Defining and measuring clinical effectiveness for cell and gene therapies
Clinical efficacy
Quality of life measurements help adjust estimates about the impact of a therapy to ensure they account not only for the number of years added to a person’s life, but also the quality of those years. When assessing the cost-effectiveness of a therapy, the clinical efficacy, as demonstrated in clinical trials, will be closely evaluated to ensure the therapy is achieving its intended outcomes. For rare diseases, defining and measuring clinical efficacy is particularly challenging due to small patient populations and variability in disease progression.
In sickle cell disease, how a vaso-occlusive crisis is defined in a clinical trial and any subsequent evaluations plays a key role in understanding the impact of a therapy on health, QOL and the cost of care. This was raised in draft consultation guidance documents from the National Institute for Health and Care Excellence (NICE), regarding the ongoing appraisal of exagamglogene autotemcel for treating SCD. For example, as part of this appraisal, discussions took place regarding whether VOCs should be defined solely by hospitalisations.
Hospitalisation is measurable, which can aid in the consistency of the definition of VOCs in the health economic modelling. However, using hospitalisation to characterise VOCs may risk overlooking the impact of a therapy on reducing incidents that do not result in hospitalisation. The majority of people living with SCD are of Black African or Caribbean descent. This is a population that faces bias and discrimination, experiencing systemic health inequalities related to care quality and access, which ultimately impacts health outcomes. People with SCD may avoid hospitalisation where possible due to poor past experiences, as well as stigmas they have faced when seeking hospital treatment. If a crisis is managed at home, but VOC episodes are defined by hospitalisation, the impact of the therapy on reducing VOCs will not be accurately captured. This is just one of many ways that health inequalities need to be closely analysed and accounted for in health economic evaluations.
Discounting
The metrics that companies use to capture clinical efficacy has an important role in the evaluation of a new therapy’s impact. In the case of CGTs, another important factor is the characterisation of long-term value, as applied by health economic evaluation bodies. For example, NICE applies a concept known as discounting of health effects, to ensure that the results of a cost-effectiveness appraisal reflect the current value of the future benefits when compared to immediate costs. Simply put, discounting of health effects means that in the health economic model, benefits delivered in the future are worth less than those delivered sooner. This can make it difficult to demonstrate cost-effectiveness for therapies like CGTs, which have long-term potential value, but high initial costs. Therefore, a lower discounting rate can be applied in special cases when it is determined that the therapy meets certain criteria, including that the therapy is made for “people who would otherwise die or have a severely impaired life,” is “likely to restore them to full or near-full health” and that the “benefits are likely to be sustained over a very long period.”
This begs the question: what qualifies as “severely impaired?” What does “full or near-full health” really mean? An appraisal committee will need to determine that a therapy is likely to restore a patient with a severely impaired life, to full health. However, this can be difficult to define. It could include both biological markers (such as organ function) and QOL measures, but these criteria are open to interpretation. This should be considered when demonstrating clinical effectiveness, such that meaningful increases in QOL are shown as well as clear evidence of sustained, irreversible effects in the target population.