Reimbursement Risk Assessment

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

Oncology

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Related Reimbursement Risk Assessments

Primary Risk Drivers

Below is a snapshot of domains that materially influence the MARA Rating. 

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.

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.

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.

Supporting Domains

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.

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.

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.

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.

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.

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.

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.
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