CMAC responded to the Department of Health and Social Care’s consultation on the commercial framework.
The consultation was the first of two consultations on the Commercial Framework that the DHSC had committed to as part of the 2024 Voluntary Scheme for Branded Medicines Pricing and Access agreement.
This consultation focused on potential commercial opportunities that could support access to multi-indication and combination treatments.
CMAC were pleased to see the focus on increasing clarity about when indication-based pricing agreements will be offered. However, we believe that the eligibility criteria for indication-based pricing agreements are too strict.
The need for indication-specific pricing arrangements is increasing with more drugs being developed and used across multiple diseases and patient groups. The cost-effectiveness of a drug across indications is influenced by the size of the patient population, the age and frailty of a patient population, the cost of the current standard of care and the clinical efficacy. We believe these differences lead to delays in access due to lengthy reimbursement discussions and non-submissions of less profitable indications.
We were also encouraged to see that DHSC is supporting the CMA’s position statement, which enables company-to-company engagement over combination treatments. The CMA position statement is a good first step, but we are concerned that it is not enough to support the approvals of combination treatments in the UK, particularly where there is no incentive for the supplier of the backbone treatment to engage in negotiations. More needs to be done to help ensure patients can access effective treatment, irrespective of whether they are combination treatments or individual drugs.
