Competition From Biosimilars Drives Price Reductions For Biologics In The French Single-Payer Health System
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Global Health Policy By James C. Robinson and Quentin Jarrion doi: 10.1377/hlthaff.2021.00070 Competition From Biosimilars HEALTH AFFAIRS 40, NO. 8 (2021): 1190–1197 ©2021 Project HOPE— The People-to-People Health Foundation, Inc. Drives Price Reductions For Biologics In The French Single-Payer Health System James C. Robinson (james .robinson@berkeley.edu) is the ABSTRACT France has a single-payer health insurance system that has the Leonard D. Schaeffer Professor of Health authority to impose pharmaceutical price reductions but relies on Economics in the Division of decentralized market negotiations between hospitals and manufacturers Health Policy and Management, School of Public to establish prices for injected and infused biologics. Hospitals rely on Health, at the University of biosimilars—less expensive but therapeutically equivalent variants of California Berkeley, in Berkeley, California. He is a biologic medications—to stimulate competition. Price reductions Health Affairs contributing negotiated by hospitals subsequently are adopted by the health insurance editor. system, driving hospitals to negotiate a new round of discounts. This Quentin Jarrion is a research article measures 2004–20 trends in prices, price reductions, utilization, physician, Health Information Management Department, and market shares for three prominent biologics—Remicade, Enbrel, and University Hospitals of Reims, Humira—and their eleven competing biosimilars. Biosimilar launches are in Reims, France. At the time this research was initiated, he associated with a sequence of price reductions for the reference biologic, was a visiting scholar at the University of California for other biologics that treat similar conditions, and for all related Berkeley. biosimilars. The French experience provides lessons for the US in its efforts to use competition from biosimilars to drive price reductions and savings from biologics. T he US is currently engaged in a tive biologics and their less expensive but thera- debate over alternative strategies peutically equivalent biosimilars.4 Biologics are for achieving moderation in drug large, complex molecules that must be injected spending, including legislative pro- or infused into the body, instead of being taken posals to set regulatory limits on orally. They are growing in use and rising in price the prices negotiated at the time of initial market and now account for almost half of pharmaceu- launch and to ban postlaunch price increases. tical industry sales.5 Biosimilars charge low Some policy analysts have highlighted the single- prices to gain market share from reference bio- payer health system in France as a possible mod- logics, which otherwise enjoy monopoly pricing el, given its authority to regulate launch prices power, and are able to sustain lower prices as and mandate subsequent price reductions.1–3 A they have lower costs of research and devel- close look at the process of drug price determi- opment. nation in France, however, indicates that the The mix of market and regulatory mechanisms actual process differs substantially from what adopted in France, and the manner in which they might be inferred from the formal structure. In- are coordinated, have important implications stead of determining prices in a centralized man- for US pharmaceutical pricing policy. The US ner with an administrative formula, France relies lacks consistent incentives for physicians to pre- in important ways on market competition and scribe low-price biosimilars and for manufac- decentralized negotiations. turers to compete using price reductions. Mis- The synergies between market and regulatory aligned incentives impede what advocates have mechanisms are particularly evident for innova- hoped would be a virtuous cycle of biosimilar 1190 H e a lt h A f fai r s A u g us t 2 0 21 40:8 Downloaded from HealthAffairs.org on August 02, 2021. Copyright Project HOPE—The People-to-People Health Foundation, Inc. For personal use only. All rights reserved. Reuse permissions at HealthAffairs.org.
product launches, accelerated adoption, intensi- hospitals using supplemental payments, analo- fied competition, better patient access, greater gous to the new technology add-on payments savings for purchasers, and the freeing up of used by Medicare.10 Drugs eligible for payments funds to pay for the next round of truly innova- beyond the French case rates are included in the tive drugs. The stunted adoption of biosimilars supplemental list. For these drugs, the French in the US also impedes the global development of social security system reimburses the hospital the market because manufacturers only engage for the amount negotiated by the hospital with in research and development if they are con- the manufacturer, plus one-half of the difference vinced that there is significant revenue potential. between this negotiated price and the national In this article we examine data from the French tariff negotiated with the manufacturer by the national authority in charge of setting prices for CEPS. This gainsharing framework creates an medical products and pharmaceuticals to derive incentive for the hospital to negotiate the lowest lessons for the US as it pursues the use of com- possible price with the manufacturer.11 petition to seek price reductions and savings France has a hospital-centered delivery system from the use of biologics and biosimilars. for ambulatory as well as inpatient care. Infused biologics such as Remicade must be adminis- tered in hospital outpatient departments; com- Decentralized Negotiations: The munity-based specialists are not permitted to Role Of Hospitals maintain infusion clinics in their private prac- The French system of social security, which cov- tices. Injected biologics such as Enbrel and ers health services as well as pensions, is funded Humira may be administered in community set- by national taxes plus contributions made by tings, but the initial prescription and injection employers.6 It is a single-payer system for medi- must be performed in a hospital clinic by a hos- cal products such as drugs, with modest contri- pital-based specialist.12 The mandate that the butions from patient copayments and comple- first injection be performed in a hospital derives mentary private insurance. The determination from evidence that community-based specialists of drug prices is delegated to the Comité Econ- rarely switch the prescriptions made by their omique des Produits de Santé (CEPS) (Economic hospital-based counterparts and that switching Committee for Health Products) in consultation from biologics to biosimilars performed in hos- with other governmental entities such as the pital settings will carry over into community French National Health Authority. settings.13 The CEPS negotiates with manufacturers a The value of the gainsharing incentive de- national tariff for each new drug and biologic pends on the level of the national tariff. The CEPS that is based on the prices of comparable prod- monitors hospital negotiations and reduces the ucts, the new product’s clinical improvement national tariff when it observes manufacturers over existing treatments, cost-effectiveness stud- offering meaningful discounts to individual hos- ies that compare the new product’s clinical ben- pitals or to hospital purchasing groups. These efit with its price, the prices charged in other reductions in the national tariff shift the eco- European nations, and the volume of prescrip- nomic savings generated by hospitals’ negotia- tions expected to be written (as an indicator of tions from the hospitals themselves to the social potential budget impact).7–9 security system. This reliance on hospital nego- These centralized administrative mechanisms tiations also provides political cover for cuts in are supplemented by decentralized negotiations the national tariff. Pharmaceutical firms cannot between the manufacturer and each French hos- claim that the new lower price is insufficient, as it pital or hospital purchasing group. These nego- has already agreed to it with the hospitals. tiations determine the price that will be paid The reliance on decentralized price negotia- for the drugs to be used in hospital ambulatory tions by hospitals, as a supplement to centralized clinics as well as inpatient settings and are the negotiations by the national insurer, requires amounts actually paid to the manufacturers. The explanation. It would seem to be counterproduc- national tariffs negotiated with the manufac- tive to replace the scale and sophistication of the turers by the CEPS are used as the basis of the national insurer with the smaller scale and lesser payments made by the social security system to sophistication of hospitals and would also add the hospitals, not the manufacturers. another level of complexity to the process of The French social security system pays diagno- price determination.14,15 The French system relies sis-specific case rates to cover the normal com- on these decentralized negotiations because the ponents of an inpatient admission in a manner CEPS is unable to ascertain a drug’s reservation analogous to Medicare Severity Diagnosis Relat- price, defined as the level below which the man- ed Group rates. Expensive drugs and devices are ufacturer will reduce its supply chain and service carved out of the case rates and reimbursed to guarantees (for example, inventory security or August 2021 40:8 Health Affairs 1191 Downloaded from HealthAffairs.org on August 02, 2021. Copyright Project HOPE—The People-to-People Health Foundation, Inc. For personal use only. All rights reserved. Reuse permissions at HealthAffairs.org.
Global Health Policy prompt delivery) or, at the extreme, withdraw its product from the French market. In contrast to the The reductions in the national tariff reduce the gainsharing revenue accruing to the hospitals, experience in Europe, as this is based on the difference between the national tariff negotiated by the CEPS and the payers in the US have prices negotiated by the hospital with the man- ufacturer. The tariff reductions therefore create been slow to develop incentives for hospitals to enter a new round gainsharing incentives of negotiations with manufacturers, with the goal of obtaining further price reductions that to drive biosimilar restore the gainsharing revenues. Subsequent local price reductions negotiated by hospitals adoption. lead to subsequent national tariff reductions. Hospitals are required to report to the CEPS the price discounts obtained from manufac- turers. In this manner, tariffs paid by the social security system trend downward without the risk that manufacturers will exit the market. apeutically similar biologics, which are required to reduce their national tariffs even when a bio- similar is launched for a different reference prod- Market Competition: The Role Of uct.17 Reductions in the national tariff reduce the Biosimilars savings available to the hospitals under the for- The statutory authority over national prices in mer tariffs and induce the hospitals to pursue France is particularly evident with respect to another round of price reduction with the man- price reductions in the years after initial market ufacturers. Reductions in the prices negotiated launch. The CEPS wields the statutory authority with hospitals in turn lead to subsequent reduc- to impose tariff reductions in response to the tions in the national tariff. market entry of a therapeutically similar prod- uct, a new indication being approved for the original drug, the price being reduced in another Study Data And Methods European nation, or evidence emerging that the Data Sources We analyzed the national tariff product is less effective than previously believed. prices for three anti–tumor necrosis factor im- In principle, therefore, the CEPS does not need munology biologics, Remicade, Enbrel, and to rely on market competition but could rely on Humira, from the beginning of 2004 through unilateral price regulation to reduce its spending January 2020, as well as the prices for the eleven on drugs. related biosimilars that entered the French mar- Despite this statutory authority, the French ket beginning in 2015. These pricing data were system has relied on the market entry of bio- obtained from the Base des Médicaments et In- similars to precipitate the most important tariff formations Tarifaires (Drug and Tariff Informa- reductions for biologics.16 The launch of new tion Base), which is updated every week.20 The biosimilars influences the tariffs of the reference prices reflect the amounts paid by the national biologics in different ways depending on wheth- insurer to the hospitals, rather than the amount er the drugs are administered by a hospital-based paid by the hospitals to the drug manufacturer. or a community-based physician.17–19 The differ- Each hospital pays the manufacturer the price it ence derives from the assumption that hospitals has negotiated, irrespective of the tariff negoti- have the ability to negotiate prices with drug ated by the CEPS with the manufacturer. manufacturers, and thereby derive information We obtained the sales volumes of each of the on reservation prices, but community-based three biologics and eleven biosimilars when used physicians do not. in the hospital outpatient setting. These data The CEPS audits the prices negotiated by hos- include the total national volumes for Remicade pitals with the manufacturers of biosimilars and and its biosimilars, as those infused products are periodically mandates reductions in the national administered only in hospital clinics in France. tariff when it observes the hospitals obtaining However, Enbrel, Humira, and their biosimilars meaningful savings. It requires that the national are administered in community as well as hospi- tariffs for a biologic and its biosimilars be the tal ambulatory settings. As noted above, the first same, in the interest of stimulating hospital ne- prescription and injection of these drugs must be gotiations with manufacturers for both types of performed in the hospital setting. Subsequent products. This uniformity extends to other ther- injections can be performed in a hospital or in 1192 H e a lt h A f fai r s A u g us t 2 0 21 40:8 Downloaded from HealthAffairs.org on August 02, 2021. Copyright Project HOPE—The People-to-People Health Foundation, Inc. For personal use only. All rights reserved. Reuse permissions at HealthAffairs.org.
local prices negotiated by hospitals. We thus Even a centralized could not measure the size of the gainsharing revenues obtained by each hospital from the single-payer system shifts to biosimilars. However, our data do illu- has limited power to minate the main theme of the study, which is the effect of biosimilar competition, working impose price through local hospital negotiations, on the tar- iffs paid at the national level. Each round of reductions on drug hospital price reductions sets the stage for an- other cut in the national tariff, and each cut in manufacturers. the national tariff sets the stage for another round of hospital negotiations. Our utilization data represent the hospital am- bulatory sector and do not include drugs admin- istered in the physician’s office or the patient’s home. The majority of injections for Enbrel and the community, depending on whether the pa- Humira and their biosimilars are performed in tient remains under the care of a hospital-based these community settings. In contrast, all infu- or a community-based specialist. Our data cover sions for Remicade and its biosimilars are per- only the volume administered in hospital ambu- formed in the hospital ambulatory setting. The latory clinics. shift toward the biosimilars of Enbrel and We calculated trends in hospital ambulatory Humira and away from the reference biologics market shares for each reference biologic, its is likely to be sustained in community settings competing biosimilars, and the combination of because of the reluctance of community-based the three therapeutically similar biologics and physicians to contravene the clinical choices of their eleven biosimilars. The data allow insight hospital-based specialists. Indeed, the French into the relative success of early and late bio- social security system explicitly uses hospital similar market entrants for these treatments. gainsharing as a tool to influence biosimilar We calculated changes in the national tariffs use in nonhospital settings.12 for the three biologics that occurred after the launch of each biosimilar as well as the impact on the tariff for one biologic associated with Study Results the market entry of a biosimilar for a different Trends In Sales And Market Shares Exhibit 1 biologic. presents the shares of the French hospital am- Insights into the functioning of the French bulatory drug market held by the three biologics system for drug price determination were ob- and their biosimilars between 2015, the year of tained from review of the CEPS annual reports, the first biosimilar launch, and January 2020. By documents from the governmental auditor, pub- 2019 the biosimilars as a group held an approxi- lished articles, and white papers from consul- mately 75 percent share of the hospital ambula- tants and other informed observers.We also con- tory market, defined in terms of volume of vials ducted interviews with individuals employed by administered, which is close to the national goal the social security system, the CEPS, hospitals, of 80 percent biosimilar market penetration.19 consulting firms, pharmaceutical associations, The French market exhibits robust competi- and academia. These qualitative interviews were tion among biosimilars as well as between bio- used to develop and refine our perspective that similars and their reference biologics. Exhibit 2 the French system uses decentralized market shows trends in market shares for Remicade negotiations to inform its centralized regulatory and each of its biosimilars beginning in 2015— pricing process. the year the first biosimilar was launched. The We limited our analysis of biosimilar policy to first biosimilar to be launched, Inflectra, gained the French approach to be able to discuss the and retained the highest market share and had actual processes used in depth, and thereby offer achieved 41 percent of the national market by more detailed lessons for the US. Excellent sur- January 2020. Each of the two subsequent bio- veys of approaches adopted by the spectrum of similar entrants gained approximately 18 per- European nations, which of necessity had to sac- cent of the market, whereas the fourth biosimilar rifice depth for breadth, have been published had failed to gain any traction (0 percent market elsewhere.21–25 share) as of January 2020. The reference biologic Limitations The data used in this study reflect Remicade itself suffered a dramatic fall in use the national tariff prices negotiated by the CEPS, and retained only one-quarter of the market using its scale as a single payer, rather than the by 2020. A u g u s t 202 1 40: 8 H e a lt h A f fai r s 1193 Downloaded from HealthAffairs.org on August 02, 2021. Copyright Project HOPE—The People-to-People Health Foundation, Inc. For personal use only. All rights reserved. Reuse permissions at HealthAffairs.org.
Global Health Policy Exhibit 1 Remicade, despite the fact that they are injected products used in both hospital and nonhospital Market shares for three reference biologics and their biosimilars used in hospital ambulatory clinics in France, 2015–20 settings, whereas the infused product Remicade is used exclusively in hospital clinics. The appen- dix exhibits represent use in hospital ambulatory clinics only, as comparable data on injections in private physician practices are not available.26 These changes in market shares occurred against a backdrop of overall growth in hospital ambulatory utilization but a reduction in spend- ing due to the shift from higher-price biologics to lower-price biosimilars. As indicated in appen- dix exhibit 3, sales revenues for Remicade de- creased from 276.4 million euros in 2015 to 33.8 million euros in 2019 under competitive pressure from the five biosimilars.26 In contrast, the combined sales of the Remicade biosimilars increased from 6.7 million euros in 2015 to 59.5 million euros in 2019. Hospital ambulatory sales for Enbrel declined from 251.4 million euros in 2015 to 49.8 million euros in 2019, whereas those for Humira declined from 4.0 mil- lion euros to 730,580 euros between 2015 and 2019. Sales of their biosimilars rose from zero SOURCE Base Nationale ATIH du Programme de Médicalisation des Systèmes d’Informations et des Médicaments (proprietary data). NOTE Combined market shares for three anti–tumor necrosis factor in 2015 to 36.8 million euros and 50.7 million biologics, Remicade, Enbrel, and Humira, and their biosimilars are shown. euros, respectively, in 2019. These figures under- state volumes administered for these latter two products, as the majority of injections are deliv- Online appendix exhibits 1 and 2 show trends ered in community-based physician offices rath- in hospital market shares for Enbrel and Humira er than in hospital ambulatory clinics. and their biosimilars.26 The growth in their bio- Trends In Prices After Biosimilar Market similar market shares was similar to that for Entry Exhibit 3 presents the national tariffs for the three biologics and their biosimilars negoti- ated by the CEPS with drug manufacturers from Exhibit 2 2004 to 2019, in the years before and after the Trends in hospital ambulatory clinic market shares for Remicade and its biosimilars in introduction of competition from biosimilars. France, 2015–20 The first two biosimilars for Remicade were launched in France in December 2014, with a third launched in October 2016 and a fourth in February 2019. The two biosimilars for Enbrel were launched in May 2016. Four biosimilars for Humira were launched in quick succession in fall 2018, with a fifth launched in August 2019. The CEPS did not wait for competition from biosimilars to achieve savings on the three refer- ence biologics. It imposed price reductions in 2010–11 and again in 2013–14 before the launch of the first biosimilar. These reductions high- light the power of centralized single-payer pur- chasing and contrast with the US pattern of postlaunch price increases. However, the CEPS imposed much larger tariff reductions in the years after biosimilar market entry, during the period in which the hospitals were negotiating their individual price reductions with the man- ufacturers. The launches of the eleven biosimi- lars were accompanied by major tariff reductions SOURCE Base Nationale ATIH du Programme de Médicalisation des Systèmes d’Informations et des in fall 2016, in spring 2018, and during 2019. The Médicaments (proprietary data). entry of a biosimilar for one biologic was associ- 1194 Health Affai rs A u g u st 2 0 2 1 40:8 Downloaded from HealthAffairs.org on August 02, 2021. Copyright Project HOPE—The People-to-People Health Foundation, Inc. For personal use only. All rights reserved. Reuse permissions at HealthAffairs.org.
Exhibit 3 Association between market entry of biosimilars and trends in prices for three reference biologics and their biosimilars used in hospital ambulatory clinics in France, 2004–20 SOURCE Base des Médicaments et Informations Tarifaires (proprietary data). NOTE Market entry for three anti–tumor necrosis factor biologics, Remicade, Enbrel, and Humira, and their biosimilars is shown. ated with cuts in the national tariff for all three drive biosimilar adoption. As of July 2020 bio- reference biologics. The differences between the similars had gained only a small market share tariff reductions imposed before and after bio- in the US against Remicade and had yet to be similar market entry reflect the use of the infor- launched against Enbrel and Humira.24 Market- mation from the decentralized hospital negotia- share gains have been more impressive for bio- tions to identify manufacturers’ readiness to similars targeting oncology biologics that typi- offer price reductions. cally are administered for short courses of treat- ment, but the overall reduction in US drug spending attributable to biosimilars is only a Discussion fraction of the initial projections. The advent of biosimilars initially stimulated op- Some frustrated policy analysts have ques- timism on the part of pharmaceutical purchas- tioned relying on biosimilars to rein in spending ers, in both Europe and the US, that the resulting on biologics. Mark Trusheim and colleagues and competition would lead to lower prices and re- Nancy Yu and colleagues, for example, have de- duced spending. This hope has been borne out in clared the biosimilar strategy to be a failure and some European nations, but the US has not en- recommend direct price regulation of biologics joyed comparable benefits. The development of once they lose patent exclusivity.27,28 Those au- the US Food and Drug Administration pathway thors suggest that the government should man- for biosimilars was delayed for years after the date a large reduction in the price of biologics European Medicines Agency had established immediately after the lapse of the original pat- its version. The manufacturers of some reference ents. They do not offer a standard that takes into biologics have erected a thicket of secondary account the reservation price of the manufac- patents that impede the launch of biosimilars turers. In contrast, the French approach, as de- in the US. In contrast to the experience in scribed in this study, does seek to identify reser- Europe, public and private payers in the US have vation prices, which are likely to vary instead of been slow to develop gainsharing incentives to being uniform across products and over time. A u g u s t 202 1 40: 8 H e a lt h A f fai r s 1195 Downloaded from HealthAffairs.org on August 02, 2021. Copyright Project HOPE—The People-to-People Health Foundation, Inc. For personal use only. All rights reserved. Reuse permissions at HealthAffairs.org.
Global Health Policy There are several lessons to be gained from formation it generates on industry reservation the French experience with biosimilars. Most ob- prices. viously, even a centralized single-payer system has limited power to impose price reductions on drug manufacturers. Payers lack information on Conclusion how low prices can be pushed before the manu- Health policy debates in the US often portray facturer withdraws its product from the market. a choice between decentralized market mecha- Insight into these reservation prices is of impor- nisms and centralized regulatory mechanisms. tance not only to ensure supply in the short-term This study suggests, however, that market and but also to sustain a competitive market for the regulatory strategies can be complements rather long term. Decentralized negotiations with man- than substitutes. ufacturers by provider organizations constitute Even the highly centralized single-payer multiple probes of these reservation prices. In French system relies on decentralized hospital France the CEPS maintains an interest in ensur- negotiations and competition from biosimilars ing a competitive biosimilars market and en- to help determine prices for brand-name biolog- courages hospitals to contract for multiple bio- ics. The price reductions obtained through de- similar products instead of filling all of their centralized negotiations and biosimilar compe- needs from the manufacturer offering the lowest tition then are translated into savings for the price. social security system through the regulatory The French approach to drug price determina- authority wielded by the national payer. Reduc- tion generates a process in which the publicly tions in the national tariff in turn reduce the visible tariffs negotiated by the CEPS and paid shared savings available to hospitals, spurring to the hospitals constitute a lagging indicator of them to negotiate another round of discounts the confidential prices negotiated by the hospi- with manufacturers. tals and paid to the manufacturers. These hospi- When hospitals cannot negotiate further dis- tal-negotiated prices in turn constitute a lagging counts, the national payer ceases to impose re- indicator of the reservation prices below which ductions in the national tariff. The national manufacturers would reduce their sales efforts payer then has found the manufacturer’s reser- and ultimately withdraw their products from the vation price for the biologic in question and must French market altogether. seek further savings elsewhere in the health care The French system allows and encourages hos- system. pitals to negotiate prices with drug manufac- In its attempt to use biosimilars to obtain sav- turers even though the CEPS has the legal au- ings for the health care system, the US has pur- thority to impose price reductions unilaterally. sued only one of the two levers used by France. It It thereby forgoes both the scale of the national has encouraged market entry from biosimilars, payer and the sophistication of its extensive ad- albeit in the face of determined opposition from ministrative staff to gain insights into reserva- manufacturers. But it has not encouraged physi- tion prices. It implicitly pays for this information cian switching through gainsharing incentives, by allowing the hospitals to retain half of the nor has it used biosimilar prices as benchmarks savings they negotiate (in terms of the difference for the reservation prices of biologics. There are between the national tariff and the hospital’s limits below which drug prices cannot be pushed negotiated rate) instead of mandating that all without prompting market exits, but the US will savings immediately be returned to the national never approach these reservation prices if it system. The system is apparently willing to forgo never seeks to find them. ▪ these short-term savings in exchange for the in- This study was supported by a contract from Arnold Ventures, a nonprofit foundation, to study biosimilars policy in Europe. NOTES 1 Rodwin MA. 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