Hannover, Germany – Since 2011, the German AMNOG (Act on the Reform of the Market for Medicinal Products) legislation regulates drug reimbursement in an attempt to reduce national health care costs. The Federal Joint Committee (G-BA) and the Institute for Quality and Efficiency in Health Care (IQWiG) are charged with evaluating a drug’s additional clinical benefit. Benefit decisions of the G-BA affect subsequent price negotiations with insurance funds and therefore have significant impact on health care provision.
One controversial and potentially misleading assessment tool used by the G-BA and IQWiG is post hoc subgroup analysis, also termed as “slicing,” to restrict the potential pool of people who may demonstrate an additional clinical benefit and thereby impact subsequent price negotiations and related reimbursement decisions.
In their commentary, “Questioning Patient Subgroups for Benefit Assessment: Challenging the German Gemeinsamer Bundesausschuss Approach,” published in Value in Health, the authors question the validity of such post hoc analyses as a basis for important decisions of drug reimbursement at a national level. The authors maintain that G-BA/IQWiG subgrouping may exclude patients who could benefit from therapy; and subgrouping as a means to cut costs abuses the principle of evidence-based medicine. In the authors´ view, this may also lead to biased treatment decisions.
The authors put forward considerations for appropriate subgroup analyses contrasting those inappropriate to support important decision making. Specifically the authors suggest that subgroup analysis should be based on a firm and prospectively defined hypothesis that is grounded in a sound biologic rationale, such as e.g. respective biomarker testing:
Tests a hypothesis
Based on biologic rationale or at least solid previous experience
Small number (≤5) of prospectively defined subgroups
Post hoc analyses
Controversial biologic rationale; no previous experience
High number of post hoc subgroups (>5): increased risk of multiplicity
|Table 1. Characteristics of appropriate and inappropriate subgroup analyses for decision making in drug reimbursement from: Ruof J, Dintsios CM, Schwartz FW. Questioning Patient Subgroups for Benefit Assessment: Challenging the German Gemeinsamer Bundesausschuss Approach. Value Health. 2014:17:307-309.|
Ruof J, Dintsios CM, Schwartz FW. Questioning Patient Subgroups for Benefit Assessment: Challenging the German Gemeinsamer Bundesausschuss Approach. Value Health. 2014:17:307-309.
Prof. Dr. med. Jörg Ruof, MPH, Head Market Access, Roche Pharma AG, and lead author, follows up in saying that, “Subgrouping standards specific to AMNOG are urgently needed and joint GBA/regulatory advice earlier in a drug development process would be highly desirable.”
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