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Donepezil, rivastigmine, galantamine and memantine for ...

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community-based care costs) were calculated based<br />

on data presented by Stewart <strong>and</strong> colleagues 82 of<br />

community costs from a societal perspective,<br />

where 23% of these costs are assumed (cited as<br />

assumption by Stewart <strong>and</strong> colleagues) to fall on<br />

the public sector, an estimate of £3231 per year is<br />

used in the industry model (the model assumes<br />

this home care cost is unrelated to MMSE/severity<br />

scores in base-case analysis). The model uses £887<br />

per year <strong>for</strong> <strong>rivastigmine</strong> costs <strong>and</strong> an estimate of<br />

monitoring costs (outpatient <strong>and</strong> GP visits) of<br />

£468 <strong>for</strong> base-case analysis (with variations in<br />

sensitivity analysis). Patients dropping out from<br />

treatment (during a 6-month model cycle) are<br />

allocated a 3-month drug <strong>and</strong> monitoring cost.<br />

In base-case analysis the discount rate <strong>for</strong> future<br />

costs <strong>and</strong> benefits is 3.5% per year.<br />

Results presented in the industry submission on<br />

cost-effectiveness of <strong>rivastigmine</strong> show an<br />

incremental cost of £2121 <strong>and</strong> an incremental<br />

QALY gain of 0.0862 from <strong>rivastigmine</strong> treatment<br />

over 5 years, reflecting a cost per QALY of £24,616.<br />

The submission states that where probabilistic<br />

sensitivity analysis has been undertaken, involving<br />

all key uncertain parameters, there is a probability<br />

of over 80% that <strong>rivastigmine</strong> is considered costeffective<br />

where the NHS is prepared to pay<br />

£30,000 per QALY. From the CEAC presented, this<br />

probability would appear to fall well below 20%<br />

where the NHS was only prepared to pay £20,000<br />

per QALY. We discuss below some concerns over<br />

the methods used <strong>for</strong> probabilistic analysis.<br />

In addition to probabilistic sensitivity analysis, the<br />

submission presents findings from one-way<br />

sensitivity analysis on important model parameters,<br />

<strong>and</strong> the authors report that results are insensitive<br />

to most of the parameters examined. However,<br />

there is no one-way analysis per<strong>for</strong>med on the<br />

assumptions surrounding the calculation of QALY<br />

values. Where cost-effectiveness analysis assumes<br />

that the only cost considerations are drug costs <strong>and</strong><br />

monitoring costs (at base-case assumptions) the<br />

cost per QALY is £39,563. Given that the<br />

monitoring cost <strong>for</strong> those treated with <strong>rivastigmine</strong><br />

is one of the variables that the authors highlight as<br />

impacting on results (i.e. cost per QALY sensitive<br />

to monitoring assumptions), it seems reasonable to<br />

assume that multi-way sensitivity analysis should be<br />

undertaken. Were the analysis to assume higher<br />

cost scenarios <strong>for</strong> monitoring <strong>and</strong> that only drug<br />

<strong>and</strong> monitoring costs are relevant <strong>for</strong> costeffectiveness,<br />

the cost per QALY would be much<br />

higher than £40,000 (indeed, much higher than<br />

£40,000 per QALY if lower QALY values were also<br />

assumed in the sensitivity analysis).<br />

© Queen’s Printer <strong>and</strong> Controller of HMSO 2006. All rights reserved.<br />

Health Technology Assessment 2006; Vol. 10: No. 1<br />

Comments on industry submission <strong>for</strong><br />

<strong>rivastigmine</strong><br />

We have highlighted above some concerns over<br />

the analysis presented in the industry submission<br />

<strong>for</strong> <strong>rivastigmine</strong> (see Appendix 15 <strong>for</strong> an outline<br />

appraisal of the model). Importantly, we are<br />

concerned at the sole use of MMSE to describe AD<br />

severity, to model disease progression <strong>and</strong> to<br />

reflect QALY gains associated with disease<br />

progression. As discussed in other earlier <strong>and</strong> later<br />

parts of this report, we believe that the use of<br />

cognitive function alone to characterise <strong>and</strong> model<br />

disease progression in AD is suboptimal <strong>and</strong> is<br />

likely to misrepresent disease progression. A<br />

further related <strong>and</strong> important concern is the use<br />

of data in the model on disease progression in the<br />

<strong>rivastigmine</strong> treated cohort which is from an<br />

observational study, an open-label study, which<br />

may be subject to serious bias, <strong>and</strong> which does not<br />

reflect an ITT analysis. Treatment benefit is<br />

reflected using data from treatment responders<br />

over time, there<strong>for</strong>e in later time periods it is only<br />

those patients who continue to benefit, <strong>and</strong> who<br />

may be highly motivated, who are used in<br />

comparison with a non-<strong>rivastigmine</strong> treated<br />

cohort. The methodology used to predict disease<br />

progression over time in an indirect<br />

control/comparator group is from Mendiondo <strong>and</strong><br />

colleagues, 128 <strong>and</strong> this is based on MMSE scores.<br />

The methodology from Mendiondo <strong>and</strong><br />

colleagues is intuitively appealing, but it is not<br />

transparent (to us) from the published paper, or<br />

the submitted industry model. The observational<br />

data used by Mendiondo <strong>and</strong> colleagues to model<br />

disease progression are from the CEARAD<br />

database, <strong>and</strong> reflects a US patient group that may<br />

not be generalisable to the UK treatment-eligible<br />

population. Furthermore, we have not identified<br />

any other applications of this methodology as a<br />

means of validation.<br />

The industry model is presented as a probabilistic<br />

model, yet we have concerns over some of the<br />

methods used in the model. The analysis does not<br />

cover all possible variables in the probabilistic<br />

sensitivity analysis, <strong>and</strong> <strong>for</strong> a number of<br />

parameters (i.e. probability of institutionalisation,<br />

costs <strong>for</strong> home care, monitoring costs) the model<br />

does not apply distributions around a mean<br />

parameter value; instead the model uses a number<br />

of possible mean values (from various<br />

sources/calculations) <strong>and</strong> r<strong>and</strong>omly selects one of<br />

the possible mean values (see further comment<br />

below). This reflects a r<strong>and</strong>om ‘choice’ (or options)<br />

of input parameters, <strong>and</strong> reflects what would be<br />

regarded as a discrete distribution, although the<br />

choice of possible inputs may have no relation to<br />

95

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