Value Viewpoint: December 13, 2024

This week,?ICER?released the latest iteration of its deeply flawed Unsupported Price Increase (UPI) report. The UPI report isn’t a value assessment, and its methodology contradicts ICER’s core value assessment framework, so it typically wouldn’t merit inclusion in?Value Viewpoint. However, given its potential to mislead healthcare stakeholders and drive harmful policy decisions, I am compelled to include it.

One of the flaws is that ICER’s analysis fails to account for inflation when calculating the report’s headline estimate. If ICER adhered to basic standards for economic analysis and adjusted its findings for inflation using the CPI-U, the supposed $815 million “increase” cited in this year’s report would instead become a $10 million?decrease. However, relying on robust, evidence-based methods that better reflect real-world market dynamics wouldn’t generate the shock value or attention-grabbing headlines that ICER seems to prioritize.

NPC addressed additional flaws in ICER’s analysis in a detailed statement. Additionally, NPC research published in the Journal of Medical Economics?last week revealed that ICER’s UPI reports from 2019 to 2023 consistently overstated spending changes and misrepresented headline estimates. Want more? Brian Reid has a great take on UPI in Thursday’s Cost Curve.

It’s well past time for ICER to retire this fundamentally flawed report. Stakeholders, and most importantly patients, deserve accurate, transparent analyses—not misleading headlines.

On Monday, ICER released their Draft Evidence Report assessing the comparative clinical effectiveness and value of suzetrigine for the treatment of acute pain. Public comments on the Draft Evidence Report are now being accepted and should be submitted before January 13, 2025.

??? Eye on ICER

A calendar of ICER’s upcoming reports & meetings:

Policy White Papers/Special Assessments:

- 12/19/24: Fair Access: Coverage Policies in 2024 — Policy White Paper

- 3/4/25: Special Assessment to Inform CMS Drug Price Negotiation: Breo Ellipta and Trelegy Ellipta — Final Report

Value Assessment Reports:

- 12/16/24: Epstein-Barr Virus Positive Post-Transplant Lymphoproliferative Disease — Final Evidence Report

- 2/5/25: Acute Pain — Revised Evidence Report

- 2/6/25: Retinitis Pigmentosa — Draft Evidence Report

- 3/26/25: Retinitis Pigmentosa — Revised Evidence Report

- 3/27/25: Acute Pain — Final Evidence Report

- 4/10/25: Multiple Sclerosis: SPMS — Draft Evidence Report

- 5/12/25: Retinitis Pigmentosa — Final Evidence Report

- 5/29/25: Multiple Sclerosis: SPMS — Revised Evidence Report

- 7/15/25: Multiple Sclerosis: SPMS — Final Evidence Report

Meetings:

- 2/28/25: Acute Pain — Public Meeting (Midwest CEPAC)

- 4/11/25: Retinitis Pigmentosa — Public Meeting (New England CEPAC)

- 6/14/25: Multiple Sclerosis: SPMS (California Technology Assessment Forum CTAF)

Contributing authors: Brian Sils , Lisabeth Buelt