Amgen’s Response to ICER’s Draft Scoping Document on Targeted Immunomodulators for the Treatment of Moderate-to-Severe Plaque Psoriasis: Effectiveness and Value (Condition Update)

Amgen appreciates the opportunity to comment on ICER’s draft scoping document on Targeted Immunomodulators for the Treatment of Moderate-to-Severe Plaque Psoriasis: Effectiveness and Value (Condition Update).  Amgen has been committed to helping patients with psoriasis for over 20 years and understands the impact of the targeted immunomodulators in substantially changing the lives of patients. 

As ICER performs this Condition Update, Amgen is encouraged by and supports ICER’s choice to utilize the previous methodology employed in the ICER’s 2016 Targeted Immunomodulators for the Treatment of Moderate-to-Severe Plaque Psoriasis: Effectiveness and Value Final Evidence Report.  ICER’s previous analysis demonstrated that targeted immunomodulators provide a “substantial net health benefit” and are “well aligned with commonly-accepted thresholds of cost-effectiveness.”  Using the same methodology will not only allow ICER to reconfirm the results of the previous analysis, but also, provide an opportunity for a comparison of the new results to the old, with the only variable being the update for new data. 

In addition, we would also like to take this opportunity to highlight several areas which could be reinforced and improve the outcomes and modeling efforts based on the previous assessment.  We believe that the consideration of these factors may allow ICER to capture the full value of these therapies. Specifically, ICER should employ a patient-centric approach as follows:

• Incorporate the varied individualized patient response and use a societal perspective as the primary analysis in this patient centric disease
• Include the effects from multiple comorbidities such as joint and cardiovascular complications
• Factor in the long-term safety profiles and efficacy and adherence data since psoriasis patients often develop severe disease early in life and remain on these agents for years

We hope that these enhancements will further incorporate the patient perspective in the assessment, reinforce the importance of greater therapeutic choices, and reconfirm the recommendation to insurers that step therapy should be limited or abolished.  

Amgen will engage in the ICER Condition Update process as a patient-centered organization that is invested in continuing patient access.  Since the new evidence has shown improved or similar efficacy, across the new and existing drugs, it would be expected that ICER’s findings reinforce the previous results of the tremendous value to psoriasis patients.  If this is the case, ICER will have the opportunity to strengthen its previous recommendations to open access to appropriate patients for these agents.