Let a Thousand Models Bloom: ICER Analytics Opens the Floodgates to Cloud Pseudoscience

It has been noted on numerous occasions that modeled claims for cost-effectiveness, if driven by assumption for the lifetime of a hypothetical patient population, can be easily ‘gamed’ to create a required claim. These marketing exercises to support product entry are all too common in the literature. The institute for Clinical and Economic Review (ICER) in its launch of the ICER Analytics platform has provided a framework to support precisely these activities. Following the mainstream methodology in health technology assessment, the ICER Analytics platform facilitates the creation of approximate information to support formulary decisions. This is an odd development because it undercuts ICERs belief that it is the key arbiter in health technology assessment in the US, setting the stage for pricing and access recommendations. With the release of the ICER Analytics platform, others can now customize the ‘backbone’ ICER model in a disease area (i.e., change assumptions) to develop alternative and competing value assessments and ‘fair’ price claims. The problem is, of course, that without a reference point, there is no basis for comparing modeled claims other than through challenging assumptions. Indeed, ICER has made this easy by reducing barriers to lifetime model building so that manufacturers and others can create competing (and confusing) claims within, literally, a few minutes. ICER will then become one of a multitude of competing voices for the attention of formulary committees and other health decision makers; letting a thousand imaginary models bloom where no model can be judged on the basis of credible, empirically evaluable and replicable product claims.