biologics Regenerative Medicines Well understood & accepted Not well, at No • Payers and physicians may by payers and physicians present place higher scrutiny on value perceived as demonstration truly novel • Commercialization may involve additional educational efforts and/or complexities Involves multiple procedural Often Rarely • More like reimbursement for a steps that may be separately device/procedure reimbursable • Failure to achieve (including in cell extraction, reimbursement of any purification and processing, and component part may administration that may include jeopardize reimbursement of imaging) the entire procedure HTA will focus on the cost- Yes Not often • Requires HEOR data effectiveness of the entire applicable collection regarding the entire procedure procedure
  • 7. Cell Therapies & Regenerative Medicine: What is Different? Issue Cell Conventional Implications Therapies & Biologics Regenerative Medicines May involve multiple billing Yes No • Lack of appropriate codes /tariffs and/or payment codes/tariffs or payment may centers for reimbursement of limit or preclude access and the full procedure uptake May involve requirements for Yes Sometimes • This is a top HTA criticism of longer-term data collection to most cell therapies in global demonstrate value (including markets to date post-market follow-up data) Strong potential to be more Often Sometimes • Higher cost means that costly than standard of care therapies must demonstrate (SOC) alternatives significant outcome improvements vs. SOC comparators May enable a disease cure or Yes Rarely • Can alter the balance of prolonged therapeutic effect benefit-cost tradeoffs in value assessment
  • 8. Can we Learn from HTAs Re: Value Demonstration for Regenerative Medicine? The Good *Image source: www.photobucket.com
  • 9. Global Evaluation of Regenerative Medicine Health Technology Assessments (HTAs) • Purpose of the study: Evaluate all available HTAs on cell and gene therapies in key global HTA markets to: – See how early regenerative medicine technologies have been handled – Identify key HTA criticisms that impacted reimbursement & commercial potential – Derive lessons for upcoming technologies in the space • Included review of 48 HTAs and reimbursement policies from Australia, Canada, France, Spain, Sweden, the UK and US – No HTAs available from Germany and Italy on the topic – Did not include evaluation of Brazil, Russia, S. Korea, China, Japan – Many are nonredundant…so harder to see trends on same technology across markets – Excluded traditional cell replacement therapies for cancer indications (e.g., bone marrow, peripheral blood) *Image source: www.bing.com
  • 10. Evidentiary Criticisms in HTA Differences Among Markets Evidence Consideration AU CA FR DE IT ES SE UK US Insufficient evidence of value S S NA NA NA S Y S S Insufficient number/quality of studies S S NA NA NA Y Y S S Lack of comparative data S S NA NA NA Y Y S S Lack of long term data (>1 year) Y Y N NA NA Y Y Y S Inconclusive or inconsistent outcomes S N NA NA NA NA N S S Focus on surrogate outcomes S S NA NA NA S Y N S Inappropriate endpoints S S N NA NA Y Y S S Concerns regarding safety N N Y NA NA N N N S Insufficient efficacy S S NA NA NA Y Y S S Insufficient cost-effectiveness S NA N NA NA N Y N N Y = yes, in all assessments (yellow); S = some (green); N = no (red); NA = not available. Abbreviations: AU = Australia, CA = Canada, FR = France, DE = Germany, IT = Italy, ES = Spain, SE = Sweden, UK = United Kingdom, and US = United States. *Note: due to the limited number of assessments in some markets and variability of information reported in HTAs and reimbursement policies, results should be interpreted with caution. N = 48 HTAs and reimbursement policies from Australia, Canada, France, Spain, Sweden, the UK and US
  • 11. Evidentiary Criticisms in HTA Differences Among Markets Evidence Consideration AU CA FR DE IT ES SE UK US Insufficient evidence of value S S NA NA NA S Y S S Insufficient number/quality of studies S S NA NA NA Y Y S S Aside from the US, Lack of comparative data S Australia had the most S NA NA NA Y Y S S Spain and HTAs (n=15). Many Sweden had few Lack of long term data (>1 year) Y were horizon scanning Y N NA NA Y Y Y S HTA reviews on reports and virtually regenerative Inconclusive or inconsistent outcomes S N all rejected the NA NA NA NA N medicineS S and technology based on premature to Focus on surrogate outcomes S S level of NA NA NA S Y N S draw conclusions evidence/maturity and on payer Inappropriate endpoints S S some due to N NA NA Y Y S S position + insufficient marginal perspectives improvement to Concerns regarding safety N N Y NA NA N N N S address unmet need Insufficient efficacy S S NA NA NA Y Y S S Insufficient cost-effectiveness S NA N NA NA N Y N N Y = yes, in all assessments (yellow); S = some (green); N = no (red); NA = not available. Abbreviations: AU = Australia, CA = Canada, FR = France, DE = Germany, IT = Italy, ES = Spain, SE = Sweden, UK = United Kingdom, and US = United States. *Note: due to the limited number of assessments in some markets and variability of information reported in HTAs and reimbursement policies, results should be interpreted with caution. N = 48 HTAs and reimbursement policies from Australia, Canada, France, Spain, Sweden, the UK and US
  • 12. Evidentiary Criticisms in HTA Differences Among Markets Evidence Consideration AU CA FR DE IT ES SE UK US Insufficient evidence of value S S NA NA NA S Y S S Many US HTAs were Insufficient number/quality of studies S S NA NA NA noncoverageY Y policies S S for technologies not yet on the market. Lack of comparative data S S NA NA NA Y Y S S Main reason is likely UK HTAs did not to prevent broader Lack of long term data (>1 year) Y Y N NA NA Y Y Y S generally include hospital use through traditional cost- existing Inconclusive or inconsistent outcomes S N NA NA NA NA N S S effectiveness analysis reimbursement seen in NICE review mechanisms for Focus on surrogate outcomes S S NA NA NA S Y N S (at this point). Many “unproven technologies were technologies” Inappropriate endpoints S S N NA NA Y Y S S early stage, “home Concerns regarding safety N Nbrew”,Y and/orNA NA N N N S required physician Insufficient efficacy S Sapproval to use NA NA NA Y Y S S Insufficient cost-effectiveness S NA N NA NA N Y N N Y = yes, in all assessments (yellow); S = some (green); N = no (red); NA = not available. Abbreviations: AU = Australia, CA = Canada, FR = France, DE = Germany, IT = Italy, ES = Spain, SE = Sweden, UK = United Kingdom, and US = United States. *Note: due to the limited number of assessments in some markets and variability of information reported in HTAs and reimbursement policies, results should be interpreted with caution. N = 48 HTAs and reimbursement policies from Australia, Canada, France, Spain, Sweden, the UK and US
  • 13. Case: Autologous Chondrocyte Implantation for Knee Cartilage Defects Key Takeaways: RECOMMENDATION: Clinical Rationale: • Technologies reviewed as NOT recommended, except in a bundle context of ongoing clinical • Few RCTs; small sample • Limited discrimination studies sizes; poor trial design & between major controls technologies Economic Rationale: • Inconsistent study • Poor study design = designs and outcomes increased potential for • Insufficient evidence to reported rejection produce robust cost/QALY • Inconsistent evidence of • Methods for mapping QoL to clinical effectiveness Implications for economics not sound • Proportion of post- Regenerative Medicine: • Long-term NICE model took procedural complications into account cost of knee • Limited long-term • Value demonstration for replacement + QoL for 50 yrs outcomes data; when QoL-driven indications is • ICER for mosaicplasty available, similar to difficult; align with payer dominated ACI in modeled standard of care expectations sceanarios • No comparison with • Focus on quality design • Inconsistent model results conservative management • Prepare for long-term based on “poor” evidence follow-up
  • 14. Case: Pancreatic Islet Cell Transplant After Pancreatectomy RECOMMENDATION: Key Takeaways: Clinical Rationale: Recommended, but with • Poor study designs and stipulations for educating • Only case series were even safety can be patients on procedure risk and available, with study overlooked if: stipulations on treatment selection designs that NICE would – Population is small with generally not consider high unmet need under “normal” – Outcomes are circumstances transformative or • 24% to 85% of patients exceptional Economic Rationale: were insulin-free at 6-18 months • Extremely small, niche • In one study 75% population with Implications for remained insulin-free up Regenerative Medicine: – High unmet need to 5 years – Limited budget impact • Accepted despite serious • Payers recognize clear, potential AEs, including • No economic review included vein thrombosis, liver transformative outcomes in the assessment failure, pancreatic • Expect greater scrutiny for infarct, and sepsis marginal, poorly differentiated outcomes
  • 15. Case: Limbal Stem Cell Transplantation for Limbal Cell Deficiency Key Takeaways: RECOMMENDATION: Clinical Rationale: Recommended, for patients • Accepted despite high with nonpterygium limbal cell • Out of 873 citations, only procedural costs because: deficiency (ocular disorder) but 9 studies met inclusion – Population is limited with weak evidence for treatment of criteria, suggesting that high unmet need pterygium recurrence rigorous study design is – Therapy provided clear required (only RCTs) clinical benefits • Long-term defined as • Safety concerns Economic Rationale: follow-up at least 6 overlooked b/c of benefits months post-procedure (not as rigorous as most • Considered budget impact, regen. med assessments but not cost-effectiveness • Improvement in visual Implications for • Costs estimated at >$8,000 acuity and visual function Regenerative Medicine: to >$33,000 Cdn per eye, deemed clinically depending on requirements significant for follow-up and • Value scrutiny more like retransplantation, with overall • Concerns regarding risks drugs than medical devices costs of ~$58,000 of long-term • RCT-level data and immunosuppression with appropriate outcomes are allogeneic transplants key to acceptance
  • 16. Case: Autologous Cell Transplant for Myocardial Infarction Key Takeaways: RECOMMENDATION: Clinical Rationale: Further research required to • Focus on surrogate • Review based on 10 RCTs outcomes = perception not determine long-term efficacy and and 4 noncomparative ready for “prime time” safety (horizon scan report trials 2007) • For high risk + high volume • All studies at the time + high cost = highest level evaluated surrogate of payer scrutiny outcomes (e.g., LVEF) vs. Economic Rationale: changes in morbidity and mortality • Limited cost impact analysis • Lack of long-term data on evaluated incremental Implications for “hard” and/or clinically costs of relevant procedure Regenerative Medicine: discernable health steps via codes/payment outcomes rates in the Australian • Understand what payers system • Insufficient evidence on view as most important short- and long-term • Did NOT account for cost value outcomes safety given risks of cells as a commercial associated with the • Evidence threshold for product, but as part of a procedure high risk/high cost hospital procedure indications will be HIGH
  • 17. Case: Vaccines for Prostate Cancer Key Takeaways: RECOMMENDATION: • The pricing of Provenge No recommendation rendered; drew significant attention to most patients on Provenge who Clinical Rationale: cellular therapies progressed received • Some payers may have chemotherapy, so overall value • All prostate cancer vaccines heighted concerns or proposition is not yet clear other than Provenge were sensitivities re: cost of Economic Rationale: viewed as investigational future therapies • Although Provenge did not • Not considered, although the prevent cancer progression, $93K cost of Provenge was Implications for it was noted to improve Regenerative Medicine: extremely overall survival (OS) controversial, involving a potential Medicare National • Outside of TEC assessment • The higher the cost of a Coverage Determination the level of OS improvement new therapy, the greater (NCD) and involvement of US was questioned, which is the level of payer Congress members common for many oncology scrutiny agents today as payers • In the US, despite costs, it is focus on the balance of • Similar acceptance difficult/impossible not to benefits vs. costs potential for non-oncology cover an oncology indications in the US is agents, but harsh less certain reimbursement limits can apply
  • 18. Several US Payers Maintain Preemptive Noncoverage Policies for Regen. Therapies Sample target indications currently not covered by leading US payers: – Myocardial infarction – Polymyositis – Congestive heart failure – Autoimmune cytopenia – Multiple sclerosis – Diabetes mellitus (type I) – Systemic lupus erythematosus – Systemic vasculitis – Systemic sclerosis – Celiac disease – Rheumatoid arthritis – Crohn's disease – Juvenile rheumatoid arthritis – Oncology (select indications/applications) – Idiopathic thrombocytopenic purpura – Dematomyositis Implications for Regenerative Medicine: • US payers are concerned about unproven, hospital-based cell therapies • Policies will change as evidence for tested products matures in the marketplace Source: Indications identified through evaluation of multiple US MCO coverage policies.
  • 19. Percentage of HTAs that Noted Key Evidentiary Criticisms Consider Long-term Clearly comparator data will be characterize Rigorous required. safety outcomes are Plan for post- key market data collection Insufficient Lack of Lack of Inconclusive Inappropriate Concerns Insufficient Insufficient #/quality of comparative long-term or endpoints regarding efficacy cost- studies data data inconsistent safety effectiveness Study design (>1yr) studies quality is key. Device-like studies = N = 48 HTAs and reimbursement policies from Australia, Canada, France, Spain, Sweden, the UK and US high rejection N = 48 HTAs and reimbursement policies from Australia, Canada, France, Spain, Sweden, the UK and US potential
  • 20. Percentage of HTAs that Noted Key Evidentiary Criticisms Ex-US HTAs did not focus Almost 50% as much on of HTAs safety noted that studies did not include the right Some endpoints outcomes were either CE not unclear, mentioned surrogate or b/c some various were early outcomes HTAs and/or were technologies reported were subject to a less rigorous review Insufficient Lack of Lack of Inconclusive Inappropriate Concerns Insufficient Insufficient #/quality of comparative long-term or endpoints regarding efficacy cost- studies data data inconsistent safety effectiveness (>1yr) studies N = 48 HTAs and reimbursement policies from Australia, Canada, France, Spain, Sweden, the UK and US N = 48 HTAs and reimbursement policies from Australia, Canada, France, Spain, Sweden, the UK and US
  • 21. Access Recommendations from HTA Review Bodies/Payers Recommendations Recommendations from All HTAs Approximately from US HTAs & Reviewed 60% of all HTAs Coverage Policies recommended Reviewed either rejection of the technology due to one or 40% more of the evidentiary criticisms 40% presented The majority of 60% the noncoverage 60% policies in the US were for technologies that have not yet entered the Rejected Accepted market Rejected Accepted
  • 22. What does the Climate Look Like for Value Demonstration in Regenerative Medicine? • Regenerative medicine is “on the payer radar” – The “storm” has been sighted & decision makers are watching carefully • Despite the promise, there is a “perfect storm” of factors converging that make global value demonstration more complex…particularly for ground breaking technologies – Driven by novelty, resource allocation pressures, and market health reform • Early indicators may suggest storms ahead, but the key to success is planning and preparation. Focus on: – Solid study designs; appropriate patient targeting and sample size – Understanding the outcomes that matter on an indication-by-indication basis – Plans for longer-term data collection beyond the pivotal study – Characterizing benefits/cost balance vs. alternatives; economics matter • Remember…for payers, saying “no” is easier than saying “yes” – Have your emergency kit well prepared to weather climate changes in HTA . Image source: www.bing.com 22
  • 23. Many Other Issues Required To Understand Value Drivers for Regenerative Medicine •Are available codes//tariffs sufficient for key procedure •Payers will look at the balance of outcomes steps? relative to cost of entire procedure •Do we need a new code/tariff? If so, what timing and info •How will evidence development differ from required? conventional therapies? Coding/ Evidence Tariff & Outcomes • What outcomes are important in avoiding reimbursement rejection? • What are the key reimbursement Coverage •Autologous or allogeneic? limitations that we can expect for the therapy? •Type or cell and persistence? Cell Therapy • How are process for cell collection, preparation, and Approach Reimbursement administration reimbursed? and Market •Is payment level appropriate to Access support access for each step? Payment •What are our options for address • What are HTA agency and payers inappropriate payment? Payer & perspectives on cell therapies? HTA •How have payers and HTA agencies Trends handled initial cell therapy entrants? Site of •How does site of care influence •What key criticisms of the value Patient Care reimbursement potential for the therapy? proposition have been cited for cell Access therapies? •Is special expertise required to provide the therapy? • Are Centers of Excellence required? • How flexible will payers be regarding patient access? • Are there subpopulations that are best to target? •What information will physicians require for adoption vs. conventional therapies? 23
  • 24. Need for Reimbursement Planning is More Pronounced for Regenerative Medicine If uncertainties exist/to Landscape, seconda confirm ry, & primary HEOR/reimbursement research approach Clinical & Economic Market Implement Pivotal Early Payer Access Study Value Demonstration Environment Maker Engagement Plan (HEOR strategy) Research Ancillary clinical and Market Forecast & economic studies Business Plan Manage the Moving Target Not new…just more Market acute focus Access, Pricing & • Due to novelty, even more reason to characterize decision Reimbursement requirements Reimbursement Strategy • Understand endpoints,/outcomes trial requirements, patient Submissions & considerations Launch • Identify appropriate comparator and perspectives on available Launch/Commercial alternatives Strategy • Understand how the procedure will fit into market reimbursement system • Decision maker reactions to TPP and costs
  • 25. Reimbursement and Market Access: Putting it All Together • Multiple regenerative medicine technologies are moving into clinical development, but: o They are truly novel and not yet understood/accepted by HTA, payer and physician decision makers: EDUCATE o Reimbursement and commercial strategy is more complex due to combination procedure/surgery and cellular component; technologies can touch more than one payment system; EVALUATE – “measure twice & cut once” o Manufacturing, distribution and market access channels are more complex than conventional biopharmaceuticals; NAVIGATE o Early analysis of HTAs suggests that regenerative medicines will have to demonstrate strong clinical, economic and long-term follow-up data; DEMONSTRATE o “Front-loaded” cost model and “episode of care” view can complicate economic and cost-effectiveness analysis; VENERATE – clearly understand economic drivers o Need for strong educational efforts and clear communication of value proposition; COMMUNICATE – “multifaceted value…let me count the ways…” • Reverse engineer product plans targeting reimbursement requirements to optimize commercial potential so the pieces fit . Image source: www.bing.com 25
  • 26. Eric Faulkner Director, Global Market Access Quintiles Thank You! 4820 Emperor Blvd. Durham, NC 13979 919-998-7266 (office) 919-381-8306 (mobile) Eric.Faulkner@quintiles.com Executive Director, Genomics, Biotech and Emerging Medical Technology Institute National Association of Managed Care Physicians Assistant Professor, Eshelman School of Pharmacy, Institute for Pharmacogenomics and Individualized Therapy University of North Carolina at Chapel Hill