3 Committee discussion
The appraisal committee considered evidence submitted by Pfizer and a review of this submission by the evidence review group (ERG). See the committee papers for full details of the evidence.
Clinical need
People would welcome a new treatment option
3.1
The patient experts highlighted that epidermal growth factor receptor (EGFR) mutation-positive non-small-cell lung cancer (NSCLC) tends to present late, so people have more advanced disease at diagnosis compared with the wider NSCLC population. The patient experts also noted that dacomitinib may improve overall survival, which is especially important to patients and their families. The committee agreed that people with EGFR mutation-positive NSCLC would welcome additional treatment options that improve overall survival.
Clinical management
Erlotinib, gefitinib and afatinib are appropriate comparators
3.2
The clinical experts explained that in line with NICE guidance, locally advanced or metastatic EGFR mutation-positive NSCLC is usually first treated with a tyrosine kinase inhibitor such as erlotinib, gefitinib or afatinib (see NICE technology appraisal guidance on erlotinib, gefitinib and afatinib). The committee understood that afatinib is more common in NHS clinical practice in England because as a second-generation tyrosine kinase inhibitor it is better than both erlotinib and gefitinib (first-generation tyrosine kinase inhibitors) in terms of prolonging progression-free survival. The committee also understood that afatinib is associated with more adverse events than erlotinib and gefitinib, so it is generally only offered to people with good Eastern Cooperative Oncology Group (ECOG) performance status. The clinical experts explained that this would also be the case for dacomitinib. The committee agreed that although afatinib is the most commonly used tyrosine kinase inhibitor and has a similar adverse-event profile to dacomitinib, gefitinib and erlotinib were also used in established NHS practice in England. So gefitinib and erlotinib were also listed as comparators in NICE's final scope.
Clinical evidence
Evidence from an open-label randomised controlled trial is relevant and high quality
3.3
The main clinical evidence came from ARCHER 1050, a multicentre, open-label, phase 3 randomised controlled trial. It compared the efficacy and safety of dacomitinib (n=227) with gefitinib (n=225) in adults with untreated locally advanced or metastatic EGFR mutation-positive NSCLC. Patients had either the exon 19 deletion (del19) or exon 21 (L858R) EGFR mutation. The trial included 71 study sites in 7 countries (China, Hong Kong, Japan, Republic of Korea, Italy, Poland and Spain). The primary outcome was progression-free survival, determined by blinded independent review committee. Secondary outcomes included overall survival, objective response rate, length of response, adverse events, time to treatment failure and health-related quality of life. After disease progression, patients could have subsequent treatment with a different drug (see section 3.6). The committee noted that in the trials used to inform NICE technology appraisal guidance on erlotinib, gefitinib and afatinib, the comparator was chemotherapy. But in ARCHER 1050 the comparator was gefitinib (the trial compared a second-generation tyrosine kinase inhibitor [dacomitinib] with a first-generation tyrosine kinase inhibitor [gefitinib]). The committee concluded that ARCHER 1050 was a well-conducted trial providing high-quality evidence relevant to the appraisal.
The treatment arms in ARCHER 1050 are well balanced
3.4
The ERG noted that in the trial, 64.3% of patients having dacomitinib were women compared with only 55.6% of patients having gefitinib. The committee was aware that there was some evidence to suggest that tyrosine kinase inhibitors tend to be more effective at treating EGFR mutation-positive NSCLC in women than in men, and so the trial could be biased in favour of dacomitinib. But the clinical experts did not consider sex to be an important factor. The committee concluded that the treatment arms in ARCHER 1050 were generally well balanced.
Dacomitinib improves progression-free and overall survival compared with gefitinib
3.5
The results of ARCHER 1050 showed that dacomitinib statistically significantly improved progression-free survival compared with gefitinib (14.7 months for dacomitinib compared with 9.2 months for gefitinib; hazard ratio [HR] 0.589, 95% confidence interval [CI] 0.47 to 0.74). Exploratory analyses also showed that dacomitinib improved overall survival compared with gefitinib (34.1 months for dacomitinib compared with 26.8 months for gefitinib; HR 0.760, 95% CI 0.58 to 0.99). During consultation, the company manufacturing gefitinib highlighted that the overall survival Kaplan–Meier curves for dacomitinib and gefitinib crossed at around 11 months (and possibly at around 36 months too). The company suggested that this shows that a specific subgroup (or subgroups) derives more benefit from gefitinib than dacomitinib. Although the committee acknowledged that the Kaplan–Meier curves did cross, it concluded that overall dacomitinib is associated with improved progression-free and overall survival compared with gefitinib.
It is unclear how subsequent treatments may affect overall survival in ARCHER 1050
3.6
In ARCHER 1050, patients who stopped taking the study drug (dacomitinib or gefitinib) could then have subsequent treatment with a different drug (the company considered the subsequent treatments to be confidential so they cannot be reported here). But the committee noted that these subsequent treatments did not reflect the type and proportion of those used in clinical practice in the NHS in England. The committee agreed that there was uncertainty about how subsequent treatments may have affected the overall survival estimates in ARCHER 1050, and that it would consider this in its decision making.
The results of ARCHER 1050 are generalisable to NHS clinical practice in England
3.7
The committee considered whether the baseline characteristics of patients in ARCHER 1050 reflected those seen in NHS clinical practice in England. It noted that the patients in the trial had only the exon 19 deletion (del19) or exon 21 (L858R) EGFR mutations. The clinical experts explained that these 2 mutations account for around 90% of all EGFR mutations. Also, most trials only include people with these mutations, including the trials that were carried out with other tyrosine kinase inhibitors. The committee acknowledged that although other mutations may not respond as well to dacomitinib, the Committee for Medicinal Products for Human Use (CHMP) did not restrict its positive opinion for dacomitinib to these 2 mutations (see section 2). The committee therefore agreed that the EGFR mutation status of patients in ARCHER 1050 generally reflected that seen in NHS clinical practice in England. It also noted that the trial included a large proportion of patients of Asian family origin (74.9% in the dacomitinib treatment arm and 78.2% in the gefitinib treatment arm) because many of the trial centres were in East Asia. It recalled that ethnicity was a prespecified subgroup in ARCHER 1050, and that the company had provided analyses in response to clarification, but the results were underpowered (overall survival: Asian family origin subgroup HR 0.81, 95% CI 0.6 to 1.11; non-Asian family origin subgroup HR 0.72, 95% CI 0.43 to 1.20. The results for progression-free survival are considered academic in confidence by the company and so cannot be reported here). During consultation, the company manufacturing gefitinib highlighted evidence suggesting that Asian ethnicity has been identified as a favourable independent prognostic factor for overall survival in NSCLC, irrespective of smoking status. The committee noted that in the company's overall survival analyses for ethnicity, dacomitinib showed a survival benefit compared with gefitinib in both the non-Asian and Asian family origin subgroups. Although ARCHER 1050 was not powered for subgroup analyses, the results were all aligned and were in favour of dacomitinib (except for the subgroup with ECOG performance status 0). The committee noted that there appeared to be much better progression-free survival for the Asian family origin subgroup, which was not reflected in overall survival for the same population. The committee agreed that there was no conclusive evidence that ethnicity has a significant effect on overall survival. Because the trial was not powered for subgroup analyses, the committee considered that the results from the whole trial population would be generalisable to the population seen in clinical practice in England. The committee noted that ARCHER 1050 excluded people with brain metastases: these are associated with a poor prognosis and often occur in people with EGFR mutation-positive NSCLC. This was an important difference between ARCHER 1050 and the LUX-Lung 7 trial (used in the comparison of afatinib with gefitinib; see section 3.9), in which 16% of patients had brain metastases. The committee concluded that overall, the trial results from ARCHER 1050 were generalisable to NHS clinical practice in England.
Dacomitinib is associated with more adverse events and may need more dose reductions than gefitinib
3.8
The committee noted that dacomitinib had a higher incidence of common adverse events than gefitinib, and that there were more dose reductions in the dacomitinib treatment arm than in the gefitinib treatment arm (66.1% and 8.0% respectively). The committee was also aware that second-generation tyrosine kinase inhibitors such as afatinib are associated with more adverse events, whereas first-generation tyrosine kinase inhibitors are generally better tolerated (see section 3.2). The clinical experts agreed that the differences in the drugs' adverse-event profiles are well known and this is reflected in how they are used in clinical practice. That is, they are used according to whether a person is well enough for treatment, which is typically categorised by ECOG performance status. Although the clinical experts acknowledged that adverse events associated with second-generation tyrosine kinase inhibitors could be effectively managed in clinical practice, they highlighted that the adverse events were detrimental to people's quality of life. The Cancer Drugs Fund clinical lead also highlighted NHS England's concerns about the toxicity of dacomitinib and the high rates of adverse events that are likely to be seen in practice. The committee agreed that dacomitinib had a higher incidence of adverse events and needed more dose reductions than gefitinib. It concluded that how this affected health-related quality of life and resource costs for managing adverse events should be fully captured in the cost-effectiveness analysis.
There is no statistically significant difference between dacomitinib and afatinib in terms of progression-free and overall survival
3.10
The ERG did its own indirect treatment comparison to address these uncertainties, and because the company's model did not report hazard ratios for progression-free or overall survival between dacomitinib and afatinib. The ERG did a fixed-effects network meta-analysis using data from ARCHER 1050 for dacomitinib and from LUX-Lung 7 for afatinib. The company agreed with the ERG's approach to estimating the hazard ratios. The results suggested that dacomitinib might be better than afatinib in terms of extending progression-free and overall survival, but there was no significant difference between the 2 treatments (progression-free survival HR 0.80, 95% CI 0.57 to 1.12; overall survival HR 0.88, 95% CI 0.61 to 1.29). The committee recalled that there was uncertainty around any estimates from a network meta-analysis that used data from ARCHER 1050 and LUX-Lung 7, because of the differences between the trials in terms of baseline patient characteristics (and because the proportional hazards assumption may have been violated in ARCHER 1050). It concluded that any estimates were uncertain and based on the evidence available there was no statistically significant difference between dacomitinib and afatinib in terms of extending progression-free and overall survival.
The company's economic model
The company's model is appropriate for decision making
3.11
The company used a partitioned-survival economic model that included 3 health states: pre-progression, post-progression and death. The model included either dacomitinib, afatinib, gefitinib or erlotinib as first-line treatment, followed by osimertinib (if T790M mutation-positive) or chemotherapy. The committee was concerned that the model captured only the costs and not the clinical benefits of subsequent treatments. However, the committee concluded that the model was generally appropriate and consistent with the models used in other appraisals for NSCLC.
Resource use and costs
The company's assumptions about health benefits and costs of subsequent therapies are implausible
3.20
In its original base case, the company assumed that 71% of people having tyrosine kinase inhibitors would also have disease progression and second-line treatment. Of these, 56% would develop the T790M mutation and have osimertinib and the other 44% would have chemotherapy. The model also assumed that 48% of the original cohort would have third-line treatment; of these, 56% would have chemotherapy (the same people who had second-line osimertinib) and 44% would have docetaxel (the same people who had second-line chemotherapy). The committee was aware of NICE's statement on handling comparators and treatment sequences on the Cancer Drugs Fund. This states that 'products recommended for use in the Cancer Drugs Fund after 1 April 2016 should not be considered as comparators, or appropriately included in a treatment sequence, in subsequent relevant appraisals'. The committee accepted that it was appropriate for osimertinib to be included in the treatment sequence in the model for dacomitinib, because this appraisal started before the position statement came into effect. The committee noted that the proportions and subsequent treatments used in the model did not reflect those used in ARCHER 1050 (see section 3.6). The Cancer Drugs Fund clinical lead explained that the proportions of people having second- and third-line treatments were higher than those seen in NHS clinical practice (50% to 60% for second line and 25% to 30% for third line). Also, osimertinib has been used less than would be expected in NHS clinical practice in England (8% to 13%), so the model overestimates its use. The clinical experts agreed that the proportions of people having subsequent treatments in the model were too high. The committee understood that the company had used the same proportions for second- and third-line treatments for all 4 tyrosine kinase inhibitors; so, although the exact proportions were inaccurate, the costs applied to the dacomitinib and comparator treatment arms were the same. But the committee recalled that the model did not capture the clinical benefits of subsequent treatment. It concluded that the company's assumptions about treatment costs and benefits in the model did not reflect the type and proportion of subsequent treatments taken by patients in the trial.
Results of the cost-effectiveness analyses
The company's updated deterministic base-case ICER for dacomitinib was below £30,000 per QALY gained
3.21
The company's 2 updated base-case analyses provided in response to consultation both included:
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an increased discount in dacomitinib's commercial arrangement
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the committee's preferred modelling of progression-free survival (see section 3.13)
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age-related disutilities (see section 3.17)
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disutilities for adverse events (see section 3.19).
Updated base case 1 included:
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equivalent post-progression survival (hazard ratio=1) from 71 months (see section 3.16)
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the Labbé post-progression utility value (0.64; see section 3.18).
Updated base case 2 included:
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no additional survival benefit (hazard ratio=1) after 60 months (see section 3.15)
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the Labbé post-progression utility value (0.64; see section 3.18).
When the updated final commercial arrangement was included, both base cases resulted in ICERs below £30,000 per QALY gained. Because the dacomitinib commercial arrangement is confidential, the exact ICERs cannot be reported here.
The ERG's updated base-case ICER for dacomitinib is over £30,000 per QALY gained
3.22
The ERG provided its updated preferred base case. This included the comparator commercial arrangements and the dacomitinib commercial arrangement that was submitted in response to consultation, assuming:
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no additional survival benefit after 36 months (see section 3.16)
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the post-progression utility value from ARCHER 1050 (see section 3.18).
The committee noted that the ERG's updated base case was above £30,000 per QALY gained. The ERG also provided scenario analyses with ICERs for:
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no additional survival benefit after 48 months
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no additional survival benefit after 60 months and
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equivalent post-progression survival (hazard ratio=1 from 71 months).
The committee noted that the ICERs for no additional survival benefit after 60 months and for equivalent post-progression survival were both below £30,000 per QALY gained. The ICER for no additional survival benefit after 48 months was above £30,000 per QALY gained. Because dacomitinib and the comparators have confidential commercial arrangements, the exact ICERs cannot be reported here. However, these ICERs did not include the company's final commercial arrangement (see section 3.23).
The most plausible ICER for dacomitinib is within the range normally considered to be a cost-effective use of NHS resources
3.23
The committee was aware that the differences among the company's and ERG's base cases and the alternative scenario ICERs were driven by the different assumptions about overall survival for all treatments. It recalled that the ERG's updated base case assumed equal efficacy for all treatments after 36 months (see section 3.22). But the company's updated base cases submitted in response to consultation assumed either equivalent post-progression survival from 71 months (updated base case 1, see section 3.21) or no additional survival benefit after 60 months (updated base case 2, see section 3.21). The committee noted the range of ICERs produced by the ERG's updated base case and scenario analyses and the company's 2 updated base-case analyses. The committee recognised that there were no clinical data from ARCHER 1050 after 36 months and that all the economic modelling predicted a hazard ratio for overall survival equal to 1 from 36 months. The committee accepted the company's position that the ERG's original base-case analysis, which assumed no additional survival after 36 months, resulted in a proportion of patients having treatment with dacomitinib at 36 months who would be expected to have clinical benefit from this ongoing treatment (see section 3.16). The committee also recognised clinical opinion that post-progression survival could be similar between treatments because of ongoing tyrosine kinase inhibitor treatment. After considering the trial data, the economic modelling and clinical opinion, the committee felt that on balance the cost-effectiveness estimates for dacomitinib would lie between the ERG's updated base-case analysis (hazard ratio for overall survival equal to 1 at 36 months) and the company's updated base case 1 (equal post-progression survival from 71 months). The committee decided that the most plausible ICER for dacomitinib would approximate to the ICER associated with the ERG's scenario analysis for assuming equal efficacy from 48 months (because dacomitinib and the comparators have confidential commercial arrangements, the exact ICERs cannot be reported here). When the company submitted analyses incorporating the final commercial arrangement, it included the assumption that there was no survival gain after 48 months and a utility value of 0.678 (see section 3.18). The ICER for this analysis was below £30,000 per QALY gained (dacomitinib has a confidential commercial arrangement so the exact ICER cannot be reported here). The committee therefore concluded that the most plausible ICER for dacomitinib was within the range normally considered to be a cost-effective use of NHS resources (dacomitinib and the comparators have confidential commercial arrangements so the exact ICERs cannot be reported here).
End of life
Dacomitinib does not meet the end-of-life criteria
3.24
The committee considered the advice about life-extending treatments for people with a short life expectancy in NICE's guide to the methods of technology appraisal. The company submission stated that dacomitinib does not meet the end-of-life criteria. The committee considered the clinical evidence and agreed that life expectancy for people with untreated locally advanced or metastatic EGFR mutation-positive NSCLC having standard care is more than 2 years: in ARCHER 1050, the median overall survival with gefitinib was 26.8 months (95% CI 23.7 to 32.1). The committee therefore concluded that dacomitinib did not meet the end-of-life criteria for this indication.
Innovation
The model adequately captures the benefits of dacomitinib
3.25
The company considered dacomitinib to be innovative, highlighting that it improves survival compared with gefitinib, erlotinib and afatinib. The clinical experts agreed that dacomitinib is an effective second-generation tyrosine kinase inhibitor and that people would welcome additional treatment options. However, they also highlighted that there is no evidence to support dacomitinib's use for patients with brain metastases because they were excluded from ARCHER 1050. The committee concluded that it had not been presented with any additional evidence of benefits that were not captured in the measurement of the QALYs and the resulting cost-effectiveness estimates.
Conclusion
Dacomitinib is recommended for routine use in the NHS
3.26
Having considered all the available evidence for dacomitinib, the committee concluded that dacomitinib was a cost-effective use of NHS resources for untreated locally advanced or metastatic EGFR mutation-positive NSCLC.
Other factors
3.27
No equality or social value judgement issues were identified.