We appreciate the opportunity to provide our comments on the September 24th draft report,
“Biologic Therapies for Treatment of Asthma Associated with Type 2 Inflammation:
Effectiveness, Value, and Value-Based Price Benchmarks.” At the outset, we want to raise a
question about the title, which unlike recent draft reports includes “Value-Based Price
Benchmarks.” ICER states that value-based price benchmarks “are related solely to the longterm
cost-effectiveness results.”i Therefore, putting Value Based Price Benchmarks in the report
seems to tilt ICER’s analytical prejudice towards economic rather than clinical outcomes.
Additionally, since ICER also states that such value-based benchmarks “are being used by the
pharmaceutical and insurance industries to develop pricing and coverage policies,”ii we are
concerned that this also indicates that ICER’s goal is to support the economic well-being of those
companies rather than the clinical (or economic) well-being of individual patients.
