Institute for Clinical and Economic Review’s (ICER) Unsupported Price Increase Assessment


The National Health Council (NHC) is pleased to provide comments on the Institute for Clinical and Economic Review’s (ICER) solicitation for feedback on the Unsupported Price Increase Assessment draft protocol.

Founded in 1920, the NHC is the only organization that brings together all segments of the health community to provide a united voice for the more than 160 million people in the United States with chronic diseases and disabilities, and their family caregivers. Made up of more than 125 diverse national health-related organizations and businesses, the NHC’s core membership includes the nation’s leading patient advocacy organizations, which control its governance and policy-making process. Other members include professional and membership associations; nonprofit organizations with an interest in health; and representatives from the pharmaceutical, generic drug, health insurance, device, and biotechnology industries.

This work is very much aligned with our 2017 report Policy Recommendations for Reducing Health Care Costs. One of the recommendations included in that report was that the National Academy of Medicine could commission reports on price increases on selected drugs of significant interest to patients. Selection criteria would be based on lack of competition, shortages, and significant price increases. We suggested that manufacturers would submit any relevant information to provide justification for the price increase, and the National Academy would retain any confidential and propriety information. The information to be collected would include but not be limited to:

  • A narrative of factors contributing to the drug’s pricing
  • Existing therapeutic alternatives and any information demonstrating its
  • comparative patient value, consistent with information contained in the FDA label
  • Acquisition information if the drug was not developed by the current manufacturer
  • Aggregate research, development, and administrative expenditures
  • Aggregate rebates, discounts, and other concessions that reduce the effective price

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