Does the Institute for Clinical and Economic Review Revise Its Findings in Response to Industry Comments? [Editor's Choice]



The Institute for Clinical and Economic Review (ICER) has gained prominance through its work conducting health technology assessments of pharmaceuticals in the United States.


To understand the influence of industry comments on pharmaceutical value assessments conducted by ICER.


We reviewed 15 ICER reports issued from 2017 through 2019. We quantified ICER’s revisions to its cost-effectiveness analysis (CEA) estimates between release of its draft and revised evidence reports and whether ratios shifted across ICER-specified categories of high, intermediate, or low value. We also reviewed industry-submitted comments recommending revision to ICER’s CEAs, noting ICER’s response as no change, text revised, assumption(s) revised, or conclusion revised. We evaluated each comment in terms of clarity, whether it offered an alternative to ICER’s approach, and whether it characterized the expected impact of revision on ICER’s analysis.


We identified 53 ICER-reported ratios. Of these, 45 (84.9%) changed between the draft and revised report, but 26 changes (57.8%) were small (10%). Six ratios shifted across value categories. We identified 256 industry comments recommending that ICER revise its CEA. Of these, 159 (62%) lacked clarity, 145 (57%) offered no alternative, and 243 (95%) did not characterize their impact on ICER’s estimated ratio. Ninety-one comments (35.5%) caused ICER to revise its assumptions, but only 5 (2.0%) caused ICER to revise its conclusions. Four of these 5 comments characterized their impact on ICER’s findings.


Changes in ICER’s estimates of cost-effectiveness between its draft and revised evidence reports are generally modest. Greater precision in industry comments could increase the influence of industry critiques, thus enhancing the dialogue around pharmaceutical value.


Joshua T. Cohen Madison C. Silver Daniel A. Ollendorf Peter J. Neumann

Explore Related HEOR by Topic

Your browser is out-of-date

ISPOR recommends that you update your browser for more security, speed and the best experience on Update my browser now