The company provided a submission to NICE describing the use of Enco + Bini (within the context of its licensed indication) in adults with advanced (unresectable or metastatic) BRAF V600 mutation-positive melanoma. The comparator for this appraisal was Dab + Tram [20]. The ERG examined and critiqued both the initial and subsequent evidence submissions from the company as well as taking into consideration the company’s response to their request for clarification on a number of issues. The ERG report comprised a critical review of the evidence of the clinical and cost-effectiveness of the technology based upon the company’s submissions to NICE. The review embodied three aims:
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To assess whether the company’s submission conformed to the methodological guidelines issued by NICE
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To assess whether the company’s interpretation and analysis of the evidence were appropriate
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To indicate the presence of other sources of evidence or alternative interpretations of the evidence that could help inform NICE guidance.
In addition to providing this detailed critique, the ERG modified a number of key assumptions and parameters within the company’s economic model to examine the impact of such changes. This section summarises the evidence submitted by the company and the ERG’s review of that evidence.
Clinical Evidence
Direct Evidence
The company conducted a literature search that identified a single randomised controlled trial (RCT), the COLUMBUS trial [21,22,23]. The COLUMBUS trial [21,22,23] is an international, randomised, open-label, phase III trial designed to assess the clinical effectiveness of the licensed dose of Enco + Bini compared with vemurafenib and compared with encorafenib monotherapy (Enco) in 577 patients with advanced (unresectable or metastatic) BRAF V600 mutation-positive melanoma. The results for patients randomised to the Enco arm were not relevant to the present appraisal and will not be discussed in any detail here. The COLUMBUS trial [21,22,23] did not compare Enco + Bini with Dab + Tram, the comparator specified in NICE’s final scope.
The direct evidence from the COLUMBUS trial [21,22,23] is presented in Table 1. The primary objective of the COLUMBUS trial [21,22,23] was to compare PFS between Enco + Bini and vemurafenib based on blinded independent central review (BICR). At the data cut-off date of 19 May 2016, median PFS was 14.9 months (95% confidence interval [CI] 11.0–18.5) and 7.3 months (95% CI 5.6–8.2) in the Enco + Bini and vemurafenib arms, respectively. The difference was statistically significant in favour of Enco + Bini: hazard ratio (HR) 0.54 (95% CI 0.41–0.71); stratified one-sided log-rank test p < 0.0001.
Table 1 PFS and OS in the ITT population of the COLUMBUS trial OS outcomes could not be formally tested, according to the pre-specified hierarchical approach of statistical testing, since Enco + Bini did not demonstrate a statistically significant advantage over Enco (HR 0.75; 95% CI 0.56–1.00). Nominal p values for OS from the interim OS analysis (7 November 2017) were, therefore, only descriptive. Median OS was 33.6 months (95% CI 24.4–39.2) in the Enco + Bini arm and 16.9 months (95% CI 14.0–24.5) in the vemurafenib arm. The HR for the comparison of Enco + Bini with vemurafenib was 0.61 (95% CI 0.47–0.79; nominal one-sided p < 0.0001). Results of updated, supportive and sensitivity analyses of primary and key secondary efficacy outcomes were consistent with the results of the primary analysis.
The HRQoL results from the COLUMBUS trial [21,22,23] demonstrated that Enco + Bini statistically significantly delayed deterioration in quality of life compared with vemurafenib, as measured by median time to 10% deterioration on the Functional Assessment of Cancer Therapy-Melanoma (FACT-M) subscale, the European Organisation for Research and Treatment of Cancer Quality of Life Questionnaire-Core 30 (EORTC-QLQ-C30) global health status and the European Quality of Life-5 Dimensions Questionnaire (EQ-5D-5L) questionnaire.
The frequencies of AEs were similar across the three arms of the COLUMBUS trial [21,22,23]. Patients treated with Enco + Bini had a longer time on treatment compared with patients treated with vemurafenib. The most frequently reported ≥ grade 3 serious AEs in ≥ 2% of patients treated with Enco + Bini were pyrexia and anaemia, and, in the vemurafenib arm, they were general physical health deterioration and back pain. The most common All-grade serious AEs (≥ 2.0% of patients) in the Enco + Bini arm were pyrexia, abdominal pain, acute kidney injury and anaemia; in the vemurafenib arm, the only common all grade serious AE was general physical health deterioration.
The ERG noted that the clinical efficacy outcomes and the HRQoL outcomes of the COLUMBUS trial [21,22,23] favoured the use of Enco + Bini and that Enco + Bini appeared to be well tolerated by patients.
Indirect Evidence
In the absence of direct evidence comparing Enco + Bini versus Dab + Tram, the company conducted Bayesian network meta-analyses (NMAs) to indirectly estimate the relative effects of treatment efficacy (PFS and OS), safety and HRQoL. The company identified seven RCTs (COLUMBUS [21,22,23], COMBI-v [24, 25], COMBI-d [26,27,28], BRF113220 Part C [29,30,31,32,33], coBRIM [34,35,36], BREAK-3 [31, 37, 38] and BRIM-3 [39,40,41,42]) that were designed to investigate the efficacy of BRAF inhibitor (BRAFi) therapies. Clinical efficacy and safety data were available from all of the trials, whilst HRQoL data were collected in five trials (COLUMBUS [21,22,23], COMBI-v [24, 25], COMBI-d [26,27,28], coBRIM [34,35,36] and BREAK-3 [31, 37, 38]).
Results from the NMAs (Table 2) showed no statistically significant differences between Enco + Bini and Dab + Tram for the outcomes of investigator-assessed PFS and OS. Three different HRQoL NMA results were estimated: pre-progression, difference in change from baseline at week 32, and at disease progression. The HRQoL results all favoured Enco + Bini (Delta < 0); however, the credible intervals (CrIs) cross 0 for all analyses, therefore the differences were not statistically significant.
Table 2 PFS, OS, AEs and HRQoL from the NMA produced by the company NMA results for the incidence of any grade ≥ 3 AEs favoured Dab + Tram (odds ratio [OR] > 1), while results for serious AEs favoured Enco + Bini (OR < 1). However, for both analyses, the CrIs crossed 1, meaning a statistically significant difference was not demonstrated.
Critique of Clinical Evidence and Interpretation
The ERG was satisfied with the company’s literature search strategy approach and was confident that the search was carried out to an acceptable standard. The ERG did not identify any additional studies that should have been included in the company’s review.
The ERG considered that the COLUMBUS trial [21,22,23] was of good quality and was well-conducted, with blinded independent review of PFS outcomes and collection of HRQoL data. The ERG noted that the patients recruited to the trial were largely representative of patients with advanced (unresectable or metastatic) BRAF V600 mutation-positive melanoma who are likely to be treated in the NHS, with the caveat that very few patients in the COLUMBUS trial [21,22,23] had brain metastases and none of the patients had a poor performance status (PS) (i.e., PS ≥ 2).
The results from the COLUMBUS trial [21,22,23] did not provide evidence for the clinical effectiveness of Enco + Bini versus Dab + Tram, the comparator specified in the final scope issued by NICE.
The ERG interpreted the results of the company’s NMAs with caution due to several issues relating to the methods, including the sparsity of evidence in the networks (particularly the HRQoL network), the variability in the lengths of trial follow-up (2–6 years), differences between trials in median follow-up for OS (11–33.3 months), the inclusion of dacarbazine within the networks (which is not a BRAFi and is no longer regarded as a standard NHS treatment), and the fact that only an NMA of PFS by local investigator review (rather than BIRC) was feasible. Five of the seven trials (COLUMBUS [21,22,23], COMBI-v [24, 25], BRF113220 Part C [29,30,31,32,33], BREAK-3 [31, 37, 38] and BRIM-3 [39,40,41,42]) included within the NMAs were designed as open-label studies; the ERG noted that investigator assessment of PFS in open-label trials may be subject to bias.
The ERG also noted that, in the final scope [20], NICE did not consider immunotherapies to be appropriate comparators to Enco + Bini. However, clinical advice to the ERG was that, in the NHS, many patients with advanced (unresectable or metastatic) BRAF V600 mutation-positive melanoma are treated with a programmed cell death protein 1 (PD-1) inhibitor immunotherapy as a first-line treatment and the rationale for not including immunotherapies as comparators in the final scope was unclear to the ERG. The ERG considered that, as many NHS patients are offered an immunotherapy as a first-line treatment, results from the company’s NMAs are only relevant to patients in the NHS who are likely to be treated with targeted therapies, i.e. patients with highly symptomatic or rapidly deteriorating disease.
Cost-Effectiveness Evidence
Overview of Company’s Economic Evidence
The company’s economic evaluation compared the cost-effectiveness of Enco + Bini versus Dab + Tram when used to treat advanced (unresectable or metastatic) BRAF V600 mutation-positive melanoma. Using Microsoft Excel, the company produced a partitioned survival model with a 30-year time horizon and monthly cycles. The UK NHS was the perspective of the model, in line with the NICE reference case [1]. Outcomes were measured in quality-adjusted life years (QALYs), and both costs and QALYs were discounted at an annual rate of 3.5%, as recommended by NICE [1]. The model comprised three mutually exclusive health states: progression-free (PF), post-progression (PP) and death. Sub-states within the PF and PP health states were included to take into account whether patients were on or off primary treatment. The survival curves representing the experience of patients treated with Enco + Bini in the COLUMBUS trial [21,22,23] are used for Enco + Bini in the economic model, with parametric models fitted to the COLUMBUS trial [21,22,23] data in order to extrapolate beyond the time horizon of the trial. In the absence of direct evidence comparing Enco + Bini versus Dab + Tram, the survival curves for Enco + Bini were adjusted using HRs generated by the company’s NMAs to obtain survival curves for Dab + Tram. The company assumed that the time on treatment was the same for patients receiving Enco + Bini and Dab + Tram, and used primary time on treatment data for both treatment combinations from the Enco + Bini arm of the COLUMBUS trial [21,22,23]. Different relative dose intensity (RDI) multipliers and grade 3/4 AEs incidence rates occurring in ≥ 5% of patients were used in the company economic model for Enco + Bini (using data from the COLUMBUS trial [21,22,23]) and Dab + Tram (using data from the COMBI-v trial [24, 25] and COMBI-d [26,27,28] trial). Utility values for the PF and PP health states were derived from the company’s NMA. The PF on-treatment utility values differed by primary treatment, whilst the same utility values were used, regardless of primary treatment for PF off-treatment and PP. Resource use and costs were estimated based on information from the COLUMBUS trial [21,22,23] (usage of primary and subsequent treatments, and AE rates), published sources—including an Australian study of people with melanoma to estimate health state resource use [43], with the unit costs of the resource use based on estimates from the NHS [44, 45], estimates of AE costs [46] and terminal care costs [47]—and advice from experts in clinical practice in the NHS.
Confidential Patient Access Scheme (PAS) prices, discounted prices for the NHS, agreed with the Department of Health, were in place for Enco + Bini and for Dab + Tram at the time of this appraisal. As the company was unaware of the PAS prices for the comparator treatments, the company base-case results only included the PAS price for Enco + Bini. Using this reduced price, the results from the company’s economic model estimate that Enco + Bini dominates Dab + Tram, generating 0.453 additional QALYs at a reduced cost.
The company carried out probabilistic and deterministic sensitivity analyses. The results showed that the base-case analyses results were sensitive to the use of an estimated HR for time to treatment discontinuation (TTD) (in comparison to making TTD equal for Enco + Bini and Dab + Tram in the base case) and the dose of Dab + Tram (drug dose each time it was administered and RDI). Two scenarios in which Enco + Bini did not dominate Dab + Tram were produced by the company; one of which included discounts to the list prices of dabrafenib and trametinib, and the other assumed Enco + Bini and Dab + Tram were equally effective and safe (OS, PFS, utility values in the PF state and AE rates).
Critique of Company’s Cost-Effectiveness Evidence
The ERG considered that the design of the company model was appropriate and that it was generally well structured. In addition, the ERG was satisfied with the way in which the COLUMBUS trial [21,22,23] data were incorporated into the model.
The COLUMBUS trial [21,22,23] data were used to populate the company economic model; OS, PFS, time on treatment data, utility values and AE rates were used for Enco + Bini. The company used the numerically, but not statistically significant, results from their NMAs within the economic model to estimate OS, PFS and utility values for Dab + Tram. The ERG, however, considered it inappropriate to model any differences between the treatments for these outcomes as the numerical differences were not statistically significant. The company used the incidence rates of grade 3 and 4 AEs occurring in at least 5% of the patients from the COLUMBUS [21,22,23], COMBI-v [24, 25] and COMBI-d [26,27,28] trials, rather than the results of the NMAs. The ERG considered that this was not a robust approach as it failed to account for any differences in patient baseline characteristics across the three trials.
Based on the lack of any evidence supporting a demonstrable difference in outcomes between Enco + Bini and Dab + Tram, the ERG considered that the only parameters that could affect model results were treatment-related costs. In the company model, these were a function of time on treatment, administration costs, RDI and drug costs. The ERG was satisfied that the time on treatment estimates and the administration costs (given the same mode of delivery) for Enco + Bini and Dab + Tram were the same, as assumed in the company base case. The company employed different RDI multipliers in their estimation of treatment costs for Enco + Bini and Dab + Tram. However, as the ERG considered that there was no robust evidence to support differential AE estimates for each of the treatment options, there was equally no robust evidence to support the use of different RDI multipliers.
The ERG’s opinion was that equivalence of time on treatment, drug administration costs and RDI across treatment options meant that drug prices were the only cost difference to consider; therefore, to establish cost-effectiveness, a simple cost-minimisation analysis, rather than a cost-utility analysis, was appropriate.
Conclusions of the ERG Report
The objective of this appraisal was to compare the clinical and cost-effectiveness of Enco + Bini versus Dab + Tram for adults with advanced (unresectable or metastatic) BRAF V600 mutation-positive melanoma. As Dab + Tram was not a comparator in the COLUMBUS trial [21,22,23], the company carried out a series of NMAs to compare Enco + Bini versus Dab + Tram in terms of efficacy (PFS and OS), safety outcomes and HRQoL. The results of these NMAs showed that there was no statistically significant difference between the two treatments for any of these four outcome measures. The ERG was satisfied that there was no robust evidence of any statistically significant clinical differences between OS or PFS outcomes, utility values or AE profiles when Enco + Bini was compared with Dab + Tram. The ERG considered that the only difference between the two treatment combinations that affected model results was treatment-related costs; a cost-minimisation analysis was therefore an appropriate approach for comparing the cost-effectiveness of the two treatments. Using the ERG’s preferred scenario (equivalent OS, PFS, utility values, AEs and RDI multipliers) and PAS prices for Enco + Bini, Enco + Bini was less costly than Dab + Tram, and as estimated total QALYs were also assumed to be equal, the ERG considered that Enco + Bini was a cost-effective alternative to Dab + Tram.
Methodological Issues
The lack of direct comparative evidence between Enco + Bini and Dab + Tram resulted in the company carrying out NMAs to provide estimates for each of the key outcomes. The networks did not, however, generate estimates of effects for Enco + Bini that statistically significantly differed from estimates for Dab + Tram. The ERG considered that estimating differences between Enco + Bini versus Dab + Tram based on estimates from the NMAs in the economic model was inappropriate and, therefore, carried out a cost-minimisation analysis.
As the company assumed time on treatment to be the same for Enco + Bini and Dab + Tram, and in the ERG’s scenarios the key outcomes (OS, PFS, HRQoL and AEs) were assumed to be the same for both treatment options, the ERG considered that the proposed difference in RDI in the company model was difficult to justify. The ERG adjusted the model so that the RDI was the same for the two comparator treatments.