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The New Zealand Medical Journal

 Journal of the New Zealand Medical Association, 28-October-2005, Vol 118 No 1224

PHARMAC responds on long-acting insulin analogues
A Special Series article in August by Dr Jeremy Krebs discussed the timing of funding of long-acting insulin analogues in glycaemic control in diabetes (http://www.nzma.org.nz/journal/118-1221/1641/). We respond to three issues raised by Dr Krebs: process; availability of long-acting insulin analogues internationally; and cost-effectiveness.

Timeframes and PHARMAC’s processes

PHARMAC aims to ensure fair allocation of funding across competing new medicines, and must ensure appropriate targeting of medicines to get best value for money. For this reason, our processes for assessing new pharmaceutical funding applications are necessarily diligent. PHARMAC’s process involves both expert clinical review, negotiation with suppliers, consultation with the health sector, and then decision by PHARMAC’s Board. The process is described in the Attachment to this letter.
For insulin glargine, the most significant delays have been caused elsewhere. Insulin glargine has been registered for use in New Zealand since June 2001, following first application to Medsafe for registration in May 1999—some two years earlier. Insulin glargine was then registered for three years before the supplier applied to PHARMAC for funding in July 2004.
We have had the application to list insulin glargine for little over a year, during which time:
  • The Pharmacology and Therapeutics Advisory Committee (PTAC)1 or its Diabetes subcommittee (one of eleven expert subcommittees) have reviewed the application four times—as part of obtaining satisfactory expert clinical advice (including information gaps). PTAC originally recommended a low priority for listing insulin glargine for the patient population proposed; hence PTAC referred the application to its Diabetes subcommittee to develop appropriate targeting criteria.
  • The application has also undergone further economic evaluation, at PTAC’s request (PTAC had concerns with the original cost utility analysis (CUA) submitted by the supplier).
  • In response to an application from another supplier for insulin detemir (another long-acting insulin analogue), PHARMAC’s economic evaluations and the Diabetes subcommittee have also this month looked at long-acting insulin analogues as a whole.
The next steps will be for PHARMAC to negotiate with the suppliers of both insulin glargine and insulin detemir for a commercial arrangement to list one or both long acting insulin analogues; any agreed proposal(s) would then be consulted on and considered by PHARMAC’s Board. Any proposals for the listing of any long-acting insulin analogues would be subject to the standard decision criteria that all proposals are weighed against, and prioritised alongside competing new medicines at the time.
Timelines for the applications to PHARMAC for long acting insulin analogues are detailed in the Attachment to this letter. Available relevant minutes of PTAC and Diabetes subcommittee meetings are also included in the Attachment.

Long-acting insulin analogues are not funded in Australia nor recommended for funding in Canada

Neither insulin glargine nor insulin detemir is funded in Australia. The New Zealand application for insulin glargine coincided with an application to the Pharmaceutical Benefits Advisory Committee (PBAC) in Australia. The Pharmaceutical Benefits Advisory Committee (PBAC) has since already rejected insulin glargine and deferred a decision for insulin detemir:
The Canadian Expert Drug Advisory Committee (CEDAC) (https://www.ccohta.ca/CDR/cdr_pdf/cdr_submissions/Complete/cdr_complete_Lantus_2005Sept28.pdf) has recently recommended that insulin glargine not be listed, citing inter alia no significant differences in 21 open-label RCTs between insulin glargine and NPH (or ultralente) insulin in the incidence of severe symptomatic hypoglycaemia. CEDAC also did not feel that the claimed differences in clinically important outcomes in favour of insulin glargine over NPH insulin justified the three-fold difference in cost.

Cost-effectiveness

Long-acting insulin analogues aim to achieve at least as good glycaemic control as insulin isophane (insulin NPH) while reducing the frequency and severity of hypoglycaemic episodes. At PTAC’s request, PHARMAC staff performed a preliminary3 CUA, based on the supplier’s original submission to PTAC for insulin glargine.4 Depending largely on the impact of fear of further hypoglycaemic episodes, PHARMAC estimated a wide range of cost/QALY values for insulin glargine treatment, ranging between $17-18,000/QALY and $3.1-3.3 million/QALY.5
Guidance from the UK National Institute of Clinical Excellence (NICE) on the use of long-acting insulin analogues6 was informed by a comprehensive systematic review and analysis by ScHARR7 (http://www.ncchta.org/fullmono/mon845.pdf). This analysis showed, similarly to PHARMAC’s CUA, a wide range of cost-utility values, again driven by the degree of anxiety/fear of further severe hypoglycaemia and this fear’s effects on quality of life.8 The ScHARR authors commented that the supplier’s submission’s claimed base case was based on the most favourable of a number of analyses. They also concluded that further research was needed that on the quality of life issues associated with the fear of hypoglycaemia, and also the economic impact of balancing HbA1c control and the incidence of hypoglycaemia achieved in practice.
PHARMAC has since estimated a $34,500 to $58,000/QALY range for long acting insulin analogues for the key group recommended by the Diabetes subcommittee – being Type 1 diabetes patients using intensive insulin regimes who had had an unexplained severe hypoglycaemic episode in the previous 12 months.9
The PHARMAC Board will use the above ranges of cost-effectiveness estimates, alongside clinical advice from PTAC and the Diabetes subcommittee and consultation feedback, when deciding whether to fund long-acting insulin analogues and if so under what access arrangements.
Conflict of interest: Scott Metcalfe is externally contracted to work with PHARMAC for public health advice. Jackie Evans and Peter Moodie declare no conflicts.
Scott Metcalfe
Public Health Physician
Wellington
Jackie Evans
Therapeutic Group Manager
PHARMAC
Wellington
Peter Moodie
Medical Director
PHARMAC|
Wellington
Footnotes and references:
  1. http://www.pharmac.govt.nz/ptac.asp The volume of applications received by PHARMAC and considered by PTAC is considerable. During 2005 PTAC will have undertaken 51 reviews of new and revised applications etc. PTAC agendas are full and submissions are extensive; agenda papers typically weigh 20 to 25 kg. PTAC recommend moderate to high priority for funding in one quarter of cases, the rest being lower priority, declines, deferrals, or referrals to subcommittees. Further details are in the Attachment to this letter.
  2. While agreeing that there are patients who will potentially benefit from fewer treatment-related hypoglycaemic events with insulin glargine (compared with insulin NPH), PBAC considered that insulin glargine’s absolute reductions in the different types of hypoglycaemic events were small, and that insulin glargine does not totally remove the risk of hypoglycaemic events. PBAC also rejected claims of cost-effectiveness, stating that the absolute differences in hypoglycaemic event rates used in the economic model submitted were higher than those observed in the clinical trials, and that the model’s utility values were poorly justified.
  3. PHARMAC undertakes four levels of economic analysis: very rapid, preliminary, indicative, and detailed. Preliminary analyses typically are rapid assessments using data derived mostly opportunistically, not systematically, typically with 1-2 weeks FTE input. Preliminary analyses are based on the broad principles used by PHARMAC for pharmacoeconomic evaluations as described by the Recommended Methods to Derive Clinical Inputs for Proposals to PHARMAC (http://www.pharmac.govt.nz/pdf/62465.pdf) and PHARMAC’s Prescription for Pharmacoeconomics (http://www.pharmac.govt.nz/pharmo_economic.asp). These principles include: the systematic identification, synthesis and presentation of relevant clinical input data; the use of overall health sector costs and direct patient costs when measuring effects on costs overall; measuring QALY gains; discounting both costs and QALY gains according to PHARMAC’s current discount rate [8% from 1 July 2005, 10% before then]; and the use of univariate and multivariate sensitivity analyses.
  4. The supplier’s submission included efficacy data from a meta-analysis of both published and unpublished data for insulin glargine in type 1 and type 2 diabetes, with 0.31 severe hypoglycaemic events per patient year. PHARMAC in turn estimated a 8%-21% risk of hospitalisation for each severe hypoglycaemic episode, hence 0.02-0.07 hospitalisations for severe hypoglycaemic episodes per patient year. PHARMAC used ScHARR’s (http://www.ncchta.org/fullmono/mon845.pdf) value for the loss of quality-of-life due to severe hypoglycaemic episodes themselves (0.15 over 4 days) and a range of values for the associated fear of further severe hypoglycaemic episodes.
  5. Under the most cost-effective scenario ($17-18,000/QALY), the fear of further hypoglycaemic episodes was assumed to be both high (loss in quality of life (i.e. disutility) of 17%) and pervasively continual. The 17% disutility derived from the Erasmus disability weight for mild/moderate generalised anxiety disorder. (Stouthard MEA, Essink-Bot M, Bonsel GJ, Barendregt PGN, et al. Disability weights for diseases in the Netherlands. Rotterdam: Department of Public Health, Erasmus University, 1997.)
Using a New Zealand-based EQ-5D disutility score for mild/moderate anxiety/depression (11112) of 0.296 would have given lower cost/QALYs. (See Devlin N, Hansen P, Kind P, Williams A. Logical inconsistencies in survey respondents’ health state valuations – a methodological challenge for estimating social tariffs. Health Economics 2003;12(7):529-544.)
Under the least cost-effective scenario ($3.1-3.3 million/QALY), the fear of further hypoglycaemic episodes was assumed to be lower-grade (0.5% disutility) and lasting three months after each episode. The 0.5% disutility derived from a patient-based survey commissioned by Aventis using the EQ-5D, used and cited by the ScHARR analysis (Warren E, Weatherley-Jones E, Chilcott J, Beverley C. Systematic review and economic evaluation of a long-acting insulin analogue, insulin glargine. Health Technol Assess. 2004 Nov;8(45):iii, 1-57.)
Assuming a high disutility from fear (but not continual disutility, rather lasting for three months) gave a cost /QALY of $210-220,000.
The cost-effectiveness estimates that assumed the fear of further hypoglycaemia to be both high and continual imply a significant loss in quality of life – with continual anxiety and moderate effects on the ability to perform usual activities (work, recreation, etc). Using such values means that the fear of hypoglycaemia is counted as being worse than the event itself (both day-to-day and as it affects year-long quality of life). It is consistent with the impact of severe hypoglycaemia on some patients and their families – where, for instance, following hospitalisations for severe hypoglycaemia and knowledge of others who have suffered perhaps crippling consequences, patients or parents consistently test frequently during the day and then at night, and diabetes control and the fear of hypoglycaemia in an individual dominate family life.
  1. National Institute for Clinical Excellence. Guidance on the use of long-acting insulin analogues for the treatment of diabetes: insulin glargine. Technical appraisal guidance 2002; No 53. http://www.nice.org.uk/pdf/53_Insulin_analogues_full_guidance.pdf
  2. Warren E, Weatherley-Jones E, Chilcott J, Beverley C. Systematic review and economic evaluation of a long-acting insulin analogue, insulin glargine. Health Technol Assess. 2004 Nov;8(45):iii, 1-57. http://www.ncchta.org/fullmono/mon845.pdf Also see http://www.nice.org.uk/pdf/Insulin_Analogues.pdf, with revisions to original model (lower prices, higher disutilities, higher hype costs) at http://www.nice.org.uk/pdf/Final_report_addendum_insulin.pdf
  3. The ScHARR analysis used by NICE examined both HbA1c improvements and reducing the risk of hypoglycaemia, giving a range of £3,500 to £72,000. However, these values understate the cost/QALYs in New Zealand, due to both currency conversion, and then the price of insulin isophane (NPH) in New Zealand being half of that of the UK, yet the insulin glargine price proposed for New Zealand being 34% higher than the UK.
  4. In general insulin detemir is expected to have similar effectiveness as insulin glargine. Note however that insulin detemir’s supplier has claimed additional clinical benefit and greater convenience to patients with insulin detemir over insulin isophane (NPH) and insulin glargine, in terms of improved glycaemic control and corresponding reduction in hypoglycaemic events, and an improved delivery system (FlexPen). Prices for the two products differ, hence PHARMAC’s cost/QALY estimates range according to the products’ prices. The $34,500-$58,000/QALY range (for Type 1 diabetes patients using intensive insulin regimes with unexplained severe hypoglycaemic episode in the previous 12 months) uses the high but not continuous fear scenario; this analysis did not attempt to account for the other claimed differences in efficacy and ease of use.
     
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