The effectiveness and value of nadofaragene firadenovec, oportuzumab monatox, and pembrolizumab for BCG-unresponsive non-muscle-invasive bladder ...
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P E R S P E C T I V E S O N V A L U E 797 The effectiveness and value of nadofaragene firadenovec, oportuzumab monatox, and pembrolizumab for BCG-unresponsive non-muscle-invasive bladder cancer A summary from the Institute for Clinical and Economic Review’s Midwest Comparative Effectiveness Public Advisory Council Molly Beinfeld, MPH; Steven J Atlas, MD, MPH; Daniel Touchette, PharmD, MA; Avery McKenna; David Rind, MD; and Steven D Pearson, MD, MSc Bladder cancer is the sixth most Calmette-Guerin (BCG), an attenuated common cancer in the United States. live form of Mycobacterium bovis.5 For Author affiliations Approximately 80,000 new cases patients with invasive disease or who Molly Beinfeld, MPH; Avery McKenna; are diagnosed each year, and more are not responding to or tolerating David Rind, MD; and Steven D Pearson, than 17,000 people die from the dis- intravesical therapy, cystectomy may MD, MSc, Institute for Clinical and ease annually.1,2 At diagnosis, most be performed to remove the bladder.6,7 Economic Review, Boston, MA. Steven patients have non-muscle-invasive Although short-term prognosis J Atlas, MD, MPH, Division of General bladder cancer (NMIBC), meaning for NMIBC is good, patients with Internal Medicine, Massachusetts General Hospital and Harvard Medical School, that the cancer involves the inner lin- BCG-unresponsive disease can Boston, MA. Daniel Touchette, PharmD, ing of the bladder but has not invaded select cystectomy or further intra- MA, University of Illinois at Chicago into the deeper muscle layer. NMIBC vesical chemotherapy with agents College of Pharmacy, Chicago, IL. includes 3 subgroups that are asso- such as gemcitabine monotherapy ciated with increasing risk of cancer or combination gemcitabine plus AUTHOR CORRESPONDENCE: progression: (1) 70% of patients have docetaxel. Response rates to these Molly Beinfeld, mbeinfeld@icer.org Ta disease, with polyps extend- agents are relatively low, underscor- ing into the lining of the bladder; ing the need for new bladder-sparing (2) 20% of patients have T1 disease, treatment options. 8,9 J Manag Care Spec Pharm. with tumors below the superficial In January 2020, pembrolizumab 2021;27(6):797-804 lining but not involving the muscular (Keytruda), a systemically admin- Copyright © 2021, Academy of Managed layer of the bladder wall; and (3) 10% istered immunotherapy agent, Care Pharmacy. All rights reserved. of patients have carcinoma in situ received an additional indication for (CIS) with flat, superficial growths. 3 BCG-unresponsive CIS disease.10 In Treatment and related health care addition, 2 new intravesical thera- costs for patients with bladder can- pies have recently begun the US cancer cells.11,12 It is instilled every cer is estimated to be $4-$5 billion Food and Drug Administration (FDA) 3 months. Oportuzumab monatox is a annually in the United States.4 approval process: nadofaragene firad- recombinant fusion protein with a cell Treatment of NMIBC involves enovec (Adstiladrin) and oportuzumab adhesion molecule antibody linked to removal of visible cancer followed monatox (Vicineum). Nadofaragene a toxin that binds to the cancer cell by intravesical therapy for those firadenovec uses a recombinant at increased risk of progression to adenovirus vector that encodes the that releases the toxin into the cell, invasive disease. The most common human interferon alfa-2b gene with inducing cell death.13 It is instilled initial intravesical therapy is Bacillus a surfactant to enhance transfer into twice a week for 6 weeks, then weekly Vol. 27, No. 6 | June 2021 | JMCP.org
The effectiveness and value of nadofaragene firadenovec, oportuzumab monatox, 798 and pembrolizumab for BCG-unresponsive non-muscle-invasive bladder cancer FIGURE 1 Phase 3 Results of Nadofaragene Firadenovec: Complete for 6 weeks and then every 2 weeks for Response and High-Grade Recurrence Free Survival, up to 2 years. CIS ± Ta/T1, and Ta/T114 The Institute for Clinical and Economic Review (ICER) conducted 90 a systematic literature review and 80 cost-effectiveness analysis to evaluate CIS ± Ta/T1 the health and economic outcomes Proportion with CR or HGRFS 70 Ta/T1 of nadofaragene firadenovec, oportu- 60 zumab monatox, and pembrolizumab 50 for BCG-unresponsive NMIBC. Complete details of ICER’s system- 40 72.9 atic literature search and protocol, as 30 62.5 58.3 well as the methodology and model 53.4 20 40.8 43.8 structure for the economic evalua- 35 24.3 tion are available on ICER’s website 10 at https://icer.org/assessment/ 0 bladder-cancer-2020/. 3 months 6 months 9 months 12 months In this report, we present the sum- Time mary of our findings and highlights of Note: Error bars represent standard error of proportion with CR or HGRFS. the policy discussion with key stake- CIS = carcinoma in situ; CR = complete response; HGRFS = high-grade recurrence free survival; Ta disease = polyps extending into the lining of the bladder; T1 disease = tumors below the superficial holders held at a public meeting of the lining but not involving the muscular layer of the bladder wall. Midwest Comparative Effectiveness Public Advisory Council (CEPAC) on November 20, 2020. FIGURE 2 Phase 3 Results of Oportuzumab Monatox: Complete Response and High-Grade Recurrence Free Survival, Summary of Findings CIS ± Ta/T1, and Ta/T1a CLINICAL EFFECTIVENESS The systematic literature review 90 identified only one phase 3 single- 80 CIS ± Ta/T1 arm, open-label prospective study Proportion with CR or HGRFS 70 Ta/T1 for nadofaragene and oportuzumab monatox and one phase 2 study of 60 pembrolizumab, making indirect 50 comparisons of relative effectiveness 40 difficult. At the time of the review, 71 only the pivotal trial of nadofaragene 30 58 firadenovec had been published,14 and 20 45 42 40 our review also evaluated information 28 from conference abstracts, regulatory 10 21 18 documents, and data submitted by the 0 3 months 6 months 9 months 12 months manufacturers. Time The pivotal trials of nadofaragene Note: Error bars represent standard error of proportion with CR or HGRFS. firadenovec and oportuzumab mona- a Unpublished data, Sesen Bio, 2020. tox included similar distributions of CIS = carcinoma in situ; CR = complete response; HGRFS = high-grade recurrence free survival; patients with CIS ± Ta/T1 and non-CIS Ta disease = polyps extending into the lining of the bladder; T1 disease = tumors below the superficial with high-grade Ta/T1 disease and lining but not involving the muscular layer of the bladder wall. used the same definitions of BCG- unresponsive disease. However, the nadofaragene firadenovec pivotal trial JMCP.org | June 2021 | Vol. 27, No. 6
The effectiveness and value of nadofaragene firadenovec, oportuzumab monatox, 799 and pembrolizumab for BCG-unresponsive non-muscle-invasive bladder cancer FIGURE 3 Phase 2 Results of Pembrolizumab: Complete Response events (TEAEs) and discontinuation. and CIS ± Ta/T116 For the 2 intravesical therapies, TEAEs generally included bladder-related 90 symptoms such as irritative voiding, 80 hematuria, and urinary tract infec- tion. For pembrolizumab, TEAEs 70 included immune-mediated adverse Proportion with CR 60 CIS ± Ta/T1 events (AEs) and infusion reactions. 50 In the pivotal trial of nadofaragene firadenovec, 146 (93%) of 157 patients 40 evaluated for safety reported at least 30 1 TEAE, of which 14 (9%) were serious, 20 40.6 but only 3 (2%) patients discontinued 38 28 due to TEAEs.14 In the pivotal trial of 10 19 19 oportuzumab monatox, 117 (88%) of 0 133 patients in the safety population 3 months 6 months 9 months 12 months 15 months reported any TEAE, of which 19 (14%) Time were serious, with 4 (3%) patients Note: Error bars represent standard error of proportion with CR. discontinuing treatment due to TEAEs CI = carcinoma in situ; CR = complete response; Ta disease = polyps extending into the lining of the bladder; (unpublished data, Sesen Bio, 2020). T1 disease = tumors below the superficial lining but not involving the muscular layer of the bladder wall. In the pivotal trial of pembrolizumab, 99 (97%) of 102 patients in the safety population reported any AE, of which 26 (26%) were serious, with 10 (10%) required a biopsy at the 12-month In the pivotal trial of nadofaragene patients discontinuing due to AEs evaluation, whereas the oportuzumab firadenovec, 55 (53%) of 103 patients (unpublished data, Merck, 2020).16 monatox pivotal trial did not. This with CIS ± Ta/T1 disease achieved a biopsy could have resulted in addi- CR at 3 months, declining to 24% at LIMITATIONS OF THE tional patients being identified as 12 months. For patients with high- CLINICAL EVIDENCE having recurrent disease who would grade Ta/T1 disease alone, HGRFS The primary limitation in the clini- not have been found without a biopsy. was 35 (73%) of 48 patients at 3 months cal evidence for these 3 agents is the Efficacy outcomes were reported for and 44% at 12 months (Figure 1).14,15 lack of data from randomized con- all eligible patients in the nadofara- In the pivotal trial of oportuzumab trolled trials. The FDA permitted gene firadenovec trial who received monatox, 36 (40%) of 89 patients single arm trials for this population the study drug, whereas patients who with CIS ± Ta/T1 disease achieved a because randomizing patients to pla- did not complete induction therapy CR at 3 months, declining to 17% at cebo or minimally effective therapies were excluded in the oportuzumab 12 months. For patients with high- was deemed unethical. The lack of monatox trial. At the time of this pub- grade Ta/T1 disease alone, HGRFS head-to-head comparative data near lication, only data from the CIS ± Ta/ was 27 (71%) of 38 patients at 3 months the time of launch is not unexpected, T1 cohort of the pivotal trial of pem- and 42% at 12 months (Figure 2; but the lack of randomization in the brolizumab were available. This trial unpublished data, Sesen Bio, 2020). pivotal trials makes even indirect included the additional inclusion cri- In the pivotal trial of pembroli- comparisons needed to guide judg- teria that patients either be ineligible zumab among patients with CIS ± Ta/ ments of relative effectiveness highly for or decline cystectomy. The most T1 disease, 39 (41%) of 96 patients uncertain. common outcomes reported in the achieved a CR at 3 months, which Differences in study populations pivotal trials were complete response declined to 19% at 12 months (Figure 3). between the single arm trials and (CR) and high-grade recurrence free Outcomes for the Ta/T1 cohort were in assessing and reporting outcomes survival (HGRFS) at prespecified time not available at the time of the report further complicate the comparability points after initial evaluation (unpub- (unpublished data, Merck, 2020).16 of the trial results. Although out- lished data, Sesen Bio, 2020; Merck, Harms recorded in these trials comes of nadofaragene firadenovec 2020).14 included treatment-emergent adverse and oportuzumab monatox show Vol. 27, No. 6 | June 2021 | JMCP.org
The effectiveness and value of nadofaragene firadenovec, oportuzumab monatox, 800 and pembrolizumab for BCG-unresponsive non-muscle-invasive bladder cancer TABLE 1 Incremental Cost-Effectiveness Ratios Compared With oportuzumab monatox were not avail- Hypothetical Treatment Comparator in Patients With able at the time of the report, the CIS ± Ta/T1 price for nadofaragene firadenovec was set to equal the annual price of Cost per year in Cost per QALY progression-free pembrolizumab ($164,337), whereas Intervention gained Cost per evLYG state oportuzumab was set at $150,000 Nadofaragene firadenovec $151,000 $135,000 $100,000 per year net of all rebates based on Oportuzumab monatox $382,000 $343,000 $281,000 analyst estimates. Full details on Pembrolizumab $114,000 $103,000 $76,000 ICER’s cost-effectiveness analysis and model are available on ICER’s web- CIS = carcinoma in situ; evLYG = equal value life-year gained; QALY = quality-adjusted life-year; Ta disease = polyps extending into the lining of the bladder; T1 disease = tumors below the superficial site at https://icer.org/assessment/ lining but not involving the muscular layer of the bladder wall. bladder-cancer-2020. For each population, we esti- mated time in progression-free state, total costs, total quality-adjusted life-years (QALYs), total equal value TABLE 2 Incremental Cost-Effectiveness Ratios Compared With Hypothetical Treatment Comparator in Patients life-years gained (evLYGs), and With High-Grade Ta/T1 Disease Alone total life-years (LYs) for each treat- ment over a lifetime time horizon. Cost per year Base-case analyses were assessed Cost per QALY in progression-free Intervention gained Cost per evLYG state from the health care perspective. A Nadofaragene firadenovec $93,000 $87,000 $65,000 discount rate of 3% was applied to all costs, QALYs, evLYGs, and LYs. Oportuzumab monatox $123,000 $117,000 $88,000 The base-case cost-effectiveness, evLYG = equal value life-year gained; QALY = quality-adjusted life-year; Ta disease = polyps extending into the lining of the bladder; T1 disease = tumors below the superficial lining but not involving the muscular with each drug compared with the layer of the bladder wall hypothetical comparator with a 0% CR at 3 months, were $151,000 per QALY gained for nadofaragene firad- enovec, $382,000 per QALY gained for response rates that are similar to or 3-month CR rate could be varied in oportuzumab monatox, and $114,000 better than currently available treat- a sensitivity analysis. For the base per QALY gained for pembrolizumab. ments, such as gemcitabine with or case, this hypothetical treatment Tables 1 and 2 summarize the full without docetaxel, there continues was completely ineffective, with a CR results for all incremental cost- to be considerable uncertainty about of 0% at 3 months. We evaluated the effectiveness outcomes evaluated. their long-term efficacy. Because cost-effectiveness of all treatments In scenario analyses, when the CR they are administered in the bladder, in 2 populations: CIS ± Ta/T1 (popula- of the hypothetical comparator was they appear to have few serious side tion 1) and high-grade Ta/T1 disease increased to 20% in the CIS ± Ta/T1 effects. For pembrolizumab, the trial alone (population 2). We developed a population, the incremental cost- data suggest similar response rates, de novo semi-Markov decision ana- effectiveness ratio for nadofaragene but because it is given systemically, lytic model with model structure and firadenovec and oportuzumab more patients report side effects, and inputs informed by key clinical trials, monatox increased to $155,000 and its use is associated with infrequent previous economic models, system- $407,000, respectively. We did not but potentially serious AEs. atic literature reviews, and input conduct scenario analyses for pem- from stakeholders (patients, advocacy brolizumab. In the high-grade Ta/T1 LONG-TERM COST-EFFECTIVENESS groups, clinicians, payers, research- population, altering the hypothetical Lacking comparative data on which ers, and manufacturers). comparator’s CR to 30% resulted in to base our incremental cost-effec- Costs and utilities for model incremental cost-effectiveness ratios tiveness analysis, we evaluated all health states were derived from 3 of $107,000 for nadofaragene firad- agents compared with a hypotheti- key studies.17-19 Since the prices for enovec and $147,000 for oportuzumab cal comparator treatment whose nadofaragene firadenovec and monatox. JMCP.org | June 2021 | Vol. 27, No. 6
The effectiveness and value of nadofaragene firadenovec, oportuzumab monatox, 801 and pembrolizumab for BCG-unresponsive non-muscle-invasive bladder cancer TABLE 3 Votes on Other Benefits and Contextual Considerations for Nadofaragene Firadenovec and Oportuzumab Monatox 1 (suggests lower value) 2 (intermediate) 3 (suggests higher value) This intervention will not differentially benefit a This intervention will differentially benefit a historically historically disadvantaged or underserved community disadvantaged or underserved community 5 votes 6 votes 0 votes 1 (suggests lower value) 2 (intermediate) 3 (suggests higher value) Small health loss without this treatment as measured by Substantial health loss without this treatment as absolute QALY shortfall measured by absolute QALY shortfall 4 votes 4 votes 3 votes 1 (suggests lower value) 2 (intermediate) 3 (suggests higher value) Small health loss without this treatment as measured by Substantial health loss without this treatment as proportional QALY shortfall measured by proportional QALY shortfall 1 vote 7 votes 3 votes 1 (suggests lower value) 2 (intermediate) 3 (suggests higher value) Will not have a significant impact on improving return to Will have a significant impact on improving return to work work and/or overall productivity vs the comparator and/or overall productivity vs the comparator 3 votes 7 votes 1 vote QALY = quality-adjusted life-year. TABLE 4 Votes on Other Benefits and Contextual Considerations for Nadofaragene Firadenovec 1 (suggests lower value) 2 (intermediate) 3 (suggests higher value) Uncertainty or overly favorable model assumptions Uncertainty or overly unfavorable model assumptions creates significant risk that base-case cost-effectiveness creates significant risk that base-case cost-effectiveness estimates are too optimistic estimates are too pessimistic 2 votes 7 votes 2 votes 1 (suggests lower value) 2 (intermediate) 3 (suggests higher value) Very similar mechanism of action to that of other active New mechanism of action compared with that of other treatments active treatments 0 votes 3 votes 7 votes 1 (suggests lower value) 2 (intermediate) 3 (suggests higher value) Delivery mechanism or relative complexity of regimen Delivery mechanism or relative complexity of regimen likely to lead to much lower real-world adherence and likely to lead to much higher real-world adherence and worse outcomes relative to an active comparator than better outcomes relative to an active comparator than estimated from clinical trials estimated from clinical trials 0 votes 3 votes 7 votes 1 (suggests lower value) 2 (intermediate) 3 (suggests higher value) Will not significantly reduce the negative impact of the Will significantly reduce the negative impact of the condition on the family and caregiver vs the comparator condition on the family and caregiver vs the comparator 1 vote 9 votes 0 votes Vol. 27, No. 6 | June 2021 | JMCP.org
The effectiveness and value of nadofaragene firadenovec, oportuzumab monatox, 802 and pembrolizumab for BCG-unresponsive non-muscle-invasive bladder cancer TABLE 5 Votes on Other Benefits and Contextual Considerations for Oportuzumab Monataox 1 (suggests lower value) 2 (intermediate) 3 (suggests higher value) Uncertainty or overly favorable model assumptions Uncertainty or overly unfavorable model assumptions creates significant risk that base-case cost-effectiveness creates significant risk that base-case cost-effectiveness estimates are too optimistic estimates are too pessimistic 2 votes 7 votes 1 vote 1 (suggests lower value) 2 (intermediate) 3 (suggests higher value) Very similar mechanism of action to that of other active New mechanism of action compared to that of other treatments active treatments 0 votes 3 votes 7 votes 1 (suggests lower value) 2 (intermediate) 3 (suggests higher value) Delivery mechanism or relative complexity of regimen Delivery mechanism or relative complexity of regimen likely to lead to much lower real-world adherence and likely to lead to much higher real-world adherence and worse outcomes relative to an active comparator than better outcomes relative to an active comparator than estimated from clinical trials estimated from clinical trials 0 votes 8 votes 2 votes 1 (suggests lower value) 2 (intermediate) 3 (suggests higher value) Will not significantly reduce the negative impact of the Will significantly reduce the negative impact of the condition on family and caregivers vs the comparator condition on family and caregivers vs the comparator 2 votes 8 votes 0 votes The ICER health benefit price benchmark (HBPB) is a deliberation of the evidence on clinical and cost-effective- suggested price range based on cost-effectiveness thresh- ness of health care interventions. The Midwest CEPAC is olds at the $100,000 and $150,000 per QALY or evLYG. The composed of medical evidence experts, including practicing HBPB for nadofaragene firadenovec ranged from $158,600 clinicians, methodologists, and leaders in patient engage- to $262,000 per year. The HBPB for oportuzumab mona- ment and advocacy. Their deliberation includes input from tox ranged from $92,800 to $162,100 per year. We did clinical experts and patient representatives specific to the not calculate a HBPB for pembrolizumab given that its condition under review, as well as formal comment from original indication was not for NMIBC. Full results are manufacturers and the public. A policy roundtable con- available on ICER’s website at https://icer.org/assessment/ cludes each meeting during which representatives from bladder-cancer-2020. insurers and manufacturers join clinical experts and patient representatives to discuss how best to apply the findings of LIMITATIONS OF THE COST-EFFECTIVENESS MODEL the evidence to clinical practice, insurance coverage, and As noted earlier, there was considerable uncertainty in the pricing negotiations. long-term estimates for the effectiveness of nadofaragene The ICER report on treatments for BCG-unresponsive firadenovec, oportuzumab monatox, and pembrolizumab, NMIBC was the subject of a Midwest CEPAC meeting on and this uncertainty affects any cost-effectiveness analy- November 20, 2020. Following the discussion, the Midwest sis of these agents. The model’s base-case assumption of an CEPAC panel members deliberated on key questions raised ineffective (0% CR) hypothetical comparator is likely overly by ICER’s report. The results of their votes on the clinical conservative, so the base-case results can be viewed as the evidence were as follows: (1) the panel voted 7-4 that the most optimistic scenario and should therefore be inter- clinical evidence was adequate to demonstrate greater preted with caution. net health benefit for nadofaragene firadenovec compared with best supportive care; (2) the panel voted 8-3 that the Policy Discussion evidence was adequate to demonstrate greater net health benefit for oportuzumab monatox compared with best The Midwest CEPAC is one of the independent appraisal supportive care; (3) the panel voted 11-0 that the clinical committees convened by ICER to engage in the public evidence was inadequate to distinguish the net health JMCP.org | June 2021 | Vol. 27, No. 6
The effectiveness and value of nadofaragene firadenovec, oportuzumab monatox, 803 and pembrolizumab for BCG-unresponsive non-muscle-invasive bladder cancer benefit of nadofaragene firadenovec lower-cost regimens and set- Beinfeld, McKenna, Rind, and Pearson from oportuzumab monatox; (4) the ting prices relative to higher-cost are employed by ICER. Touchette received funding from ICER for work on this report panel voted 11-0 that the evidence was options adds to the growing finan- and has also received fees from Monument inadequate to demonstrate a greater cial toxicity of oncology care. Analytics and AstraZeneca, unrelated to net health benefit of nadofaragene • It seems likely that the FDA label this work. The University of Illinois at firadenovec compared with pembro- for the emerging treatments will Chicago (UIC) and Touchette hold a pat- lizumab; (5) the panel voted 10-1 that be limited to BCG-unresponsive ent for the model described in this report. The model is included in ICER’s Interactive the evidence was inadequate to dem- patients, and payers may therefore Modeler, for which a fee is paid to UIC onstrate a greater net health benefit wish to consider requiring docu- and Touchette. Atlas also received funding of oportuzumab monatox compared mentation of a trial of BCG as a from ICER for work on this report. with pembrolizumab. criterion for coverage. The CEPAC panel also voted on • Patient groups should continue ACKNOWLEDGMENTS “other potential benefits” and “con- their efforts to encourage inno- The authors thank Maggie O’Grady, textual considerations” as part of a vation while pushing life science Mrinmayee Joshi, Kanya Shah, Rick process intended to signal to policy- companies to generate better evi- Chapman, and Monica Fredrick for their makers whether there are important dence to guide patient and clinician contributions to this report. considerations when making judg- decision making. 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