IVI submitted comments to ICER regarding proposed methodological changes for assessments of the value of single or short-term transformative (SST) therapies. IVI emphasized the need for ICER to address the potential use of its findings by decision makers, specifically when short-term budget estimates may discourage investment in therapies with high long-term value, including careful consideration of the potential for use of outcomes-based contracts and other mechanisms of payment. IVI also offered specific comments on ICER’s stances on structural uncertainty in HEOR models and on the role and application of novel and non-clinical elements of value.

Read the full comment letter to ICER here.