Bristol-Myers Squibb (BMS) welcomes the opportunity to participate in the Institute for Clinical and Economic Review’s (ICER) national call for suggestions on how to improve its value assessment framework. Although we agree with ICER that an evidence-driven approach to measuring treatment value is important, we fundamentally disagree on many aspects of its overall methodology of how these treatments are currently evaluated. 

It is essential that transformational medicines are accessible and affordable for patients and we believe an open, science-driven approach is critical to finding long-term solutions. We do not consider the reports produced by ICER’s process to be scientifically sound, and in turn we believe it is misleading to the community to suggest that it should be used as a tool for evaluating drug costs or restricting patient access to innovative medicines.

By failing to account for disease and patient complexity, while also narrowly focusing on a single component of the healthcare system, ICER’s value framework sidesteps any opportunity for a meaningful assessment of value. We believe in promoting a comprehensive and real-world approach to value that addresses patient priorities, total health system value over a multi-year timeline, multi-stakeholder input and the most up-to-date clinical science. 

Our comprehensive response on ICER’s value assessment framework is intended to contribute our company’s perspective on what we believe a qualitatively and scientifically accurate value framework should address. We encourage ICER to incorporate the recommendations that are outlined in our response, including:

• Include more robust clinical expertise in the evaluation design
• Remove the budget impact threshold analysis
• Increase transparency and reproducibility of methodology and processes
• Improve care value methodology
• Incorporate stakeholder critiques into methodology and processes
• Define value from patient perspective, including recognition of the heterogeneity of treatment effects

We hope that ICER takes these comments seriously and considers how to incorporate our recommendations, as well as feedback from the broader healthcare community, into its modelling and processes moving forward. Through collaboration, we believe we can find sustainable solutions that support innovation and ensure patients have access to life-saving medicines.