How much will Herceptin really cost?
BMJ 2006; 333 doi: https://doi.org/10.1136/bmj.39008.624051.BE (Published 23 November 2006) Cite this as: BMJ 2006;333:1118All rapid responses
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Thank you for your thoughtful article about the difficult choices
that arise from the NICE recommendation about Herceptin. As a Chair of a
PCT that refused to fund Herceptin before it was licensed and had been
assessed by NICE I have been very involved in these debate. I agree that
NICE has not really resolved the issue as no guidance is given as to dis-
investment. This issue is at the heart of robust commissioning and as the
other reactions to your piece show, the decision rules must include
equity, cost-effectiveness and the assessment of quality of life. The
perspective of patients and their social networks must be taken into
account, and therefore you are correct in raising the profile of the 'non-
sexy' and predominantly chronic conditions. It is interesting that
research and our experience as PCTs show that when asking the public what
should be prioritised they will identify mental health, degenerative
diseases and prevention; however, when faced with individual choices about
so-called life-saving treatments, preferences centre around cancer and
other diseases that are perceived to be life-threatening. PCTs as strong
commissioners will have to play a prominent role in supporting clinicians
in facing up to the media, politicians and forceful patient groups to
disseminate the sort of information that you provide and to continually
emphasise that choices about dis-investment will have to be made if new
treatments are to be funded. These choices must balance individual need
and 'the common good' and require wide involvement and ownership. A close
partnership between PCTs, providers and clinicians is central to this
endeavour, and the type of evidence that you have provided will play an
important role in the continuing drive to offer equitable and evidence-
based patient care.
Competing interests:
None declared
Competing interests: No competing interests
The authors of How much will Herceptin really cost should be
congratulated both on their article in BMJ 25th November and for their
defence of it on the Today programme, BBC Radio 4. It provided a
refreshing and honest account of how a much publicised national dispute
has impacted at the local NHS trust level. Herceptin, whilst being a
useful tool in the treatment of some breast cancer patients has become the
latest ‘wonder drug’ in the eyes of the public.
I agree with the authors’ conclusion that NICE (National Institute
for Health and Clinical Excellence) should be given responsibility to
decide the cuts needed to fund newly recommended technologies; but the
general public do not acknowledge that healthcare is rationed. People
believe that scientific discovery is the main obstacle to curing disease,
and that once medical research has found the answer it should be available
for all. Public expectation is often in front of scientific discovery,
but is certainly racing ahead of the reality at ‘the coal face’ of medical
care. The discrepancy is getting wider and wider with each new
technological or therapeutic advance.
The discussion as to who gets which treatment, and when, needs to be
brought out into the open. Doctors and NICE have important roles in
rationing healthcare, but I believe society as a whole must accept some of
the responsibility for these difficult decisions. The public needs to
accept that healthcare is a finite resource. The long term problem of
funding new treatments will not be solved by doctors taking a pay cut as
suggested in the Radio 4 discussion, but by society accepting that modern
healthcare is a privilege to be distributed wisely and not a human right
to be demanded by those who can shout the loudest.
Competing interests:
None declared
Competing interests: No competing interests
Dear Editor, Barrett et al have written a powerful and useful paper,
which clearly picks out a significant problem with the present structure
of the health care prioritisation process in the UK.[1] This problem is of
course that while it is good that we have a body like NICE giving us cost
effectiveness recommendations. Without either the same or another body
having the responsibility for implementing these recommendations and
balancing the books, or having cost effectiveness recommendations for all
other already available treatments it is unclear how we ought to react to
these recommendations.
They are absolutely right that opportunity cost needs to be
considered. As other respondents have pointed out there is considerable
scope for saving money in our present practise, for example by using
generic medicines. New Zealand for example has actually reduced its
overall spending on pharmaceuticals while maintaining and increasing the
range of treatments available since 1998, mainly through the use of
generics and bulk purchasing.[2]
However, these measures are palliative rather than curative, they may
reduce our present need to prioritise health care, they will do little to
reduce our future need to implement prioritisation, to give just one
example of the potential new costs it is estimated that the costs of pig
xenografting will be 10 billion US$ / year by 2010 and that this market
will by that stage have only barely begun to reduce the pool of dialysis
patients.[3]
The real issue at stake here is what is the opportunity cost of using
cost effectiveness as our only, or at least primary tool of
prioritisation?
It is suggested that there are three main objections to using cost
effectiveness alone.[4]
1. Equality:
Suppose we can either distribute our resources such that either A, B &
C all end up with 10 units of value each or we can distribute resources
such that A ends up with 30 & B & C end up with 1. Cost
effectiveness recommends the second outcome which seems counter-intuitive.
2. Deservingness:
Suppose we can distribute our resources such that either A can get 7 &
B can get 3 or A can get 4 and b can get 7. Suppose the difference between
the two patients is that A's condition has nothing to do with their own
actions, indeed they have aimed to be fit and healthy all their life,
eaten right, only had that one glass of wine etc. B on the other hand is
an unrelenting risk taker and their condition has come about as a result
of their risk taking. (Be it smoking or bungee jumping... whatever you
think is a clear case of their condition primarily being as a result of
their own activities.) We might think it is unfair to consider the
treatment B prior to the treatment of A but again cost-effectiveness
recommends that we ought to.
3. Non-medical factors:
Traditionally cost effectiveness considers all factors which have an
effect on the outcome, regardless of whether they are medical factors or
not. But it is commonplace in medical practise to consider some factors
which are relevant to the outcome in terms of utility as factors that
shouldn’t be considered when we are deciding whether or not to treat. So
for example what the effects on the respective families will be, whether
the patient has good job prospects etc. Even if the consideration of
utility is just limited to medical considerations, such as the likelihood
of patient survival, there is some evidence that this is influenced by
factors we think shouldn't be used to influence medical decisions, so for
example one study showed that low income Americans had significantly lover
survival rates than high income Americans for 12 out of the 15 cancers
examined.[5] If this is generally the case then the utilitarian has
grounds for preferring to fund health care treatment of the affluent over
the poor because of its increased efficiency.
So which principles should we use? Well that is up for debate, but we
ought to at least consider some of the more egalitarian accounts of
distributive justice in health care such as those developed by Norman
Daniels, Robert Veatch and Ronald Dworkin as alternatives or at least
constraints on the consequentialism embraced by cost
effectiveness.[6][7][8][9][10][11]
References:
1.Ann Barrett, Tom Roques, Matthew Small, and Richard D Smith How much
will Herceptin really cost?
BMJ 2006; 333: 1118-1120
2. National Advisory Committee on Health and Disability, Prioritising
Health Services: A background paper for the National Health Committee.
2004.
http://www.nhc.govt.nz/publications/PDFs/prioritisation-
backgroundpapers.pdf
3. Hancock WW. The Business of xenotransplantation. American Society of
Transplant Physicians Newsletter. 1997; 4(4).
4. Beauchamp, Tom L. Walters, LeRoy. Justice in the distribution of
health care. In: Contemporary Issues in Bioethics. Fourth Edition.
Belmont, CA: Wadsworth; 1994: 675-752.
5. Gorey, K. et al, “An International Comparison of Cancer Survival:
Toronto, Ontario and Detroit Metro Areas,” American Journal of Public
Health 87(7):1156-1163 (07/1997)
6. Beauchamp, T. and Childress, J. Principles of Biomedical Ethics, 5th
ed. New York: Oxford Univ. Press, 2001.
7. Daniels, N., Just Health Care. Cambridge: University Press, 1985.
8. Daniels N, Sabin J. Setting Limits Fairly: Can We Learn to Share
Medical Resources? Oxford: Oxford University Press, 2002.
9. Veatch, R. “Justice, the Basic Social Contract, and Health Care.
Reprinted in Contemporary Issues in Bioethics 5th edition, edited by Tom
L. Beauchamp and LeRoy Walters (Belmont, CA: Wadsworth, 1999),pp.368–374.
10. Dworkin, R. Sovereign Virtue: The Theory and Practice of Equality.
London: Harvard University Press, 2000.
11. McMillan J, Sheehan M, Austin D, Howell J. Ethics and opportunity
costs: have NICE grasped the ethics of priority setting? J Med Ethics,
Vol. 32, No. 3. (March 2006), pp. 127-128.
Competing interests:
None declared
Competing interests: No competing interests
The paper by Barrett et al. (1) shows that, when a single budget is
used to cover drug treatments historically approved as well as innovative
drug treatments, innovation can be adopted only by cutting well-settled
drug treatments. But, as the authors point out, this approach is a
nonsense from all points of view and, more importantly, implies that there
can never be any amount of money for innovative drugs. One relatively
simple solution to this problem is to identify two separate drug budgets:
the first for “historical” treatments and the second for innovative
treatments. Of course, deciding the two respective proportions in which
an overall budget can be split is difficult. Anyhow, once this decision is
made, the budget for historical treatments should simply be directed to
maintaining the historical levels of standard drug therapies; on the
other hand, cost-effectiveness could be the main factor to guide
decisions about the adoption of innovative drugs. Why shouldn’t we use
costs per life year gained for priority setting in the field of drug
innovation? Aren’t they designed exactly for this purpose? For example,
adjuvant trastuzumab for early breast cancer [cost per life year gained =
$27,800 (2)] should clearly have priority over erlotinib for non small
cell lung cancer [cost per life year gained =$71,000(3)], and so on. No
matter how many patients are potential candidates to the individual
treatments examined. Giving too importance to the number of potential
patients in the application of cost-effectiveness could result in the same
mistake in terms of equity as in the case recently shown for orphan drugs
priced at excessive values (4).
REFERENCES
1. Barrett A, Roques T, Small M, Smith RD. How much will Herceptin
really cost? BMJ 2006;333:1118 - 1120
2. Garrison LP, Perez EA, Dueck A, Lalla D, Paton V, Lubeck D. Cost-
effectiveness analysis of trastuzumab in the adjuvant setting for
treatment of HER2+ breast cancer. J Clin Oncol. 2006 ASCO Annual Meeting
Proceedings Part I. Vol 24, No.18S (June 20 Supplement), 2006:6023
3. Canadian Agency for Drugs and Technologies in Health. Common Drug
Review: Erlotinib, Cedac Final Recommendation, 6 December 2005,
http://www.cadth.ca/ accessed on 24 November 2006
4. McCabe C, Claxton K, Tsuchiya A. Orphan drugs and the NHS: should
we value rarity? BMJ 2005;331:1016-1019
Competing interests:
None declared
Competing interests: No competing interests
Barret et al(1) identify many issues in their analysis of the
consequences of NICE’s ruling on Herceptin. They point out that “the real
cost of Herceptin is in the other patients not treated, whether they are
patients with cancer or those with other conditions” i.e. the opportunity
cost. They conclude that “medical professionals ultimately have to make
these difficult decisions” but they ought to go further and acknowledge
the competing demands that medical professional across multiple
disciplines place on limited resources and also recognise the
responsibility on medical professionals to ensure the judicious use of
publicly funded resources.
If as they say, it seems that no one has suggested which treatments
should be cut then it may be because they have not looked widely enough
for the answers. Moon and Bogle recently highlighted savings of £1.1
billion over five years available from promoting the generic substitution
of statins used for the primary and secondary prevention of cardiovascular
disease(2). The Strategic Health Authority covering the oncology centre
where Barret et al are employed estimates that it can save £20 million
pounds from implementing such a generic substitution policy(3). This would
have no significant impact on patient care. These potential savings
reflect inefficiencies arising from prescribing decisions that may be
viewed as averted wastage. It is too easy to blame NICE when healthcare
professionals can do so much more to make more judicious use of what has
already been provided.
Clinicians currently have little incentive to seek prescribing
savings particularly if savings are then used to stem deficits. Devolving
prescribing costs into locally held unified budgets for clinical service
delivery across multiple disease areas would promote negotiation and
priority setting. This would ensure that the opportunity costs and
potential benefits of resource allocation strategies were directed toward
the environment where the decisions are made rather than indirectly
impacting on other unrelated areas. Oncologists, cardiologists and GP’s
working at the “clinical coal face” would have to talk to each other and
ensure the sensible use of public funds. Primary Care Trusts would have to
improve their performance considerably(4).
Introducing a system of ‘reference pricing’ where drug reimbursement
is pegged to the price of a therapeutically equivalent generic drug could
do much to resolve these types of issues at source. Clinicians could
decide whether to pay a premium for a non-generic drug from regional
budgets or fund new technologies such as Herceptin.
External pressures that should not determine who is treated and what
they are treated with can affect prescribing decisions made by medical
professionals. Specialist professional groups that adopt a narrow
viewpoint can play such a countervailing role. Their guidelines are
usually uncosted and promote recomendations that do not consider the
impact across other specialties. Suggested targets for reducing
cholesterol advocated by the Joint British Societies(5) are a prime
example of recommendations for clinical practice that are likely to have a
significant resource impact, are completely uncosted and may cause harm by
constraining resources such as those for oncology care. Uncosted
recommendations are inexpensive to make but may be expensive to implement
in both mortality and financial terms.
Disinvestment will promote allocative efficiency but as clinicians we
must also disinvest ourselves of a myopic clinical mindset that results in
“silo medicine”. Expecting NICE to provide the all the answers is to be
blind to our own faults and only shifts the blame.
REFERENCES
1. Barrett A, Roques T, Small M et al. Rationing. How much will
Herceptin really Cost? BMJ 2006;333:1118-1120 (25 November),
2. Moon JC, Bogle RG. Switching statins. BMJ 2006;332: 1344-5. (10
June.)
3. Statins - the SHA perspective. Achieving Clinical Efficiency. A
practical case study. Kate Gill, Head of Service Development, East of
England SHA
http://www.heart.nhs.uk/scripts/default.asp?site_id=23&id=28050 (accessed
24 November)
4. O’ Dowd A. Watchdog brands two thirds of NHS trusts as "fair" or
"weak"
BMJ 2006;333:769 (14 October)
5. British Cardiac Society, British Hypertension Society, Diabetes
UK, HEART UK, Primary Care Cardiovascular Society, The Stroke Association.
JBS 2: the Joint British Societies' guidelines for prevention of
cardiovascular disease in clinical practice.
Heart 2005;91 (suppl V):v1-v52.
Competing interests:
Over the past 12 months RM has attended advisory boards for Novartis and Pfizer. Over the past 10 years RS has attended educational meetings, received travel grants, honorariums for lectures, and advisory boards from a number of pharmaceutical companies including AstraZeneca, Bayer, Fournier, GlaxoSmithKline, Pfizer, Merck, MSD, and Sanofi-Aventis. RM is a member of the Primary Care Cardiovascular Society and the South Asian Health Foundation. RM is an appraisal committee member within NICE and a participant within NICE guideline development groups.
Competing interests: No competing interests
Dear Editor
Barrett et al. elegantly demonstrate that the true cost of Herceptin
is the benefit foregone from alternative treatments that resources do not
now permit to be prescribed (the ‘opportunity cost’). However, I disagree
with their recommendation that NICE should be given the authority to
decide which services should be cut to fund newly recommended
technologies.
Primary Care Trusts (PCTs) are responsible for providing an
appropriate mix of services to best meet the needs of their populations.
These needs vary from location to location (the needs of rural Norfolk are
very different from, say, those of inner-city Nottingham). Because
resources are finite it is not possible to provide everything, everywhere
to everyone. Therefore services must vary from area to area. To put it
another way, ‘post-code prescribing’ is the raison d’être of a PCT.
Because needs vary, the opportunity cost of NICE decisions varies,
and thus the most appropriate services to trim to make way for NICE
approved technologies must vary. It would therefore be inappropriate for
NICE to dictate which services not to provide (although suggestions of
less cost-effective services to consider restricting would, no doubt, be
of assistance).
Following the same reasoning, it is also inappropriate for NICE to
dictate what services PCTs should provide. Under current legislation,
PCTs have to provide funding for approved drugs (although this is not the
case for other NICE output: guidelines, surgical interventions and public
health guidance). This obligation distorts local priorities with a
resulting potential loss of health gain to the population (1).
This should be scrapped and NICE technology appraisals made advisory.
PCTs and clinicians could then incorporate the guidance to best meet the
needs of (and so maximise the health of) their local populations.
Yours faithfully
Ed Wilson
(1) Wilson E, Sussex J, Macleod C, Fordham R. Prioritizing health
technologies in a primary care trust. Journal of Health Services Research
and Policy (In Press).
Competing interests:
None declared
Competing interests: No competing interests
The herceptin problem is yet another example of how much breast
cancer is costing not only those of us who get it but everyone. The No
More Breast Cancer Campaign argues that far greater efforts and resources
must be put into preventing the disease from occurring in the first place.
In any one year, breast cancer is devastating the lives of nearly a
quarter of a million women in the UK: women who are newly diagnosed, those
living with the disease from diagnoses made in the previous decade, and
fatalities. Incidence is rising across all age-ranges.
The No More Breast Cancer Campaign rejects the vision, put forward by
Karol Sikora and other key cancer strategists, that breast cancer will in
the future become an almost ubiquitous, non-fatal disease, to be
controlled by pharmaceutical drugs. The ‘good news story’ of improving
mortality rates must also be qualified. Unpublished government data,
recently obtained by the No More Breast Cancer Campaign, indicate that
mastectomy rates (total excisions) in England and Wales between 1990 and
2005 have increased 44 per cent overall. Most disturbingly, the upward
trend is just as drastic in women aged 15 to 44 years old, at 41 per cent,
evidence that breast cancer is rising in all age groups, and is not just a
disease of ageing.
The government must act urgently on pollutants. Endocrine-disrupting
chemicals in our food and in consumer products are suspected to contribute
to breast cancer. Over a third of the food we buy is contaminated with
pesticide residues, for example. The current regulation of chemicals in
cosmetics and consumer products is still poor, and the UK government must
support a strong European Chemicals Directive to protect human health.
When prevention becomes a priority, and the focus of the National
Health Service is on health rather than disease management, doctors will
faced less often with the kind of apalling dilemmas described by Ann
Barrett and colleagues.
www.nomorebreastcancer.org.uk
Competing interests:
None declared
Competing interests: No competing interests
I'm glad that rationing has explicitly been brought up, and that this
paper has been picked up by the broadsheets.
As a practice, and with the help of a pharmacist, we spend time trying to
save several thousand pounds a year on our prescribing (and I think that
is only correct within reason). But this is blown out of the water by
decisions like this.
How independent is NICE?
Is it now backing the ridiculous stance that Patricia Hewitt took some
months ago in prejudging her own advisory mechanisms? Or is Big Pharma
more pervasive than we think? (1)
Whatever, we need to open an urgent debate on cost effectiveness.
Can I start by suggesting that in the light of recent evidence breast
screening is re-examined?
(1) NEJM 2006;355;2169 Dangerous deception - hiding the evidence of
dangerous drug effects.
Competing interests:
None declared
Competing interests: No competing interests
How much will Herceptin really cost?
Herceptin for early stage breast cancer is a cost- effective
treatment and it is right that the NHS should make it available. The
challenge of funding new treatments and balancing local and national
priorities is one the NHS has faced since its inception. The process NICE
follows for evaluating new medicines is the most rigorous anywhere in the
world, and local NHS organisations can have confidence that implementing
our recommendations is an effective use of their resources.
The Institute's independent advisory committees do not 'rubber stamp'
decisions. They make them based on an objective and impartial
interpretation of the evidence. Those who suggest otherwise should come
forward with their evidence for doing so.
It is wrong to suggest that a single recommendation from NICE will
necessarily cause other services to be reduced and that these decisions
are made only by clinicians. There are many demands made on available
funds in any hospital at any one time and it is the responsibility of
local NHS management, working with their clinical teams to make the best
use of these resources. This difficult job is made easier by NICE guidance
and the support tools we offer, such as our commissioning guides and our
forthcoming advice on shifting spending from less to more effective
treatments.
Yours sincerely,
Professor Peter Littlejohns
NICE Clinical and Public Health Director
Andrew Dillon
Chief Executive
Competing interests:
None declared
Competing interests: No competing interests
NICE approval for adjuvant breast cancer treatments
In their recent article (1) Barrett et al add to the debate on
funding of expensive cancer treatments that are approved by the National
Institute of Clinical Excellence (NICE). The issue in breast cancer
treatment is not limited to Herceptin.
NICE recently published two single technology appraisals regarding
the use of the taxanes, paclitaxel (2) and docetaxel (3), for the adjuvant
treatment of early node-positive breast cancer. Use of a docetaxel-
containing regimen was approved. Paclitaxel was not recommended on the
grounds that there has not been a trial of paclitaxel-containing
chemotherapy compared with a ‘modern’ anthracycline-based regimen.
However, a randomised trial directly comparing the two drugs and including
almost 5000 patients has shown only minor differences in efficacy between
paclitaxel and docetaxel, with a small advantage for a regimen of weekly
paclitaxel (4). NICE did not feel it was in their remit to consider
results from this trial in their assessments of adjuvant taxanes.
Comments in the eBMJ to the Barrett paper have suggested that cost
savings could be made by greater use of generic treatments. Paclitaxel is
available generically with possible bulk-purchase price reductions,
whereas docetaxel remains under patent as Taxotere. Pharmaceutical company
marketing of paclitaxel is now limited. The cost per patient treated using
docetaxel is approximately £2500-£4500 greater than using paclitaxel. This
is likely to be an under-estimate as the docetaxel regimens also require
greater support with colony stimulating factors in view of higher febrile
neutropaenia rates. The number of patients eligible for adjuvant taxanes
will be greater than those eligible for adjuvant herceptin.
As the result of the NICE adjuvant taxane guidelines it is likely
that any use of generic paclitaxel will be reduced or curtailed. Trusts or
Cancer Networks may feel obliged to use the more expensive brand-named
docetaxel. As with herceptin, there are issues about how this will be
funded.
1.Barrett A, Roques T, Small M, Smith RD. How much will Herceptin
really cost? BMJ 2006;333:1118 – 1120
2.NICE. Technology appraisal guidance - No 108. Paclitaxel for the
adjuvant treatment of early node-positive breast cancer. 2006.
3.NICE. Technology appraisal guidance - No 109. Docetaxel for the
adjuvant treatment of early node-positive breast cancer. 2006.
4.Sparano JA, Wang M, Martino S, et al. Phase III study of
doxorubicin-cyclophosphamide followed by paclitaxel or docetaxel given
every 3 weeks or weekly in patients with axillary node-positive or high-
risk node-negative breast cancer: results of North American Breast Cancer
Intergroup Trial E1199. Proceedings of the San Antonio Breast Cancer
Symposium 2005. Abstract 48.
Competing interests:
None declared
Competing interests: No competing interests