Discrepancies Between FDA-Required Labeling and Evidence that Payers Cite in Drug Coverage Policies

BACKGROUND: FDA-required labeling summarizes certain data that the FDA relies on in its drug approval process. However, when determining coverage of specialty drugs, health care payers may consider dissimilar evidence. OBJECTIVE: To compare evidence cited by the largest U.S. commercial payers in their specialty drug coverage policies with evidence featured in the labeling of the indicated drugs. METHODS: We used the Tufts Medical Center Specialty Drug Evidence and Coverage Database (SPEC)—a database of specialty drug coverage policies issued by 17 of the 20 largest U.S. commercial health care payers—to identify coverage policies for drugs indicated for multiple sclerosis, rheumatoid arthritis, juvenile idiopathic arthritis, ankylosing spondylitis, and non-small cell lung cancer (NSCLC). These disease categories were selected because each was represented by multiple drugs. For each drug, we identified endpoints included in the clinical studies presented in the FDA-required labeling. Using SPEC, we identified randomized controlled trials (RCTs) and other clinical studies that at least 1 payer cited in its coverage policies for the included drugs. We reviewed the full text of each study to identify the endpoints reported. We categorized endpoints as identical to endpoints in the FDA-required labeling of the drugs; similar (e.g., a different measurement scale was used to evaluate the same endpoint); and different (the endpoint was not featured in the FDA-required labeling). RESULTS: We included 41 drugs and reviewed 348 studies (246 RCTs and 102 other clinical studies). Of 2,237 endpoints, 63% were categorized as identical, 26% as similar, and 12% as different. Rheumatoid arthritis was the indication with the largest proportion of endpoints categorized as identical (74% of endpoints in the RCTs cited by payers; 59% of endpoints in the other clinical studies cited by payers). NSCLC was the indication with the largest proportion of endpoints categorized as different (33% of end-points in the RCTs cited by payers; 37% of endpoints in the other clinical studies cited by payers). CONCLUSIONS: Payers often report reviewing clinical evidence that goes beyond information included in FDA-required labeling. Our findings suggest that the FDA should continue engaging with the manufacturer and payer communities to appropriately facilitate communication of information necessary to allow for informed coverage decisions.