Independent Market Access and Reimbursement Risk Assessment.

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Cemiplimab for treating advanced cutaneous squamous cell carcinoma

As of June 2022, MARA’s assessment finds Cemiplimab’s reimbursement risk concentrated in uncertainty, sensitivity, and broader impacts, with care pathway integration a strength; the current MARA Rating and full rationale are available in the report.

The assessment also weighs clinical effectiveness: how much additional benefit the drug demonstrated over the care patients already receive — the first question every payer asks. The strength recorded in care pathway integration carries weight because that domain asks how the drug fits into the way care is organised today; a treatment that demands new infrastructure or displaces an established pathway faces extra scrutiny.

Oncology

This rating sits within MARA’s Oncology coverage, alongside 153 other independently assessed treatments in the same area.

What payers will ask

Is the clinical benefit the kind payers reward? — Clinical effectiveness

Cemiplimab has shown promising results in clinical trials, with an objective response rate of 46.1% and median overall survival not reached after 15.7 months. However, it has not been directly compared with best supportive care, and the evidence from indirect comparisons is considered highly uncertain. Therefore, while it meets non-inferiority, there is no clear edge over existing options.

Does the economic case hold at the expected price? — Cost effectiveness

The ICER for cemiplimab compared to best supportive care is estimated at £30,952 per QALY gained, which is within NICE’s acceptable range. Despite uncertainties in clinical effectiveness, the committee concluded that the cost-effectiveness estimates are likely acceptable.

Is there quality-of-life evidence payers weigh? — Quality of life

The committee noted that cemiplimab is well tolerated and can lead to substantial benefits for those who respond, including improved quality of life due to reduced tumor burden. However, specific HRQoL data from validated instruments is not detailed in the document.

Does the safety profile hold up for payers? — Safety and Adverse Effects

Cemiplimab has a very good safety profile, with most adverse events being mild to moderate, such as fatigue and rashes. Serious autoimmune side effects are manageable, indicating a favorable tolerability compared to existing therapies.

Was the drug compared against what payers expect? — Comparator Selection

The primary comparator is best supportive care, which is appropriate given the patient population. However, the lack of direct comparisons with other treatments limits the robustness of the evidence.

Is the population defined the way payers need it? — Patient Population and Subgroups

The trial population is moderately representative of the intended patient population, with a median age of 72 years. However, there are concerns about the generalizability of trial results to the older population treated in the Healthcare.

Does the drug fit how care is delivered and paid for? — Care Pathway Integration

Cemiplimab can be integrated into existing care pathways with minor adjustments, as it is a monotherapy that does not require significant changes in infrastructure or training.

Are the wider system costs understood? — Resource Use and Cost Implications

The budget impact is manageable, with the potential for cost savings due to the commercial arrangement. The treatment is expected to be resource-efficient given its cost-effectiveness.

Would the evidence survive payer scrutiny? — Evidence Quality and Robustness

While there are promising results from clinical trials, the evidence base has gaps, particularly due to the lack of direct comparisons and reliance on indirect comparisons, which introduces uncertainty.

How exposed is the case to uncertainty? — Uncertainty, Sensitivity, and Broader Impacts

There is significant uncertainty regarding the clinical effectiveness and survival estimates, particularly due to the differences between trial populations and real-world data. This uncertainty may impact decision-making.

Be alerted when this rating changes:

Sample two-page MARA Rating report for the fictional drug Samplinib: the rating with its decision record, and the ten graded payer questions with the reasoning behind each
Every MARA rating is delivered as a two-page reasoned report (sample, fictional product) — see it in full
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