Independent Market Access and Reimbursement Risk Assessment.

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Pembrolizumab / keytruda for previously treated endometrial, biliary, colorectal, gastric or small intestine cancer with high microsatellite instability or mismatch repair deficiency

As of September 2023, MARA’s assessment finds Pembrolizumab / Keytruda’s reimbursement risk concentrated in quality of life, 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

The evidence for pembrolizumab indicates comparable efficacy to existing chemotherapy options, meeting non-inferiority but lacking direct head-to-head trials. The indirect comparisons suggest that pembrolizumab may lead to longer survival and delayed progression compared to chemotherapy, but these results are uncertain due to the absence of direct evidence.

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

The cost-effectiveness estimates for pembrolizumab are within NICE’s acceptable range, with ICERs below £30,000 per QALY gained. The economic model considers the severity of the condition and the unmet need for effective treatments, supporting its cost-effectiveness.

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

While there are indications of improved quality of life for patients receiving pembrolizumab, the evidence is not robust, and specific HRQoL data from validated instruments are limited. The document does not provide strong evidence of significant improvements in HRQoL compared to standard care.

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

Pembrolizumab has an acceptable safety profile, with adverse effects primarily being manageable. The document indicates that serious adverse events are rare, and the overall tolerability is good compared to chemotherapy.

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

The document acknowledges that pembrolizumab has not been directly compared with chemotherapy in clinical trials. Instead, it relies on indirect comparisons, which raises concerns about the robustness of the evidence regarding its positioning against standard care.

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

The trials included a diverse patient population across multiple cancer types, and subgroup analyses were conducted. The committee concluded that the trial population is sufficiently representative of the intended real-world patients.

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

Pembrolizumab can be integrated into existing treatment pathways with manageable adjustments, such as the need for routine biomarker testing. The committee noted that the integration would require some planning but is feasible.

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

The budget impact of pembrolizumab is considered manageable, with potential net savings due to its effectiveness and the commercial arrangement providing a discount. The overall resource implications are aligned with planning expectations.

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

The evidence base is primarily derived from phase 2 trials, which introduces limitations in robustness. While the trials provide some insights, the lack of phase 3 data and direct comparisons raises concerns about the overall quality of the evidence.

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

There is considerable uncertainty regarding the treatment effects due to the reliance on indirect comparisons and the small population sizes. However, the context of unmet need and the rarity of the condition provide some mitigating factors.

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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