The effectiveness and value of nadofaragene firadenovec, oportuzumab monatox, and pembrolizumab for BCG-unresponsive non-muscle-invasive bladder ...

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P E R S P E C T I V E S O N V A L U E 797

The effectiveness and value of nadofaragene
firadenovec, oportuzumab monatox, and
pembrolizumab for BCG-unresponsive
non-muscle-invasive bladder cancer
A summary from the Institute for Clinical and Economic Review’s Midwest Comparative
Effectiveness Public Advisory Council

Molly Beinfeld, MPH; Steven J Atlas, MD, MPH; Daniel Touchette, PharmD, MA; Avery McKenna; David Rind, MD;
and Steven D Pearson, MD, MSc

Bladder cancer is the sixth most           Calmette-Guerin (BCG), an attenuated
common cancer in the United States.        live form of Mycobacterium bovis.5 For    Author affiliations
Approximately 80,000 new cases             patients with invasive disease or who     Molly Beinfeld, MPH; Avery McKenna;
are diagnosed each year, and more          are not responding to or tolerating       David Rind, MD; and Steven D Pearson,
than 17,000 people die from the dis-       intravesical therapy, cystectomy may      MD, MSc, Institute for Clinical and
ease annually.1,2 At diagnosis, most       be performed to remove the bladder.6,7    Economic Review, Boston, MA. Steven
patients have non-muscle-invasive             Although short-term prognosis          J Atlas, MD, MPH, Division of General
bladder cancer (NMIBC), meaning            for NMIBC is good, patients with          Internal Medicine, Massachusetts General
                                                                                     Hospital and Harvard Medical School,
that the cancer involves the inner lin-    BCG-unresponsive disease can
                                                                                     Boston, MA. Daniel Touchette, PharmD,
ing of the bladder but has not invaded     select cystectomy or further intra-
                                                                                     MA, University of Illinois at Chicago
into the deeper muscle layer. NMIBC        vesical chemotherapy with agents          College of Pharmacy, Chicago, IL.
includes 3 subgroups that are asso-        such as gemcitabine monotherapy
ciated with increasing risk of cancer      or combination gemcitabine plus           AUTHOR CORRESPONDENCE:
progression: (1) 70% of patients have      docetaxel. Response rates to these        Molly Beinfeld, mbeinfeld@icer.org
Ta disease, with polyps extend-            agents are relatively low, underscor-
ing into the lining of the bladder;        ing the need for new bladder-sparing
(2) 20% of patients have T1 disease,       treatment options. 8,9                                      J Manag Care Spec Pharm.
with tumors below the superficial             In January 2020, pembrolizumab                                  2021;27(6):797-804
lining but not involving the muscular      (Keytruda), a systemically admin-               Copyright © 2021, Academy of Managed
layer of the bladder wall; and (3) 10%     istered     immunotherapy       agent,             Care Pharmacy. All rights reserved.

of patients have carcinoma in situ         received an additional indication for
(CIS) with flat, superficial growths. 3    BCG-unresponsive CIS disease.10 In
Treatment and related health care          addition, 2 new intravesical thera-
costs for patients with bladder can-       pies have recently begun the US          cancer cells.11,12 It is instilled every
cer is estimated to be $4-$5 billion       Food and Drug Administration (FDA)       3 months. Oportuzumab monatox is a
annually in the United States.4            approval process: nadofaragene firad-    recombinant fusion protein with a cell
   Treatment of NMIBC involves             enovec (Adstiladrin) and oportuzumab
                                                                                    adhesion molecule antibody linked to
removal of visible cancer followed         monatox (Vicineum). Nadofaragene
                                                                                    a toxin that binds to the cancer cell
by intravesical therapy for those          firadenovec uses a recombinant
at increased risk of progression to        adenovirus vector that encodes the       that releases the toxin into the cell,
invasive disease. The most common          human interferon alfa-2b gene with       inducing cell death.13 It is instilled
initial intravesical therapy is Bacillus   a surfactant to enhance transfer into    twice a week for 6 weeks, then weekly

                                                                                             Vol. 27, No. 6 | June 2021 | JMCP.org
The effectiveness and value of nadofaragene firadenovec, oportuzumab monatox,
798
                                   and pembrolizumab for BCG-unresponsive non-muscle-invasive bladder cancer

                              FIGURE 1            Phase 3 Results of Nadofaragene Firadenovec: Complete                  for 6 weeks and then every 2 weeks for
                                                  Response and High-Grade Recurrence Free Survival,                      up to 2 years.
                                                  CIS ± Ta/T1, and Ta/T114                                                  The Institute for Clinical and
                                                                                                                         Economic Review (ICER) conducted
                              90                                                                                         a systematic literature review and
                              80                                                                                         cost-effectiveness analysis to evaluate
                                                                                                     CIS ± Ta/T1
                                                                                                                         the health and economic outcomes
Proportion with CR or HGRFS

                              70                                                                     Ta/T1
                                                                                                                         of nadofaragene firadenovec, oportu-
                              60                                                                                         zumab monatox, and pembrolizumab
                              50                                                                                         for     BCG-unresponsive       NMIBC.
                                                                                                                         Complete details of ICER’s system-
                              40
                                              72.9                                                                       atic literature search and protocol, as
                              30                                  62.5                58.3                               well as the methodology and model
                                       53.4
                              20                           40.8                                                   43.8   structure for the economic evalua-
                                                                                 35
                                                                                                           24.3          tion are available on ICER’s website
                              10
                                                                                                                         at     https://icer.org/assessment/
                               0                                                                                         bladder-cancer-2020/.
                                       3 months            6 months             9 months               12 months
                                                                                                                            In this report, we present the sum-
                                                                         Time
                                                                                                                         mary of our findings and highlights of
 Note: Error bars represent standard error of proportion with CR or HGRFS.                                               the policy discussion with key stake-
 CIS = carcinoma in situ; CR = complete response; HGRFS = high-grade recurrence free survival;
 Ta disease = polyps extending into the lining of the bladder; T1 disease = tumors below the superficial                 holders held at a public meeting of the
 lining but not involving the muscular layer of the bladder wall.                                                        Midwest Comparative Effectiveness
                                                                                                                         Public Advisory Council (CEPAC) on
                                                                                                                         November 20, 2020.

                              FIGURE 2            Phase 3 Results of Oportuzumab Monatox: Complete
                                                  Response and High-Grade Recurrence Free Survival,
                                                                                                                         Summary of Findings
                                                  CIS ± Ta/T1, and Ta/T1a                                                CLINICAL EFFECTIVENESS
                                                                                                                         The systematic literature review
                              90
                                                                                                                         identified only one phase 3 single-
                              80                                                             CIS ± Ta/T1                 arm, open-label prospective study
Proportion with CR or HGRFS

                              70                                                             Ta/T1                       for nadofaragene and oportuzumab
                                                                                                                         monatox and one phase 2 study of
                              60
                                                                                                                         pembrolizumab,      making     indirect
                              50                                                                                         comparisons of relative effectiveness
                              40                                                                                         difficult. At the time of the review,
                                              71                                                                         only the pivotal trial of nadofaragene
                              30                                  58                                                     firadenovec had been published,14 and
                              20                                                      45                          42
                                        40                                                                               our review also evaluated information
                                                            28                                                           from conference abstracts, regulatory
                              10
                                                                                 21                        18            documents, and data submitted by the
                               0
                                       3 months            6 months             9 months               12 months         manufacturers.
                                                                         Time                                               The pivotal trials of nadofaragene
Note: Error bars represent standard error of proportion with CR or HGRFS.
                                                                                                                         firadenovec and oportuzumab mona-
a
  Unpublished data, Sesen Bio, 2020.                                                                                     tox included similar distributions of
CIS = carcinoma in situ; CR = complete response; HGRFS = high-grade recurrence free survival;                            patients with CIS ± Ta/T1 and non-CIS
Ta disease = polyps extending into the lining of the bladder; T1 disease = tumors below the superficial
                                                                                                                         with high-grade Ta/T1 disease and
lining but not involving the muscular layer of the bladder wall.
                                                                                                                         used the same definitions of BCG-
                                                                                                                         unresponsive disease. However, the
                                                                                                                         nadofaragene firadenovec pivotal trial

 JMCP.org | June 2021 | Vol. 27, No. 6
The effectiveness and value of nadofaragene firadenovec, oportuzumab monatox,
                                                                                                                                     799
                                                         and pembrolizumab for BCG-unresponsive non-muscle-invasive bladder cancer

                     FIGURE 3        Phase 2 Results of Pembrolizumab: Complete Response                        events (TEAEs) and discontinuation.
                                     and CIS ± Ta/T116                                                          For the 2 intravesical therapies, TEAEs
                                                                                                                generally included bladder-related
                     90                                                                                         symptoms such as irritative voiding,
                     80                                                                                         hematuria, and urinary tract infec-
                                                                                                                tion. For pembrolizumab, TEAEs
                     70
                                                                                                                included immune-mediated adverse
Proportion with CR

                     60                                                            CIS ± Ta/T1                  events (AEs) and infusion reactions.
                     50                                                                                         In the pivotal trial of nadofaragene
                                                                                                                firadenovec, 146 (93%) of 157 patients
                     40
                                                                                                                evaluated for safety reported at least
                     30                                                                                         1 TEAE, of which 14 (9%) were serious,
                     20     40.6
                                                                                                                but only 3 (2%) patients discontinued
                                             38
                                                          28                                                    due to TEAEs.14 In the pivotal trial of
                     10
                                                                              19                   19           oportuzumab monatox, 117 (88%) of
                      0                                                                                         133 patients in the safety population
                          3 months        6 months     9 months          12 months           15 months
                                                                                                                reported any TEAE, of which 19 (14%)
                                                         Time
                                                                                                                were serious, with 4 (3%) patients
Note: Error bars represent standard error of proportion with CR.                                                discontinuing treatment due to TEAEs
CI = carcinoma in situ; CR = complete response; Ta disease = polyps extending into the lining of the bladder;   (unpublished data, Sesen Bio, 2020).
T1 disease = tumors below the superficial lining but not involving the muscular layer of the bladder wall.
                                                                                                                In the pivotal trial of pembrolizumab,
                                                                                                                99 (97%) of 102 patients in the safety
                                                                                                                population reported any AE, of which
                                                                                                                26 (26%) were serious, with 10 (10%)
required a biopsy at the 12-month                            In the pivotal trial of nadofaragene               patients discontinuing due to AEs
evaluation, whereas the oportuzumab                       firadenovec, 55 (53%) of 103 patients                 (unpublished data, Merck, 2020).16
monatox pivotal trial did not. This                       with CIS ± Ta/T1 disease achieved a
biopsy could have resulted in addi-                       CR at 3 months, declining to 24% at                   LIMITATIONS OF THE
tional patients being identified as                       12 months. For patients with high-                    CLINICAL EVIDENCE
having recurrent disease who would                        grade Ta/T1 disease alone, HGRFS                      The primary limitation in the clini-
not have been found without a biopsy.                     was 35 (73%) of 48 patients at 3 months               cal evidence for these 3 agents is the
Efficacy outcomes were reported for                       and 44% at 12 months (Figure 1).14,15                 lack of data from randomized con-
all eligible patients in the nadofara-                       In the pivotal trial of oportuzumab                trolled trials. The FDA permitted
gene firadenovec trial who received                       monatox, 36 (40%) of 89 patients                      single arm trials for this population
the study drug, whereas patients who                      with CIS ± Ta/T1 disease achieved a                   because randomizing patients to pla-
did not complete induction therapy                        CR at 3 months, declining to 17% at                   cebo or minimally effective therapies
were excluded in the oportuzumab                          12 months. For patients with high-                    was deemed unethical. The lack of
monatox trial. At the time of this pub-                   grade Ta/T1 disease alone, HGRFS                      head-to-head comparative data near
lication, only data from the CIS ± Ta/                    was 27 (71%) of 38 patients at 3 months               the time of launch is not unexpected,
T1 cohort of the pivotal trial of pem-                    and 42% at 12 months (Figure 2;                       but the lack of randomization in the
brolizumab were available. This trial                     unpublished data, Sesen Bio, 2020).                   pivotal trials makes even indirect
included the additional inclusion cri-                       In the pivotal trial of pembroli-                  comparisons needed to guide judg-
teria that patients either be ineligible                  zumab among patients with CIS ± Ta/                   ments of relative effectiveness highly
for or decline cystectomy. The most                       T1 disease, 39 (41%) of 96 patients                   uncertain.
common outcomes reported in the                           achieved a CR at 3 months, which                         Differences in study populations
pivotal trials were complete response                     declined to 19% at 12 months (Figure 3).              between the single arm trials and
(CR) and high-grade recurrence free                       Outcomes for the Ta/T1 cohort were                    in assessing and reporting outcomes
survival (HGRFS) at prespecified time                     not available at the time of the report               further complicate the comparability
points after initial evaluation (unpub-                   (unpublished data, Merck, 2020).16                    of the trial results. Although out-
lished data, Sesen Bio, 2020; Merck,                         Harms recorded in these trials                     comes of nadofaragene firadenovec
2020).14                                                  included treatment-emergent adverse                   and oportuzumab monatox show

                                                                                                                         Vol. 27, No. 6 | June 2021 | JMCP.org
The effectiveness and value of nadofaragene firadenovec, oportuzumab monatox,
800
       and pembrolizumab for BCG-unresponsive non-muscle-invasive bladder cancer

    TABLE 1            Incremental Cost-Effectiveness Ratios Compared With                                    oportuzumab monatox were not avail-
                       Hypothetical Treatment Comparator in Patients With                                     able at the time of the report, the
                       CIS ± Ta/T1                                                                            price for nadofaragene firadenovec
                                                                                                              was set to equal the annual price of
                                                                                       Cost per year in
                                        Cost per QALY                                  progression-free       pembrolizumab ($164,337), whereas
          Intervention                     gained               Cost per evLYG              state             oportuzumab was set at $150,000
Nadofaragene firadenovec                   $151,000                $135,000                 $100,000          per year net of all rebates based on
Oportuzumab monatox                        $382,000                $343,000                 $281,000          analyst estimates. Full details on
Pembrolizumab                              $114,000                $103,000                 $76,000
                                                                                                              ICER’s cost-effectiveness analysis and
                                                                                                              model are available on ICER’s web-
CIS = carcinoma in situ; evLYG = equal value life-year gained; QALY = quality-adjusted life-year;
Ta disease = polyps extending into the lining of the bladder; T1 disease = tumors below the superficial       site at https://icer.org/assessment/
lining but not involving the muscular layer of the bladder wall.                                              bladder-cancer-2020.
                                                                                                                  For each population, we esti-
                                                                                                              mated time in progression-free state,
                                                                                                              total costs, total quality-adjusted
                                                                                                              life-years (QALYs), total equal value
    TABLE 2            Incremental Cost-Effectiveness Ratios Compared
                       With Hypothetical Treatment Comparator in Patients                                     life-years gained (evLYGs), and
                       With High-Grade Ta/T1 Disease Alone                                                    total life-years (LYs) for each treat-
                                                                                                              ment over a lifetime time horizon.
                                                                                         Cost per year        Base-case analyses were assessed
                                        Cost per QALY                                 in progression-free
          Intervention                     gained               Cost per evLYG               state            from the health care perspective. A
Nadofaragene firadenovec                    $93,000                  $87,000                 $65,000          discount rate of 3% was applied to all
                                                                                                              costs, QALYs, evLYGs, and LYs.
Oportuzumab monatox                       $123,000                 $117,000                  $88,000
                                                                                                                  The base-case cost-effectiveness,
evLYG = equal value life-year gained; QALY = quality-adjusted life-year; Ta disease = polyps extending into
the lining of the bladder; T1 disease = tumors below the superficial lining but not involving the muscular    with each drug compared with the
layer of the bladder wall                                                                                     hypothetical comparator with a 0%
                                                                                                              CR at 3 months, were $151,000 per
                                                                                                              QALY gained for nadofaragene firad-
                                                                                                              enovec, $382,000 per QALY gained for
response rates that are similar to or                    3-month CR rate could be varied in                   oportuzumab monatox, and $114,000
better than currently available treat-                   a sensitivity analysis. For the base                 per QALY gained for pembrolizumab.
ments, such as gemcitabine with or                       case, this hypothetical treatment                    Tables 1 and 2 summarize the full
without docetaxel, there continues                       was completely ineffective, with a CR                results for all incremental cost-
to be considerable uncertainty about                     of 0% at 3 months. We evaluated the                  effectiveness outcomes evaluated.
their long-term efficacy. Because                        cost-effectiveness of all treatments                 In scenario analyses, when the CR
they are administered in the bladder,                    in 2 populations: CIS ± Ta/T1 (popula-               of the hypothetical comparator was
they appear to have few serious side                     tion 1) and high-grade Ta/T1 disease                 increased to 20% in the CIS ± Ta/T1
effects. For pembrolizumab, the trial                    alone (population 2). We developed a                 population, the incremental cost-
data suggest similar response rates,                     de novo semi-Markov decision ana-                    effectiveness ratio for nadofaragene
but because it is given systemically,                    lytic model with model structure and                 firadenovec      and    oportuzumab
more patients report side effects, and                   inputs informed by key clinical trials,              monatox increased to $155,000 and
its use is associated with infrequent                    previous economic models, system-                    $407,000, respectively. We did not
but potentially serious AEs.                             atic literature reviews, and input                   conduct scenario analyses for pem-
                                                         from stakeholders (patients, advocacy                brolizumab. In the high-grade Ta/T1
LONG-TERM COST-EFFECTIVENESS                             groups, clinicians, payers, research-                population, altering the hypothetical
Lacking comparative data on which                        ers, and manufacturers).                             comparator’s CR to 30% resulted in
to base our incremental cost-effec-                         Costs and utilities for model                     incremental cost-effectiveness ratios
tiveness analysis, we evaluated all                      health states were derived from 3                    of $107,000 for nadofaragene firad-
agents compared with a hypotheti-                        key studies.17-19 Since the prices for               enovec and $147,000 for oportuzumab
cal comparator treatment whose                           nadofaragene        firadenovec   and                monatox.

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The effectiveness and value of nadofaragene firadenovec, oportuzumab monatox,
                                                                                                                             801
                                                 and pembrolizumab for BCG-unresponsive non-muscle-invasive bladder cancer

    TABLE 3            Votes on Other Benefits and Contextual Considerations for Nadofaragene Firadenovec and
                       Oportuzumab Monatox
                    1 (suggests lower value)                 2 (intermediate)                    3 (suggests higher value)
This intervention will not differentially benefit a                             This intervention will differentially benefit a historically
historically disadvantaged or underserved community                             disadvantaged or underserved community
                              5 votes                            6 votes                                  0 votes
                    1 (suggests lower value)                 2 (intermediate)                    3 (suggests higher value)
Small health loss without this treatment as measured by                         Substantial health loss without this treatment as
absolute QALY shortfall                                                         measured by absolute QALY shortfall
                              4 votes                            4 votes                                  3 votes
                    1 (suggests lower value)                 2 (intermediate)                    3 (suggests higher value)
Small health loss without this treatment as measured by                         Substantial health loss without this treatment as
proportional QALY shortfall                                                     measured by proportional QALY shortfall
                               1 vote                            7 votes                                  3 votes
                    1 (suggests lower value)                 2 (intermediate)                    3 (suggests higher value)
Will not have a significant impact on improving return to                       Will have a significant impact on improving return to work
work and/or overall productivity vs the comparator                              and/or overall productivity vs the comparator
                              3 votes                            7 votes                                   1 vote
QALY = quality-adjusted life-year.

    TABLE 4            Votes on Other Benefits and Contextual Considerations for Nadofaragene Firadenovec
                    1 (suggests lower value)                 2 (intermediate)                    3 (suggests higher value)
Uncertainty or overly favorable model assumptions                               Uncertainty or overly unfavorable model assumptions
creates significant risk that base-case cost-effectiveness                      creates significant risk that base-case cost-effectiveness
estimates are too optimistic                                                    estimates are too pessimistic
                              2 votes                            7 votes                                  2 votes
                    1 (suggests lower value)                 2 (intermediate)                    3 (suggests higher value)
Very similar mechanism of action to that of other active                        New mechanism of action compared with that of other
treatments                                                                      active treatments
                              0 votes                            3 votes                                  7 votes
                    1 (suggests lower value)                 2 (intermediate)                    3 (suggests higher value)
Delivery mechanism or relative complexity of regimen                            Delivery mechanism or relative complexity of regimen
likely to lead to much lower real-world adherence and                           likely to lead to much higher real-world adherence and
worse outcomes relative to an active comparator than                            better outcomes relative to an active comparator than
estimated from clinical trials                                                  estimated from clinical trials
                              0 votes                            3 votes                                  7 votes
                    1 (suggests lower value)                 2 (intermediate)                    3 (suggests higher value)
Will not significantly reduce the negative impact of the                        Will significantly reduce the negative impact of the
condition on the family and caregiver vs the comparator                         condition on the family and caregiver vs the comparator
                               1 vote                            9 votes                                  0 votes

                                                                                                         Vol. 27, No. 6 | June 2021 | JMCP.org
The effectiveness and value of nadofaragene firadenovec, oportuzumab monatox,
802
      and pembrolizumab for BCG-unresponsive non-muscle-invasive bladder cancer

   TABLE 5           Votes on Other Benefits and Contextual Considerations for Oportuzumab Monataox
                   1 (suggests lower value)                  2 (intermediate)                   3 (suggests higher value)
Uncertainty or overly favorable model assumptions                               Uncertainty or overly unfavorable model assumptions
creates significant risk that base-case cost-effectiveness                      creates significant risk that base-case cost-effectiveness
estimates are too optimistic                                                    estimates are too pessimistic
                            2 votes                              7 votes                                  1 vote
                   1 (suggests lower value)                  2 (intermediate)                   3 (suggests higher value)
Very similar mechanism of action to that of other active                        New mechanism of action compared to that of other
treatments                                                                      active treatments
                            0 votes                              3 votes                                 7 votes
                   1 (suggests lower value)                  2 (intermediate)                   3 (suggests higher value)
Delivery mechanism or relative complexity of regimen                            Delivery mechanism or relative complexity of regimen
likely to lead to much lower real-world adherence and                           likely to lead to much higher real-world adherence and
worse outcomes relative to an active comparator than                            better outcomes relative to an active comparator than
estimated from clinical trials                                                  estimated from clinical trials
                            0 votes                              8 votes                                 2 votes
                   1 (suggests lower value)                  2 (intermediate)                   3 (suggests higher value)
Will not significantly reduce the negative impact of the                        Will significantly reduce the negative impact of the
condition on family and caregivers vs the comparator                            condition on family and caregivers vs the comparator
                            2 votes                              8 votes                                 0 votes

   The ICER health benefit price benchmark (HBPB) is a                 deliberation of the evidence on clinical and cost-effective-
suggested price range based on cost-effectiveness thresh-              ness of health care interventions. The Midwest CEPAC is
olds at the $100,000 and $150,000 per QALY or evLYG. The               composed of medical evidence experts, including practicing
HBPB for nadofaragene firadenovec ranged from $158,600                 clinicians, methodologists, and leaders in patient engage-
to $262,000 per year. The HBPB for oportuzumab mona-                   ment and advocacy. Their deliberation includes input from
tox ranged from $92,800 to $162,100 per year. We did                   clinical experts and patient representatives specific to the
not calculate a HBPB for pembrolizumab given that its                  condition under review, as well as formal comment from
original indication was not for NMIBC. Full results are                manufacturers and the public. A policy roundtable con-
available on ICER’s website at https://icer.org/assessment/            cludes each meeting during which representatives from
bladder-cancer-2020.                                                   insurers and manufacturers join clinical experts and patient
                                                                       representatives to discuss how best to apply the findings of
LIMITATIONS OF THE COST-EFFECTIVENESS MODEL                            the evidence to clinical practice, insurance coverage, and
As noted earlier, there was considerable uncertainty in the            pricing negotiations.
long-term estimates for the effectiveness of nadofaragene                 The ICER report on treatments for BCG-unresponsive
firadenovec, oportuzumab monatox, and pembrolizumab,                   NMIBC was the subject of a Midwest CEPAC meeting on
and this uncertainty affects any cost-effectiveness analy-             November 20, 2020. Following the discussion, the Midwest
sis of these agents. The model’s base-case assumption of an            CEPAC panel members deliberated on key questions raised
ineffective (0% CR) hypothetical comparator is likely overly           by ICER’s report. The results of their votes on the clinical
conservative, so the base-case results can be viewed as the            evidence were as follows: (1) the panel voted 7-4 that the
most optimistic scenario and should therefore be inter-                clinical evidence was adequate to demonstrate greater
preted with caution.                                                   net health benefit for nadofaragene firadenovec compared
                                                                       with best supportive care; (2) the panel voted 8-3 that the

Policy Discussion                                                      evidence was adequate to demonstrate greater net health
                                                                       benefit for oportuzumab monatox compared with best
The Midwest CEPAC is one of the independent appraisal                  supportive care; (3) the panel voted 11-0 that the clinical
committees convened by ICER to engage in the public                    evidence was inadequate to distinguish the net health

JMCP.org | June 2021 | Vol. 27, No. 6
The effectiveness and value of nadofaragene firadenovec, oportuzumab monatox,
                                                                                                                          803
                                              and pembrolizumab for BCG-unresponsive non-muscle-invasive bladder cancer

benefit of nadofaragene firadenovec              lower-cost regimens and set-                   Beinfeld, McKenna, Rind, and Pearson
from oportuzumab monatox; (4) the                ting prices relative to higher-cost         are employed by ICER. Touchette received
                                                                                             funding from ICER for work on this report
panel voted 11-0 that the evidence was           options adds to the growing finan-
                                                                                             and has also received fees from Monument
inadequate to demonstrate a greater              cial toxicity of oncology care.             Analytics and AstraZeneca, unrelated to
net health benefit of nadofaragene             • It seems likely that the FDA label          this work. The University of Illinois at
firadenovec compared with pembro-                for the emerging treatments will            Chicago (UIC) and Touchette hold a pat-
lizumab; (5) the panel voted 10-1 that           be limited to BCG-unresponsive              ent for the model described in this report.
                                                                                             The model is included in ICER’s Interactive
the evidence was inadequate to dem-              patients, and payers may therefore
                                                                                             Modeler, for which a fee is paid to UIC
onstrate a greater net health benefit            wish to consider requiring docu-            and Touchette. Atlas also received funding
of oportuzumab monatox compared                  mentation of a trial of BCG as a            from ICER for work on this report.
with pembrolizumab.                              criterion for coverage.
   The CEPAC panel also voted on               • Patient groups should continue              ACKNOWLEDGMENTS
“other potential benefits” and “con-             their efforts to encourage inno-
                                                                                             The authors thank Maggie O’Grady,
textual considerations” as part of a             vation while pushing life science
                                                                                             Mrinmayee Joshi, Kanya Shah, Rick
process intended to signal to policy-            companies to generate better evi-           Chapman, and Monica Fredrick for their
makers whether there are important               dence to guide patient and clinician        contributions to this report.
considerations when making judg-                 decision making. Patient groups
ments about long-term value for                  should embrace their power to               REFERENCES
money not adequately captured in                 speak explicitly about the impact
                                                                                             1. Siegel RL, Miller KD, Goding Sauer A,
analyses of clinical and/or cost-effec-          of the high costs of treatments for
                                                                                             et al. Colorectal cancer statistics, 2020.
tiveness. Given that pembrolizumab               BCG-unresponsive NMIBC.
                                                                                             CA Cancer J Clin. 2020;70(3):145-64.
had already been available for more            • Clinician specialty societies should
                                                 rapidly move to update guide-               2. National Cancer Institute. Cancer stat
than a year, voting was focused on
                                                 line recommendations to address             facts: bladder cancer. 2021. Accessed May
nadofaragene firadenovec and opor-
                                                                                             17, 2021. https://seer.cancer.gov/stat-
tuzumab monatox. The results of                  the role of these new treatment
                                                                                             facts/html/urinb.html
these votes are shown in Tables 3-5.             options.
                                                                                             3. Kirkali Z, Chan T, Manoharan M, et al.
   The subsequent policy round-
                                                                                             Bladder cancer: epidemiology, staging and
table discussion explored how best to          DISCLOSURES
                                                                                             grading, and diagnosis. Urology. 2005;66
translate the evidence and additional          Funding for this summary was contributed      (6 Suppl 1):4-34.
considerations into clinical practice          by Arnold Ventures, California Health Care
                                                                                             4. Yeung C, Dinh T, Lee J. The health
and into pricing and insurance cover-          Foundation, The Donaghue Foundation,
                                               Harvard Pilgrim Health Care, and Kaiser       economics of bladder cancer: an updated
age policies. The full set of policy
                                               Foundation Health Plan to the Institute for   review of the published literature.
recommendations can be found in                                                              PharmacoEconomics. 2014;32(11):1093-104.
                                               Clinical and Economic Review (ICER), an
the final evidence report on the ICER          independent organization that evaluates
                                                                                             5. Davies BJ, Hwang TJ, Kesselheim AS.
website at https://icer.org/assess-            the evidence on the value of health care
                                                                                             Ensuring access to injectable generic
ment/bladder-cancer-2020. Several              interventions. ICER’s annual policy summit
                                               is supported by dues from AbbVie, Aetna,      drugs - the case of intravesical BCG
key policy recommendations follow:                                                           for bladder cancer. N Engl J Med.
                                               America’s Health Insurance Plans, Anthem,
• The FDA should require that                  Alnylam, AstraZeneca, Biogen, Blue Shield     2017;376(15):1401-03.
   manufacturers developing new                of CA, Boehringer-Ingelheim, Cambia
                                                                                             6. Brisbane WG, Holt SK, Winters BR, et al.
   treatments for BCG-unresponsive             Health Services, CVS, Editas, Evolve Phar-
                                                                                             Nonmuscle invasive bladder cancer influ-
   NMIBC use randomized trials as              macy, Express Scripts, Genentech/Roche,
                                               GlaxoSmithKline, Harvard Pilgrim, Health      ences physical health related quality of
   the basis of regulatory approval.                                                         life and urinary incontinence. Urology.
                                               Care Service Corporation, HealthFirst,
   Manufacturers should also spon-             Health Partners, Humana, Johnson & John-      2019;125:146-53.
   sor real-world comparative studies          son (Janssen), Kaiser Permanente, LEO         7. Winters BR, Wright JL, Holt SK, Dash A,
   that help evaluate a broad set of           Pharma, Mallinckrodt, Merck, Novartis,
                                                                                             Gore JL, Schade GR. Health related
   patient-relevant outcomes such as           National Pharmaceutical Council, Pfizer,
                                                                                             quality of life following radical cystec-
                                               Premera, Prime Therapeutics, Regeneron,
   quality of life and overall mortality.                                                    tomy: comparative analysis from the
                                               Sanofi, Spark Therapeutics, uniQure, and
• Manufacturers should set prices              United Healthcare.                            Medicare Health Outcomes Survey. J Urol.
   based on the added clinical value                                                         2018;199(3):669-75.
   of treatments over lower-cost
   regimens.      Leapfrogging     these

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