Independent Market Access and Reimbursement Risk Assessment.

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Pembrolizumab / keytruda for neoadjuvant and adjuvant treatment of triplenegative early or locally advanced breast cancer

As of December 2022, MARA’s assessment finds Pembrolizumab / Keytruda’s reimbursement risk concentrated in clinical effectiveness and care pathway integration, with cost effectiveness a strength; the current MARA Rating and full rationale are available in the report.

The assessment also weighs evidence quality and robustness: how solid the underlying evidence is on its own terms — trial design, size and endpoints — before any question of price is reached. The strength recorded in cost effectiveness carries weight because that domain asks whether the price asked stands in a defensible relationship to the benefit delivered — the core of most European reimbursement decisions.

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 moderate clinical benefit over standard chemotherapy, with a statistically significant improvement in pathological complete response (63.0% vs. 55.6%) and event-free survival (83.5% vs. 74.9%). However, the overall survival benefit is not statistically significant, indicating that while there are improvements in key outcomes, the margin of benefit is modest.

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

The cost-effectiveness estimates for pembrolizumab are likely within acceptable thresholds for Healthcare resources, with the committee concluding that it is likely to be cost-effective based on the economic model presented, despite some uncertainties.

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

The treatment is associated with improved quality of life due to less invasive surgical options resulting from higher rates of pathological complete response. The psychological benefits of achieving a complete response are emphasized, suggesting moderate improvements in HRQoL.

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

While there are additional adverse events associated with pembrolizumab, the clinical experts and patient feedback indicate that these are manageable and that the potential benefits outweigh the risks. The overall safety profile is considered very good.

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

The comparator used in the KEYNOTE-522 trial (chemotherapy plus placebo) is appropriate and reflects standard care practices, although there are some concerns about the specific chemotherapy agents used. Overall, the trial design supports the relevance of the comparator.

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

The trial population is broadly representative of the intended patient population in the Healthcare, with a diverse demographic and relevant subgroup analyses. The generalizability of the results to UK clinical practice is supported by the trial’s design.

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

Pembrolizumab can be integrated into existing treatment pathways with minor adjustments, as it is intended to be used alongside standard chemotherapy. The committee noted that practice would change to include this treatment, indicating a good fit.

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

The budget impact is manageable, and there are potential cost savings associated with reduced invasive surgeries due to higher rates of pathological complete response. The overall resource use is considered justifiable given the benefits.

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

The evidence is based on a robust Phase III trial (KEYNOTE-522) with a large sample size (n=1,174) and a well-structured design. While there are some limitations, the overall quality of evidence is strong.

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

There is some uncertainty regarding long-term outcomes and the generalizability of subgroup results, but the context of unmet need and the potential benefits of treatment provide a favorable backdrop for 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
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