Trends in Use of Cost-Minimization Analyses in CDA-AMC Reimbursement Submissions

OBJECTIVES: Canada's Drug Agency-L’Agence des medicaments du Canada (CDA-AMC) accepts a cost-minimization analysis (CMA) in place of a cost-utility analysis when an intervention is an additional drug in a therapeutic class already reimbursed for the indication and the intervention has similar effectiveness to relevant comparators. In January 2024, CDA-AMC revised its criteria to no longer require sponsor-submitted CMAs to demonstrate cost savings of the intervention relative to comparators and signalled greater use of CMAs in re-analyses. This study evaluated the CMA trends pre- and post-revision.
METHODS: Sponsored submissions were identified from the CDA-AMC website within a one-year time frame pre- and post-criterion revision, as well as years 2019 onwards. The submitted economic evaluation, CDA-AMC re-analysis, and final recommendation were captured.
RESULTS: Of 87 sponsor submissions with review reports available, 65 were pre-revision and 22 post-revision, reflecting ongoing post-revision reviews. There were nine CMAs submitted, with annual sponsor-submitted CMA rates of 13.8% pre-revision vs. 0.0% post-revision. The number of CMAs were roughly equal between oncology products (4/25 [16.0%]) and non-oncology products (5/40 [12.5%]), with all receiving conditional recommendations. The number of sponsor-submitted CMAs varied year over year between 2019-2024 (0.0%, 7.1%, 14.7%, 5.5%, 14.1% and 0.0%). The number of CMA re-analyses conducted by the CDA-AMC following a sponsored cost-utility analysis pre- and post-revision were both 0.0% however, rates varied between 2019-2024 (0.0%, 4.8%, 5.3%,4.1%, 0.0%, and 0.0%).
CONCLUSIONS: Sponsor-submitted CMAs to CDA-AMC are a minority of submissions and were not used in any completed reimbursement reviews since the change to CMA criteria. However, this study was limited by a small sample size of completed post-revision reviews. Analysis of the last five years suggests no obvious trend in the annual proportion of submitted CMAs or CMA re-analyses by the CDA-AMC.