SWHR Input on ICER Migraine Therapies Draft Report

Policy Engagement

Published 5/8/18

SWHR submitted comments to the Institute for Clinical and Economic Review (ICER) on ICER’s new draft report regarding the effectiveness and value of calcitonin gene-related peptide (CGRP) inhibitors. CGRPs represent a new class of preventive therapies for episodic and chronic migraine. Migraine disproportionally affects women. Additionally, current preventive treatment options are suboptimal for most patients. New treatment options are therefore long overdue.

SWHR provided multiple recommendations for improving the ICER migraine therapies methodology used to analyze the budget impact of CGRP inhibitors. Women show higher prevalence of migraine, making it crucial that data be stratified by sex and quality of life measures be evaluated to ensure proper reflection of their experiences. Additionally, wholesale acquisition cost (WAC) does not take into account rebates and discounts, meaning that it may be an incorrect estimate of the financial burden of these drugs. ICER should ensure to accurately reflect direct care costs of migraine by using appropriate cost and health care data and using robust sensitivity analyses around resource and cost estimates.

See SWHR’S Full Comments Here