Independent Market Access and Reimbursement Risk Assessment.

Built by former payers, HTA reviewers, and Industry Experts. 

Pembrolizumab / keytruda for adjuvant treatment of completely resected stage 3 melanoma with lymph node involvement

As of February 2022, MARA’s assessment finds Pembrolizumab / Keytruda’s reimbursement risk concentrated in uncertainty, sensitivity, and broader impacts, with comparator selection 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 comparator selection carries weight because that domain asks whether the drug was tested against the treatment payers actually fund today; a benefit shown against the wrong comparator carries little weight in a reimbursement decision.

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

Pembrolizumab shows a moderate benefit over current care, with statistically significant improvements in recurrence-free survival (HR 0.59) and distant metastases-free survival (HR 0.60) compared to placebo. However, overall survival data remains immature, limiting the strength of the evidence.

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

The most conservative ICER estimate is £26,493 per QALY gained, which is within acceptable thresholds for Healthcare resources. The committee concluded that pembrolizumab is a cost-effective use of resources, especially considering its administration schedule.

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

While specific HRQoL data is not detailed, the committee noted that recurrence-free survival is a significant outcome for patients, indicating a moderate improvement in quality of life associated with the treatment.

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

Pembrolizumab is generally well tolerated, with 80% of patients experiencing no toxicity. However, there are notable risks of high toxicity (5-10%), which require careful monitoring, but overall, the safety profile is favorable compared to existing therapies.

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

The treatment was compared against placebo in a well-designed RCT (KEYNOTE-054), which is appropriate given the context of adjuvant therapy for melanoma. The committee acknowledged the relevance of the comparator.

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 53.9 years and a significant proportion of patients with BRAF mutations. However, some subgroup data is limited.

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

Pembrolizumab can be integrated into existing care pathways with minor adjustments, as it is administered every 6 weeks, which is preferable for patients compared to other treatments like nivolumab.

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

The treatment is expected to have a manageable budget impact, especially considering the potential reduction in administration costs due to less frequent dosing compared to alternatives.

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

The evidence is based on a robust RCT design (KEYNOTE-054) with a significant sample size (1,019 participants). However, the immaturity of overall survival data introduces some methodological concerns.

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

There is high uncertainty regarding overall survival estimates due to the ongoing nature of the trial and the reliance on surrogate endpoints. This uncertainty may affect decision-making and restrict use.

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
Full Legal Disclaimer and Usage Terms

The MARA Rating® is an independent opinion of a drug’s market access pharma risk profile and is provided for informational purposes only—not as investment, medical, legal or any other type of advice. See our full disclaimer here.