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The Formulary Process: Who Decides Coverage?. The P and T Committee orThe
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1. Evidence-based Formularies Pete Penna, PharmD
Formulary Resources, LLC
2. The Formulary Process: Who Decides Coverage? The P and T Committee
or
The Pharmacy Business Committee
- P and T determines clinical merit
- If equivalent, then business issues are the determining factor
(A key issue is the capabilities of the staff support pharmacist)
4. Three Basic Questions: Is the drug under review more effective, equal to, or less effective than comparators?
5. Three Basic Questions: Is the drug under review safer, equal to or less safe than its comparators
6. Three Basic Questions: If equivalent to the comparators, which drug is the best overall deal?
7. Current Method of Evaluation Anecdote and bias
Incomplete information
Drug impact only (cost, rebate)
Evidence based decision-making
Total medical costs: cost offsets
Total health impact
Total value
8. Factors That Can Impact a Decision
9. The Environment: Current Limitations Often inadequate safety and efficacy data
Evidence-based assessments difficult
Lack of unpublished studies
Lack of off-label use data
Lack of QOL, functional status, and cost-effectiveness data
Committee capabilities
Excessive staff time required Typically, safety and efficacy data has been well researched and documented, but this information may still be inadequate, particularly in the case of drugs that are fast-tracked by the FDA. The vast majority of products lack a description of their effectiveness in actual practice. Accordingly, P&T committee members must either ignore the economics and outcomes implications of products under review, attempt to express efficacy data in terms of effectiveness, contract for their own PE studies to gain the necessary perspective. Typically, safety and efficacy data has been well researched and documented, but this information may still be inadequate, particularly in the case of drugs that are fast-tracked by the FDA. The vast majority of products lack a description of their effectiveness in actual practice. Accordingly, P&T committee members must either ignore the economics and outcomes implications of products under review, attempt to express efficacy data in terms of effectiveness, contract for their own PE studies to gain the necessary perspective.
10. Other Issues Status of decision making - increasing challenges to formularies
Consumer demand and appeals
Manufacturer pressure
Foreign formulary processes
FDA regulations and unsolicited requests
AMCP Format for Formulary Submissions
11. Whats Needed to Make the Best Decisions? EBM expertise
Appropriate committee membership
Capable staff support
Evidence
A rigorous process
Support of the organization
12. Whats Meant by Evidence? Randomized controlled trials
Peer reviewed publications
Data on file
Anecdotal information
Comparator information
Economic information
13. Is the Evidence Relevant? Are studies (of any type) well designed and conducted?
relevant study populations?
Are head to head comparisons relevant to clinical practice?
Are multiple measures of efficacy and effectiveness presented?
Is focus on intermediate endpoints or final outcomes?
14. Is the Evidence Relevant? Are costs associated with introduction of the drug addressed?
Is long term impact addressed (beyond clinical trial periods)?
Is impact on sub-groups addressed?
differing cost-effectiveness characteristics (age, sex, physiological response)
15. The Need for Improvement Given the current environment there appears to be a real need for change
Given the diversity in evaluation processes, there is a substantial need for standardization
16. AMCPs Format for Formulary Submissions
17. Content Product Information
Supporting Clinical and Economic Information
Modeling Report
Product Value and Overall Cost
Supporting Information
18. Product Information Product description
- Approved Indications
- Off label Uses
- Pharmacology
- Adverse Reactions and Interactions
- Pharmacokinetics
19. Product Information (Cont.) Place in Therapy
- Epidemiology
- Pathophysiology
- Approaches to Treatment
- Alternative/Comparator Products
- Place in Treatment
- Expected Outcomes
20. Supporting Clinical and Economic Information Key Clinical and Economic Studies (Published or not) in evidence tables
Disease Management Intervention Strategies
Outcomes Studies and Economic Evaluation Supporting Data
21. Modeling Report To predict system-wide consequences of the drug
Helps define the drugs role in the MCO
Should be relevant to the MCO, based on their
- Costs
- Demographics
Overall, aids the decision-making process
22. Model Output Examples The cost to treat a case of AOM using drug A = $10.50, vs $59.00 for drug B
We need to invest $3 million in bisphosphonates to prevent 1 fracture
Using Wonderstatin for all lipid lowering will increase drug spend $0.75 pmpm, but will decrease TME by $2.50 pmpm.
23. Product Value and Overall Cost Develop a Value Argument Based on:
Summary of all the data presented
Expected unit cost
Estimate of the expenditures for the drug
Anticipated effects on clinical and HRQL outcomes
Economic consequences for the MCO, members, and clients
24. Supporting Information References (Copies of publications or other documents)
Spreadsheet models
Submission check-sheet.
Anything else that may be pertinent but does not fit elsewhere.
25. TYPICAL DOSSIER REVIEW
26. AMCP Format Perspective The Format is not the Answer to rational formulary or coverage decisions, but it is a major step in the right direction