In July 2004, the “Institute for Quality and
Economic Efficiency in Health Care” (Institut fuer
Qualitaet und Wirtschaftlichkeit im Gesundheitswesen,
IQWiG) was officially founded and
established in Cologne in the form of a private
foundation. Most of the current assessments
were assigned in February 2005 (see below).
Some still refer to the IQWiG as the “German
NICE”, although methods and objectives are fairly
different from UK´s National Institute for Health
and Clinical Excellence (NICE).
The German institute is comparable to HTA bodies
in other countries but follows its own self-formulated
"methods" (version 1.0 of March 2005,
to be found on the institute's website). First of all,
cost-benefit assessment of pharmaceuticals is
not one of the IQWiG's tasks, although one might
come to this conclusion reading the terms
“Economic Efficiency” in the IQWiG title. Hence,
IQWiG will not consider QALYs (Quality Adjusted
Life Years) within its evaluation and there is currently
no need for health economic modeling.
Assessment process
Assessments are commissioned by the “Joint
Federal Committee” of physicians and health
insurance funds (“Gemeinsamer Bundesausschuss”,
G-BA) or the Ministry of Health.
Unlike NICE, dialog, external exchange of information
or hearing procedures of the IQWiG, e.g.
with manufacturers or patients, are not directly
subject to a formalized process.
Timelines are not as closely defined, as it is the
case for the technology appraisal process in the
UK. Approximately nine months had initially been
planned to conduct an IQWiG-assessment,
although this has not been achieved with current
assessments.
It is worth mentioning that study selection and
inclusion criteria follow IQWiG internal standards
and may vary substantially from assessment to
assessment (e.g. duration of studies included,
minimum patient number required). In many
cases; these requirements can neither be derived
from international recommendations (e.g. guidelines
by the European marketing authorization
institution EMEA or the international medical
expert societies) nor do they meet standards that
used to apply during the conceptualization and implementation of studies in these therapeutic
indications. As a result, only selected partial
quantities of the existing evidence are being
viewed.
The evaluation criteria are defined in the corresponding
"report schedules" (project descriptions)
of the IQWiG, which are issued at the
beginning of each assessment process; they are
not discussed with concerned manufacturers.
There is no such thing as a formal scoping workshop
with manufacturers, although the IQWiG is
free to consult any external expertise.
During the assessment process, the IQWiG will
seek national as well as international scientific
advice via external peer reviews to evaluate existing
data. At this stage of the assessment, external
experts are not made known to the public.
IQWiG will concentrate on head to head trials, it will focus on
morbidity and mortality and it is unlikely that IQWiG will consider
compliance or most of the commonly accepted surrogate
endpoints as relevant factors.
After internal review and publication of an
assessment pre-report, there is a timeline of four
weeks for the manufacturers and other concerned
parties to comment on the report. To
structure this input, a form is provided by the
IQWiG, restricting the comments to six pages.
There are also substantial restrictions concerning
the contents of the statement: study design etc.
may not be discussed, comments have to
address mainly formal issues of the previous
assessment, e.g. comments on studies that have
been missed by the institute.
The IQWiG may also invite patients or manufacturers
and other experts for a hearing. The hearing
is not mandatory. The (revised) report will
finally be submitted to the G-BA for further processing
and implementation.
It also has to be emphasized that none of the IQWiG´s assessments and recommendations of
the final report will become effective before the
G-BA converts the recommendations into binding
guidelines (e.g. via so-called “Arzneimittelrichtlinien”,
drug guidelines). After an IQWiG
assessment, the G-BA may or may not evaluate any further aspects (e. g. related to drug costs),
based on the IQWiG´s recommendations.
Therefore, one may consider the IQWiG as the
“assessment” body whereas the G-BA comprises
the “appraisal” committee.
There is no explicit need for the G-BA to follow the
IQWiG´s recommendations, although it might be
difficult to completely ignore the previous findings.
The G-BA may also consider the opinion of additional
experts to challenge the results of an assessment
and would then have to include additional evidence
that had previously been ignored by the
IQWiG due to restrictive data selection criteria.
However, even before any authorization and
implementation by the G-BA, one may postulate
an effect of the IQWiG´s publications (e.g. via the
internet), as physicians (and their associations)
or other organizations (as statutory health insurance companies) are certainly going to
recognize, refer to and distribute the preliminary
recommendations, e.g. to influence prescription
behavior. The relevance and effects of such a
premature use of preliminary recommendations
are highly debatable.
Main tasks of the IQWiG are (as legally defined):
-
Research, representation and assessment of
current medical findings on diagnostic and therapeutic
procedures for selected diseases;
-
Generation of scientific papers, expert reports
and statements on questions of quality and economic
efficiency of the services rendered under
statutory health insurance (SHI);
-
Assessment of evidence-based guidelines for
the most important diseases from an epidemiological
standpoint;
-
Issuance of recommendations on disease management
programs (DMP);
-
Assessment of the benefits of pharmaceuticals;
and
-
Provision of general information on the quality
and efficiency of health care services that is
understandable to all citizens
As of February 2006, 53 employees have been
hired, including 35 scientists, mainly physicians
or life scientists. The Institute's staff will be
raised to a head count of approximately 60-70
over the next years. The head of the Institute is
Prof. Dr. med. Peter T. Sawicki, a diabetologist
who had formerly been heading the department
for internal medicine of a hospital in Cologne.
Sawicki is also a critical expert for evidence
based medicine and has been involved in the
conception of guidelines for the DMP Diabetes
mellitus.
The IQWIG has six scientifically oriented departments,
responsible for data assessment and
evaluation:
-
Health Economics;
-
Department of Biometrics;
-
Department of Pharmaceutical Assessment;
-
Department for the Assessment of Non-pharmaceutical
Therapeutic Procedures, Diagnostic
Procedures and Screening Measures;
-
Department for Guidelines and Disease
Management Programs; and
-
Department for the Generation and
Methodology of Patient Information.
Two additional departments (communication and
quality management; administration) have supportive
functions. Furthermore, a “Department
for the Coordination of Studies” is planned, but
will probably be formed only after the establishment
phase of the Institute.
An internationally staffed scientific advisory
board (9 members) and a board of trustees (30
members) have consulting functions to support
the IQWiG in the process of decision-making.
Until now, however, the boards held only one
meeting.
In February 2005, the first assessments were
assigned to the IQWiG. Concerning pharmaceuticals,
a current focus of the IQWiG, the Institute is
mainly about to assess the following indications
and treatment options:
-
Hypertension;
-
Asthma and COPD;
-
Alzheimer's Dementia (Cholinesterase-
Inhibitors, Memantine, Ginkgo);
-
Diabetes (mainly insulin analogues and oral antidiabetics); and
-
Depression.
In addition, there also is a clear focus on compiling
comprehensible information for patients and
a new internet platform has recently been issued,
addressing patients´ needs with respect to a
wide variety of diseases and treatment options
(http://www.gesundheitsinformation.de/index.html). This also correlates with the Institute's frequently
expressed claim to assess “patient relevant
outcomes”.
Distribution of assignments between different
IQWiG departments (Feb. 2006):
-
Department of Pharmaceutical Assessment:
43 assignments;
-
Department for the Assessment of Non-pharmaceutical
Therapeutic Procedures, Diagnostic
Procedures and Screening Measures: 18
assignments;
-
Department for the Generation and
Methodology of Patient Information:
7 assignments;
• Department of Biometrics: 2 assignments;
-
Department for Guidelines and DMP: 2
assignments; and
-
Department of Health Economics: 1 assignment.
Looking at the assignment distribution it
becomes quite clear that approximately twothirds
of the assessments are related to evaluations
of pharmaceuticals.
The IQWiG´s first important assessment result
(in addition to a statin-assessment already published
in September 2005, which did not have a
substantial impact) is a final report for short acting
insulin analogues. It was recently published
and subsequently submitted to the G-BA. As
expected, the criteria and results of this assessment
have been very restrictive, considering only
seven out of 1017 published studies as relevant.
Finally, insulin analogues are not recommended
as a therapeutic option owing to “lack of added
value”.
Scientific acceptance and
credibility of the IQWiG now
strongly depend on
contents,
quality and implementation of
the next assessment results,
e.g. those for Cholinesterase-
Inhibitors & Antihypertensives.
Only head to head trials of the short acting
insulin analogues against the traditional insulins
have been included. Indirect comparisons are not
considered relevant. Furthermore only published
studies and only comparisons against products,
which are registered in Germany, have been
included.
Currently, the G-BA is about to implement binding
drug guidelines. This could lead to restricting
the use of insulin analogues to a certain patient
population.
In general, the G-BA´s implementation of IQWiG
assessments is crucial and does not necessarily
have to be congruent with all of the IQWiG recommendations.
However, in the case of insulin
analogues, the G-BA is going to follow the
IQWiG´s recommendation to restrict SHI-reimbursement
of this drug class.
Conclusions
In its evaluation of clinical effects, IQWiG focuses
on complications and mortality based on data
of RCTs. The first examples of IQWiG assessments
lead to the following conclusions: IQWiG
will concentrate on head to head trials, it will
focus on morbidity and mortality and it is unlikely
that IQWiG will consider compliance or most
of the commonly accepted surrogate endpoints
as relevant factors.
The core points one might criticize regarding IQWiG procedures are a lack of specification
regarding assessment criteria; and that essential
parts of the IQWiG paper on methods have not
been put in more specific terms. Currently, the
method paper is being re-evaluated by the
IQWiG. The new version should therefore also
include the development of a scientifically substantiated
benefit concept, as this has not been
defined in the method paper that is now being
used for benefit assessment.
The transparency and participation principle
needs to be further implemented. During the
process of benefit assessment, the IQWiG must
not shut itself off from structured professional
dialog with the manufacturers concerned. The
process that has been established with drug regulatory
bodies and authorities (e. g. EMEA or the
German BfArM) may very well serve as an example
of such a structured and transparent dialog.
To allow this valuable discussion and exchange
of information, the IQWiG may not rely on separation
but should intensify communication, also
with corporate experts, e.g. for scoping issues.
The IQWiG primarily evaluates the published
results of controlled clinical endpoint studies
(randomized controlled clinical trials, RCTs). As a
result, benefit assessment is abbreviated to a
secondary test of the efficacy of pharmaceuticals
based on the clinical studies submitted
during the marketing authorization process. An
evaluation like that could also be achieved by a
mere Cochrane review.
The effect of pharmaceuticals under everyday
conditions is largely ignored, although the benefit
of drugs shows itself in practical application
compared to specifically available therapeutic
alternatives.
It is therefore also important to select an adequate
point in time for the assessment and to
apply a broad methodical assessment approach.
Benefit assessments, especially those of innovative
pharmaceuticals, should not be made directly
after and certainly not before marketing
authorization. Recently, there have been two
assignments by the G-BA to conduct assessments
for new drugs (for the treatment of diabetes)
even before the official marketing authorization
was granted for the German market. At this
point, the practical benefit of a pharmaceutical
under everyday conditions cannot be proven.
Broad application experience will only be available
a few years after marketing authorization.
Depending on the therapeutic indication, a time
window of at least three to five years between
marketing authorization notification and assessment
commission would seem appropriate.
Scientific acceptance and credibility of the IQWiG
now strongly depend on content, quality and
implementation of the next assessment results,
e.g. those for Cholinesterase-Inhibitors and
Antihypertensives. The restrictive evaluation of
insulin analogues does confirm some of the initial
criticism that has been associated with the
IQWiG.
As mentioned before, G-BA and BMG
(Bundesministerium fuer Gesundheit, MoH) also
play a crucial role, as the G-BA is responsible for
the final appraisal and implementation of the
Institute's recommendations and the BMG takes
responsibility for the legal supervision. It remains
to be seen to which extent certain political objectives
or even public pressure will influence this
final step of the appraisal process, especially in
the light of the on-going process of the German
health care reform and cost-containment measures.
In the end, similar to NICE changing its appraisal
process and participation policy over the years, it
will be exciting to see how long it takes until first
relevant changes of the IQWiG´s assessment
process will be implemented.
Further details and publications concerning the IQWiG may be found on the internet on the institute's
homepage: http://www.iqwig.de/.