Amarin ICER CVD Final Evidence Report 101719
Amarin ICER CVD Final Evidence Report 101719
Amarin ICER CVD Final Evidence Report 101719
Prepared for
The Institute for Clinical and Economic Review (ICER) is an independent non-profit research
organization that evaluates medical evidence and convenes public deliberative bodies to help
stakeholders interpret and apply evidence to improve patient outcomes and control costs. Through
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largest single funder being the Laura and John Arnold Foundation. No funding for this work comes
from health insurers, pharmacy benefit managers, or life science companies. ICER receives
approximately 19% of its overall revenue from these health industry organizations to run a separate
Policy Summit program, with funding approximately equally split between insurers/PBMs and life
science companies. Life science companies relevant to this review who participate in this program
include: Janssen Pharmaceuticals, Inc. For a complete list of funders and for more information on
ICER's support, please visit http://www.icer-review.org/about/support/.
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of ICER – provides a public venue in which the evidence on the effectiveness and value of health
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patients, clinicians, insurers, and policymakers interpret and use evidence to improve the quality
and value of health care.
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and value of medical interventions. More information about the Midwest CEPAC is available at
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The economic models used in ICER reports are intended to compare the clinical outcomes, expected costs, and
cost effectiveness of different care pathways for broad groups of patients. Model results therefore represent
average findings across patients and should not be presumed to represent the clinical or cost outcomes for any
specific patient. In addition, data inputs to ICER models often come from clinical trials; patients in these trials and
provider prescribing patterns may differ in real-world practice settings.
For a complete list of stakeholders from whom we requested input, please visit:
https://icer-review.org/material/cvd-stakeholder-list/.
Expert Reviewers
Robert A. Harrington, MD
Arthur L. Bloomfield Professor of Medicine
Stanford University
No relevant conflicts of interest to disclose, defined as more than $10,000 in health care company
stock or more than $5,000 in honoraria or consultancies during the previous year from health care
manufacturers or insurers.
Patrick T. O’Gara, MD
Watkins Family Distinguished Chair in Cardiology
Brigham and Women’s Hospital
Professor of Medicine
Harvard Medical School
Dr. Patrick T. O’Gara serves as a member of the Apollo (TMVR) Executive Committee at Medtronic
and as a member of the Early TAVR Executive Committee at Edwards Life Sciences.
In addition to mortality risks and financial burden associated with CVD, major adverse
cardiovascular events can result in long-term disability and complicate care for other conditions.
For example, an analysis of linked data from the US Health and Retirement Study and Medicare
claims found significant increases in the number of functional limitations on activities of daily
living following hospitalization for MI or stroke; in addition, those hospitalized for stroke had a
fourfold increase in the odds of moderate-to-severe cognitive impairment, even after
controlling for pre-hospitalization cognition.4
The management of CVD has commonly consisted of behavioral and lifestyle changes (i.e., diet,
weight reduction, physical activity, smoking cessation) to interrupt atherosclerotic processes, as
well as risk factor management, including blood pressure control, treatment with lipid-lowering
agents such as statin medications and PCSK9 inhibitors, antiplatelet therapy, and when
necessary, management of diabetes as well as surgical or percutaneous revascularization.
Although low-dose acetylsalicylic acid (aspirin, or ASA) and statins have become cornerstone
therapies with proven benefit for patients with established CVD, this population remains at high
residual risk of cardiovascular events.5 In addition, those without documented CVD but with
established risk factors such as diabetes and comorbid hypertension or hypercholesterolemia
are also at elevated risk of major cardiovascular events. For these patients, there is clinical
interest in exploring other types of medical management in addition to the strategies.
Rivaroxaban (Xarelto®, Janssen Pharmaceuticals, Inc.) is an oral direct and selective inhibitor of
factor Xa in the blood coagulation pathway. Rivaroxaban was first approved for the prevention
of deep vein thrombosis in patients undergoing major orthopedic surgery and is commonly
used in the management of atrial fibrillation and venous thromboembolic disease. In October
2018, rivaroxaban 2.5 mg taken twice daily with aspirin received an indication for the
prevention of major cardiovascular events in patients with CAD or PAD.6
Icosapent Ethyl
Icosapent ethyl (Vascepa®, Amarin Pharma, Inc.) is a purified ethyl ester of the omega-3 fatty
acid known as eicosapentaenoic acid (EPA), which was initially approved in 2012 as an adjunct
to diet to treat severe hypertriglyceridemia (triglyceride levels ≥500 mg/dL). The manufacturer
has filed for an expanded indication for management of patients with established CVD or at high
risk of CV events. Initially, a decision from the Food and Drug Administration (FDA) was expected
by September 28, 2019,7 however an FDA advisory committee meeting has been scheduled for
November 14, 2019.8 Icosapent ethyl’s mechanism of action in cardioprotection is not fully
known.9 It is taken twice daily with food (total daily dose: 4 g).
We also heard that medication adherence might be a challenge in this population, given already
high rates of polypharmacy and comorbidity in older patients likely to be candidates for add-on
therapy. Indeed, patients expressed trepidation with an increased therapeutic burden, citing
concerns with both the daily complexity of treatment and increased financial responsibility for
ongoing treatment. Patients also mentioned that the value and risk of adding new treatments
to an already complex treatment regimen is not necessarily clearly and consistently
communicated. Indeed, prior research in this clinical area suggests that patients tend to
significantly overestimate both their event and bleeding risks relative to their quantified risk
scores.10 Other feedback included the need to tailor the physician-patient conversation to
Rivaroxaban
Compared to treatment with ASA alone, rivaroxaban + ASA reduced the composite risk of
cardiovascular death, stroke, or MI in patients with stable CVD. Patients treated with
rivaroxaban + ASA experienced significantly fewer strokes (including disabling or fatal
strokes), less cardiovascular death, and fewer cardiovascular-related hospitalizations. No
significant effect of rivaroxaban on hemorrhagic stroke or MI was observed. Patients treated
with rivaroxaban + ASA experienced a significant increase in major bleeding events, which led
to permanent discontinuation of therapy in approximately 3% of patients. Most major
bleeding events occurred in the GI tract.
Our review of rivaroxaban was primarily informed by the Phase III COMPASS trial,11 which
randomized approximately 27,000 patients to receive rivaroxaban 2.5 mg twice daily and 100
mg once daily of ASA, 5 mg twice daily of rivaroxaban alone, or 100 mg once daily of ASA alone.
The FDA-approved indication is for rivaroxaban only in combination with ASA, however; as such,
evidence from the rivaroxaban alone arm is not summarized here. Based on a planned interim
analysis, the COMPASS trial was stopped early (after a mean of 23 months of follow-up) due to
evidence of significant clinical benefit.
Clinical Benefits
The primary outcome of the COMPASS trial was a composite endpoint consisting of the first
occurrence of cardiovascular death, stroke, or MI.11 In the time to event analysis, the hazard
ratio for the primary outcome was 0.76 (95% CI: 0.66, 0.86; p<0.001). Patients treated with
rivaroxaban + ASA had statistically significantly fewer primary outcome events (4.1%) compared
Individual Events
Individual components of the primary and secondary composite outcomes are presented in
Table 3.3 in Section 3. Patients treated with rivaroxaban + ASA experienced significantly fewer
strokes, and less cardiovascular death, death from coronary heart disease, and death from any
cause. In an exploratory analysis, rivaroxaban + ASA reduced the risk of disabling or fatal
strokes (i.e., strokes defined as a score between 3 and 6 on the modified Rankin Scale) by 42%
(HR 0.58; 95% CI: 0.37 to 0.89; p=0.01).12-14 Hemorrhagic strokes occurred in more patients in
the rivaroxaban + ASA group but differences did not reach statistical significance.
Other Benefits
Hospitalization for cardiovascular causes (Appendix Table D4) occurred less in patients
randomized to rivaroxaban + ASA versus ASA alone (14.2% vs. 15.3%; HR 0.92; 95% CI: 0.86 to
1.00; p=0.04). The non-cardiovascular-related hospitalization rate was not statistically different
between arms. Although the European Quality of Life-5 Dimensions (EQ-5D) scale was
measured in the COMPASS trial, no results have been published or presented as of the
publication of this Evidence Report.
Harms
Major bleeding events occurred in significantly more patients treated with rivaroxaban + ASA
compared to ASA alone (3.1% vs. 1.9%; HR 1.70; 95% CI: 1.40 to 2.05; p<0.001); 2.7% of patients
in the rivaroxaban + ASA group permanently discontinued treatment due to bleeding, compared
to 1.2% in the ASA alone group.6,11 The most common bleeding site was the GI tract (1.5% vs.
0.7%; HR 2.15; 95% CI: 1.60 to 2.89; p<0.0001). Selected bleeding outcomes are presented in
Table ES1 and all bleeding outcomes are reported in Appendix Table D5.
Serious adverse events (SAEs) occurred in 7.9% of patients in the rivaroxaban + ASA arm versus
7.3% of patients on ASA alone; discontinuation due to non-bleeding AEs was not reported.
Our literature search did not identify any studies directly comparing rivaroxaban + ASA to DAPT
in the population of focus. Although we did not systematically review DAPT versus ASA alone,
we searched for RCTs that evaluated new initiation of DAPT (as opposed to continuation of
current DAPT therapy) in patients with stable CVD. We identified two RCTs of ticagrelor + ASA
and clopidogrel + ASA, respectively.15-18 These trials are summarized in Appendix D for context.
We also indirectly compared DAPT to rivaroxaban + ASA through an NMA of major adverse
cardiovascular events in patients with a recent MI (see below).
NMA
We performed an NMA in the subgroup of patients with a recent MI (i.e., in the two years prior
to randomization for the studies of rivaroxaban and ticagrelor, and at a median of two years
prior to randomization for the study of clopidogrel) to compare ticagrelor + ASA and clopidogrel
+ ASA with rivaroxaban + ASA. The analysis estimated the comparative risk of a composite
endpoint of cardiovascular death, stroke, or MI between each of the regimens of focus. The
results of our NMA, presented in Table ES2, do not reveal statistical differences between
therapies. However, given the elevated risk of major bleeding that is associated with each of
the regimens, any analysis of comparative effectiveness is incomplete without an accompanying
analysis of comparative safety. We endeavored to also compare the incidence of major
bleeding between therapies but were unable to quantitatively synthesize the data due to the
use of important differences in definitions of major bleeding.
Table ES2. NMA Results Comparing the Risk of Cardiovascular Death, Stroke, or MI in Patients
Treated with Antithrombotic Therapy for Stable CVD
Rivaroxaban + ASA
0.91
Ticagrelor + ASA
(0.61 to 1.36)
0.91 1.00
Clopidogrel + ASA
(0.58 to 1.40) (0.75 to 1.32)
0.70 0.77 0.77
ASA
(0.48 to 1.02) (0.66 to 0.90) (0.61 to 0.98)
Each box represents the estimated hazard ratio and 95% credible interval for the combined direct and
indirect comparisons between two drugs. Estimates in bold signify that the 95% credible interval does
not contain one.
Compared to optimal medical management alone (i.e., placebo), icosapent ethyl reduced the
risk of a composite outcome of cardiovascular death, stroke, MI, coronary revascularization, or
unstable angina in patients with established CVD or diabetes mellitus and additional risk
factors, as well as each individual component and the composite secondary outcome of
cardiovascular death, MI, or stroke. A treatment benefit was also observed in analyses of the
first, subsequent, and total major adverse cardiovascular events. Rates of serious adverse
events and events leading to treatment discontinuation were similar between arms. A greater
proportion of patients treated with icosapent ethyl experienced serious bleeding-related
disorders, as well as peripheral edema, constipation, and atrial fibrillation.
Evidence on icosapent ethyl was primarily derived from the Phase III REDUCE-IT trial,19 which
randomized patients at increased risk of ischemic events (either established CVD or primary
prevention in patients age ≥50 with diabetes and at least one additional risk factor) to 2 g twice
daily of icosapent ethyl (n=4089) or a placebo (n=4090) that contained mineral oil to resemble
the color and consistency of icosapent ethyl. Patients were required to have elevated fasting
triglyceride levels (≥135 and <500 mg/dL) and well-controlled LDL cholesterol levels (>40 and
≤100 mg/dL) while on a stable dose of statins for at least four weeks. At baseline, 71% of
patients had established CVD and 29% made up the high-risk primary prevention cohort.19
Patients were followed for a median of 4.9 years.
Clinical Benefits
As noted above, the REDUCE-IT trial evaluated a composite of cardiovascular death, MI, stroke,
coronary revascularization, or unstable angina as its primary endpoint. In the time-to-event
analysis, icosapent ethyl reduced the risk of a primary endpoint event by 25% (HR 0.75; 95% CI:
0.68 to 0.83; p<0.001).19 At a median follow-up of 4.9 years (maximum 6.2 years), 17.2% of
patients treated with icosapent ethyl and 22.0% treated with placebo had a first primary
endpoint event. The annual event rate in the placebo arm was approximately 4.4%, suggesting
a very high-risk population.
The REDUCE-IT trial’s key secondary endpoint (cardiovascular death, MI, or stroke) also occurred
in fewer patients treated with icosapent ethyl compared to those receiving placebo (11.2% vs.
14.8%, respectively; HR 0.74; 95% CI: 0.65-0.83; p<0.001).19
Icosapent ethyl reduced the risk of cardiovascular death by 20%, nonfatal MI by 30%, nonfatal
stroke by 29%, coronary revascularization by 34%, and hospitalization for unstable angina by
32%; however, a 13% reduction in all-cause mortality was not statistically significant. The effect
of icosapent ethyl on total events (first and subsequent) was examined in a pre-specified
analysis using a negative binomial regression model.20 The risk of total primary endpoint events,
Harms
The incidence of serious treatment-emergent adverse events (TEAEs) was similar in the
icosapent ethyl and placebo arms of the REDUCE-IT trial (30.6% vs. 30.7%, respectively).19
Serious TEAEs leading to death occurred in 2.3% of patients treated with icosapent ethyl and
2.5% of patients who received placebo. Serious bleeding-related disorders, identified using the
Medical Dictionary for Regulatory Activities (MedDRA), occurred in a greater proportion of
patients treated with icosapent ethyl, although the difference was not statistically significant
(2.7% vs. 2.1%, p=0.06). No fatal bleeding events occurred in either group and rates of
hemorrhagic stroke, central nervous system bleeding, and GI bleeding did not statistically differ.
TEAEs that occurred in proportionately more patients treated with icosapent ethyl included
peripheral edema (6.5% vs. 5.0%, p=0.002), constipation (5.4% vs. 3.6%, p<0.001), and atrial
fibrillation (5.3% vs. 3.9%, p=0.003).19 Hospitalization for atrial fibrillation or flutter was
significantly higher in the icosapent ethyl arm compared to placebo (3.1% vs. 2.1%; p=0.004).
Approximately 11% of patients randomized to placebo and 10% randomized to icosapent ethyl
discontinued the study early.9 The rate of TEAEs leading to discontinuation of the study drug
was similar for patients treated with icosapent ethyl and placebo (7.9% vs 8.2%, respectively) as
was the rate of drug discontinuation due to serious TEAEs (2.2% vs 2.3%, respectively).
The generalizability of the COMPASS trial population is subject to a number of uncertainties. For
one, study entry criteria of stable CAD and PAD as well as documentation of atherosclerosis in at
least two vascular beds among patients age <65 years ensured a population at high risk of
recurrent cardiovascular events, but exclusion of patients at high bleeding risk and further
exclusion of 8% patients not tolerating or adherent to run-in ASA therapy likely resulted in a
sample at reduced bleeding risk relative to the potential candidate population for
rivaroxaban.21,22 In addition, we cannot exclude the possibility that the clinical benefits
observed in COMPASS are somewhat overstated due to the trial having been stopped early for
benefit after a mean of 23 months of follow-up. 23 In addition, the decision to separately
randomize patients to receive the proton-pump inhibitor (PPI) pantoprazole or placebo within
the rivaroxaban + ASA, rivaroxaban alone, and ASA alone groups is a puzzling one, given that
clinical guidelines recommend routine use of PPIs for gastroprotection in patients receiving
combination anticoagulation + ASA therapy24 but not for anticoagulants or ASA alone.
Icosapent Ethyl
As noted previously, the placebo vehicle used in the REDUCE-IT trial (as well as earlier trials of
icosapent ethyl) contained mineral oil to mimic the viscosity of the active agent. Biomarker
changes observed in the trial raise the possibility that the mineral oil used was not biologically
inert, however; patients in the placebo arm experienced a threefold-higher percentage increase
in LDL-C at year one (10.2% vs. 3.1% for icosapent ethyl, p<0.001 for between-group difference)
and a substantial increase in the inflammation marker hsCRP at year two (32.9% vs. -13.9%,
p<0.001), adding to documented concerns regarding the mineral oil’s potential interference
with statin absorption.9 The manufacturer conducted a post-hoc analysis, the results of which
suggested a consistent risk reduction with icosapent ethyl irrespective of whether LDL-C
increased in the placebo arm.9 However, it is difficult to interpret analyses of effects utilizing
on-treatment response subgroups, and so residual concerns remain about a potentially
biologically active “placebo” and the possibility that the true effect of icosapent ethyl may be
attenuated from that observed in the REDUCE-IT trial.
We also note that the results of this trial stand apart from many prior studies of omega-3
preparations that showed little to no cardiovascular benefit.27 Indeed, when a Bayesian
approach is taken to the overall evidence base, the interpretation of REDUCE-IT’s findings will
differ depending on whether prior expectations for these results are pessimistic, realistic, or
optimistic.28 It is worth noting that reductions in cardiovascular events of approximately 20%
were observed in a prior EPA-only trial (JELIS), which randomized approximately 19,000
Japanese patients to 1.8 g of EPA in addition to statin therapy versus statins alone over a mean
of 4.6 years of follow-up.29 However, the JELIS trial was open-label and showed no reductions in
cardiovascular death, so its relevance to the results of REDUCE-IT is unclear. The JELIS trial was
also conducted in a Japanese population with a much higher baseline consumption of fish than
is typically seen in the US; very few patients in REDUCE-IT were from the Asia-Pacific region
making comparisons across trials difficult.30,31
Regardless of issues of trial design or interpretation, the greatest uncertainty may be in how
generalizable the REDUCE-IT results are and therefore what the most appropriate target
Compared to ASA alone, rivaroxaban + ASA significantly reduced the risk of cardiovascular
death, stroke, or MI in patients with stable CVD. Patients treated with rivaroxaban + ASA
experienced significantly fewer strokes (including disabling or fatal strokes), less cardiovascular
death, less all-cause mortality, fewer major adverse limb events, and fewer cardiovascular-
related hospitalizations. Bleeding events of greatest severity—i.e., fatal bleeding, symptomatic
bleeding into a critical organ, and nonfatal symptomatic intracranial hemorrhages—were not
significantly increased by adding rivaroxaban to ASA. We therefore have high certainty that
rivaroxaban + ASA provides a small-to-substantial net health benefit in patients with CAD, PAD,
or both conditions (“B+”).
We did not identify any head-to-head studies that directly compared rivaroxaban + ASA to DAPT
in patients with stable CVD. Although an indirect comparison of the risk of major adverse
cardiovascular events in patients with a recent MI suggested that DAPT may provide a similar
cardioprotective benefit to rivaroxaban + ASA, clinically significant differences in the way major
bleeding was defined in the clinical trials of focus precluded a companion analysis of relative
bleeding risks. We also note that those with a recent MI represented a relatively small subset of
patients in the COMPASS trial, so the comparative benefits and risks of these two strategies in
the remaining CAD and PAD population are unknown. We therefore have low certainty of
whether rivaroxaban + ASA provides a negative, comparable, or positive net health benefit
compared to DAPT in patients with CAD or PAD (“I”).
Icosapent ethyl reduced the risk of major adverse cardiovascular events in patients with
established CVD or diabetes mellitus and additional risk factors compared to optimal medical
management alone (i.e., placebo). The therapy was generally well-tolerated, despite a slight
increase in the incidence of major bleeding disorders. However, over 4.9 years of follow-up, no
fatal bleeding events occurred, and rates of TEAEs were comparable between the icosapent
ethyl and placebo arms. Although we are uncertain whether the use of mineral oil may have
caused some harm to the placebo group, we do not believe that this theory can account for the
entire benefit observed in the REDUCE-IT trial. We believe that the results of REDUCE-IT likely
The primary aim of this analysis was to estimate the cost effectiveness of rivaroxaban and
icosapent ethyl as additive therapies to optimal medical management in patients with
established CVD, and in the case of icosapent ethyl, also in patients without evidence of CVD but
with diabetes and at least one additional risk factor. A Markov cohort model was constructed to
compare the addition of rivaroxaban to ASA therapy to ASA alone and to compare the addition
of icosapent ethyl to optimal medical management (including statins) to optimal medical
management (including statins) alone. Rivaroxaban and icosapent ethyl were modeled
separately but shared a similar overall model structure. Patient survival, quality-adjusted
survival, and health care costs from a health care sector perspective were estimated over a
lifetime time horizon for each intervention and comparator. Costs and outcomes were
discounted at 3% per year. While the base-case analysis took a health care sector perspective,
productivity losses to the patient and caregiver were considered in a scenario analysis using a
modified societal perspective.
Individuals in the CVD cohort began on treatment and could stay in that state, pass into event
states of MI or stroke, or could die (Figure ES1). Patients who experienced a cardiovascular
event moved into post-event health states, where they may have had higher likelihood for
death as compared to the general CVD prevention population. Patients remained in the model
until they died. All patients could transition to death from all-causes from any of the alive
health states. Death could have occurred from all-cause or cardiovascular event/post-event
related morality.
Model Validation
We used several approaches to validate the model. First, we provided preliminary methods and
results to manufacturers, patient groups, and clinical experts. Based on feedback from these
groups, we refined data inputs used in the model. Second, we varied model input parameters
to evaluate face validity of changes in results. We performed model verification for model
calculations using internal reviewers. As part of ICER’s efforts to increase modeling
transparency, we also shared the model with relevant manufacturers for external verification
and feedback shortly after publishing the draft report for this review. Finally, we compared
results to other cost-effectiveness models in this therapy area.
Base-Case Results
Base-case discounted costs and outcomes from the model are listed in Table ES4 for rivaroxaban
and in Table ES5 for icosapent ethyl. Rivaroxaban was associated with approximately $17,000 in
discounted lifetime intervention costs, whereas icosapent ethyl was associated with $15,000 in
lifetime intervention costs. Average discounted life years, equal value life years gained (evLYG)
(a measure that evenly values any gains in length of life, regardless of the impact on patients’
quality of life), and QALYs were higher for both interventions as compared to optimal medical
management alone.
Table ES5. Base-Case Discounted Results for Icosapent Ethyl Compared to Optimal Medical
Management including Statins
Non-
Intervention
Treatment Intervention Total Costs Life Years evLYG QALYs
Costs
Costs
Icosapent
$15,000 $25,000 $40,000 12.26 10.21 10.19
Ethyl
Medical
$800 $30,000 $31,000 11.73 9.69 9.69
Management
evLYG: equal value of life years gained, QALY: quality-adjusted life year
Base-case discounted incremental results are shown in Table ES6, with rivaroxaban versus
optimal medical management yielding $36,000 per QALY gained. Icosapent ethyl versus optimal
medical management yields $18,000 per QALY gained. Discounted incremental life year results
were slightly lower than the incremental cost-per-QALY findings. Results for the incremental
evLYG were slightly more favorable than the cost-per-QALY findings given there is a life
extension to each therapy over medical management. The incremental cost per major adverse
cardiovascular event avoided should be interpreted with caution, given that this metric does not
have a known threshold for an understanding of value and does not include the differential
timing or the differential importance of major adverse cardiovascular events. Note that the
intervention-specific incremental findings are modeled using intervention-specific populations
and therefore should not be directly compared across treatments.
Cost per
Incr. Incr. Incr. Incr. Cost Cost per Cost per
Intervention* MACE
Costs LYs evLYG QALYs per LY evLYG QALY
Avoided
Icosapent
$17,000 $17,000 $18,000 $53,000
Ethyl vs.
$9,000 0.54 0.52 0.50 per LY per evLYG per QALY per MACE
Medical
gained gained gained avoided
Management
ICER: incremental cost-effectiveness ratio, Incr.: Incremental LY: life year, MACE: major cardiovascular event,
QALY: quality adjusted life year
*Modeled populations differed across interventions; results for the interventions are not directly comparable.
Sensitivity Analyses
To demonstrate effects of uncertainty on both costs and health outcomes, we varied input
parameters using available measures of parameter uncertainty (i.e., standard errors) or
reasonable ranges to evaluate changes in cost per additional QALY in deterministic sensitivity
analyses. Key drivers of uncertainty for both comparisons (rivaroxaban versus optimal medical
management and icosapent ethyl versus optimal medical management) included the clinical
event hazard ratios for MI, stroke, and cardiovascular death, with smaller impacts observed
from uncertainty in utility and cost inputs. In probabilistic sensitivity analyses, in which all
important parameters were varied simultaneously, 92% of iterations suggested that rivaroxaban
met the $50,000/QALY threshold. Icosapent ethyl results suggested that nearly 100% of
iterations met the $50,000/QALY threshold. Both interventions achieved 100% of iterations
meeting the $100,000/QALY and $150,000/QALY thresholds.
Threshold Analyses
Table ES8 presents the threshold results for each drug at thresholds of $50,000, $100,000, and
$150,000 per equal value life year gained (evLYG). An analysis of the evLYG is included to
complement the cost per QALY calculations and provide policymakers with a broader view of
cost effectiveness.
Our base-case results suggest that the use of rivaroxaban (plus ASA) and icosapent ethyl (in
patients receiving statins) both provide clinical benefit in terms of gains in quality-adjusted
survival and overall survival compared to optimal medical management alone in the adult,
established CVD cohort, and in the case of icosapent ethyl also for adults without known CVD
but at high risk for cardiovascular events. This translated into incremental cost-effectiveness
estimates that fell below commonly cited cost-effectiveness thresholds under the assumptions
used in this analysis. The results were relatively robust to parameter uncertainties in the one-
way and probabilistic sensitivity analyses. Further, the results were robust to a number of
scenario analyses including the modified societal perspective and others.
Our analyses had important limitations and assumptions. We assumed three-component major
adverse cardiovascular events, MI, stroke, and cardiovascular death, to form the base-case
health states within the model structure for both rivaroxaban and for icosapent ethyl. A
scenario analysis that broadened major adverse cardiovascular events to include other events
©Institute for Clinical and Economic Review, 2019 Page ES15
Additive CVD Therapies – Final Evidence Report Return to Table of Contents
suggested similar but lower cost-effectiveness findings for icosapent ethyl. An additional
limitation of this analysis was the model calibration to the observed clinical trial event rates for
optimal medical management. Many unknowns were a part of the model calibration exercise.
Finally, it is important to note that randomized controlled trial findings may not generalize or
translate to observed signals within the real world (i.e., efficacy does not equal effectiveness).
Given that the cost-effectiveness findings relied on randomized controlled trials for estimates of
clinical benefit and harm, the findings should be interpreted with caution when estimating
whether these interventions would achieve similar value for money in actual practice.
In conclusion, the findings of our analysis suggest that the additive CVD therapies of focus for
this review provide gains in quality-adjusted survival and overall survival over optimal medical
management. Assuming clinical signals within the trial hold for patients treated with these
interventions and current net prices, the base-case results suggest that costs for treatment with
either rivaroxaban or icosapent ethyl would fall below commonly cited thresholds for cost
effectiveness. The results were relatively robust to sensitivity and scenario analyses.
For rivaroxaban, price changes of approximately 4% discount to 39% over the list price (WAC)
would be required to reach the $100,000 to $150,000 per QALY threshold prices, respectively.
For icosapent ethyl, prices approximately 70% to 149% above WAC would achieve $100,000 to
$150,000 per QALY threshold prices. The cost per evLYG price range is quite similar to the cost
per QALY range for both rivaroxaban and icosapent ethyl.
As shown in Figures ES2 and ES3, despite both therapies meeting common cost-effectiveness
thresholds, only a small portion of the eligible populations could be treated with crossing the
ICER budget impact threshold of $819 million per year because so many patients are potentially
eligible. When using net prices, only approximately 6% and 4% of eligible patients could be
treated in a given year with rivaroxaban and icosapent ethyl respectively without crossing the
ICER budget impact threshold.
$8,000
$150,000 per QALY
$7,000
$6,000
WAC price
$5,000 $100,000 per QALY
Annual Price
$4,000
Net price
$2,000
$1,000
$0
0% 20% 40% 60% 80% 100%
$10,000
$8,000
$7,000
$5,000
$2,000
Net price
$1,000
$0
0% 20% 40% 60% 80% 100%
ICER is issuing an access and affordability alert for both rivaroxaban and icosapent ethyl. For
rivaroxaban, at the net price of $2,215 per year, approximately 6% of eligible patients could be
treated in a given year without crossing the ICER potential budget impact threshold of $819
million, while clinical experts at the Public Meeting stated that they would consider using
rivaroxaban in approximately 30% of eligible patients. For icosapent ethyl, at the net price of
$1,625 per year, approximately 4% of eligible patients could be treated in a given year without
crossing the ICER potential budget impact threshold of $819 million. Clinical experts at the
Public Meeting stated that they believe that the majority of eligible patients would want to be
on icosapent ethyl. The purpose of an ICER affordability and access alert is to signal to
stakeholders and policy makers that the amount of added health care costs associated with a
new service may be difficult for the health care system to absorb over the short term without
displacing other needed services or contributing to rapid growth in health care insurance costs.
Thus, there is a risk to sustainable access to high-value care for all patients if managing these
issues is not appropriately planned for.
1. Is the evidence adequate to demonstrate that the net health benefit of rivaroxaban
plus ASA is superior to that provided by ASA alone?
2. Is the evidence adequate to demonstrate that the net health benefit of rivaroxaban
plus ASA is superior to that provided by ASA as part of dual antiplatelet therapy
(DAPT) with an oral P2Y12 inhibitor (e.g., ticagrelor or clopidogrel)?
3. Is the evidence adequate to demonstrate that the net health benefit of icosapent ethyl
added to optimal medical management (including statin therapy) is superior to that
provided by optimal medical management (including statin therapy) alone?
4. Does treating patients with rivaroxaban plus ASA offer one or more of the following
potential “other benefits or disadvantages” compared to ASA alone? (Select all that
apply).
5. Does treating patients with icosapent ethyl offer one or more of the following
potential “other benefits or disadvantages” compared to optimal medical
management (including statin therapy) alone? (Select all that apply).
This intervention will significantly reduce caregiver or broader family burden. 0/11
This intervention offers a novel mechanism of action or approach that will allow 7/11
successful treatment of many patients for whom other available treatments have
failed.
This intervention will have a significant impact on improving patients’ ability to 0/11
return to work and/or their overall productivity.
There are other important benefits or disadvantages that should have an important No vote
role in judgements of the value of this intervention.
6. Are any of the following contextual considerations important in assessing the long-
term value for money of rivaroxaban plus ASA? (Select all that apply).
This intervention is intended for the care of individuals with a condition of 6/11
particularly high severity in terms of impact on length of life and/or quality of life.
This intervention is intended for the care of individuals with a condition that 6/11
represents a particularly high lifetime burden of illness.
There is significant uncertainty about the long-term risk of serious side effects of this 9/11
intervention.
There is significant uncertainty about the magnitude or durability of the long-term 9/11
benefits of this intervention.
There are additional contextual considerations that should have an important role in N/A
judgements of the value of this intervention.
7. Are any of the following contextual considerations important in assessing the long-
term value for money of icosapent ethyl? (Select all that apply).
This intervention is intended for the care of individuals with a condition of 6/11
particularly high severity in terms of impact on length of life and/or quality of life.
This intervention is intended for the care of individuals with a condition that 6/11
represents a particularly high lifetime burden of illness.
There is significant uncertainty about the long-term risk of serious side effects of this 5/11
intervention.
As described in ICER’s value assessment framework, questions on long-term value for money are
subject to a value vote when incremental cost-effectiveness ratios for the interventions of
interest are between $50,000 and $175,000 per QALY in the primary “base-case” analysis. The
base-case estimates of the cost per QALY for both rivaroxaban + ASA and icosapent ethyl are
below the lower end of this range, and therefore the treatment is deemed “high long-term
value for money” without a vote unless the CEPAC determines in its discussion that the Evidence
Report base-case analysis does not adequately reflect the most probable incremental cost-
effectiveness ratio for either treatment.
ICER’s value assessment framework also describes that the CEPAC does not take Long-Term
Value for Money votes on treatments for which the evidence is considered inadequate during
the Clinical Vote. Such is the case for rivaroxaban + ASA versus DAPT therapy. Thus, no Value
vote was taken for rivaroxaban + ASA versus DAPT therapy (e.g. clopidogrel).
Payers
Providers
3. Clinicians, when thinking about the apparent benefit of rivaroxaban in the clinical trial,
should remember that patients at high risk of bleeding were excluded.
4. Develop options to help patients navigate complex medication regimens.
5. Develop a decision algorithm and/or tool for clinicians to use in determining the most
appropriate additive therapies to consider for a given patient.
6. Ensure that any clinical guideline statements regarding rivaroxaban clearly warn against
assuming a class effect for direct oral anticoagulants.
Manufacturers
Regulators
9. The FDA, manufacturers, and the clinical research community should work to solidify a
common, single, outcomes definitions for key outcomes -- such as major bleeding -- so
clinicians and patients have the information they need to make informed decisions.
Researchers
10. Researchers should develop explicit head-to-head evidence of the comparative benefits
and risks of rivaroxaban + aspirin versus dual antiplatelet therapy in patients who have
completed an initial course of DAPT (12-30 months).
11. Researchers should conduct a real-world observational study to confirm the benefits of
icosapent ethyl.
In addition to mortality risks and financial burden associated with CVD, major adverse
cardiovascular events can result in long-term disability and complicate care for other conditions.
For example, an analysis of linked data from the US Health and Retirement Study and Medicare
claims found significant increases in the number of functional limitations on activities of daily
living following hospitalization for MI or stroke; in addition, those hospitalized for stroke had a
fourfold increase in the odds of moderate-to-severe cognitive impairment, even after
controlling for pre-hospitalization cognition.4
The management of CVD has commonly consisted of behavioral and lifestyle changes (i.e., diet,
weight reduction, physical activity, smoking cessation) to interrupt atherosclerotic processes, as
well as risk factor management, including blood pressure control, treatment with lipid-lowering
agents such as statin medications and PCSK9 inhibitors, antiplatelet therapy, and when
necessary, management of diabetes as well as surgical or percutaneous revascularization.
Although low-dose acetylsalicylic acid (aspirin, or ASA) and statins have become cornerstone
therapies with proven benefit for patients with established CVD, this population remains at high
residual risk of cardiovascular events.5 In addition, those without documented CVD but with
established risk factors such as diabetes and comorbid hypertension or hypercholesterolemia
are also at elevated risk of major cardiovascular events. For these patients, there is clinical
interest in exploring other types of medical management in addition to the strategies.
Rivaroxaban
Rivaroxaban (Xarelto®, Janssen Pharmaceuticals, Inc.) is an oral direct and selective inhibitor of
factor Xa in the blood coagulation pathway. This process also results in inhibition of
prothrombinase,6 an enzyme essential not only to hemostasis but to complex biologic processes
such as angiogenesis, cell proliferation, and inflammation; it therefore plays a role in the
development and progression of atherosclerosis, cancer, and other chronic inflammatory
diseases.34
Rivaroxaban, first approved for the prevention of deep vein thrombosis in patients undergoing
major orthopedic surgery, is commonly used in the management of atrial fibrillation and venous
thromboembolic disease. It received an indication for the prevention of major cardiovascular
events in patients with chronic CAD or PAD in October 2018, and is the latest in a line of
antithrombotic regimens that have been tested as alternatives or additions to ASA, including
vitamin K antagonists, antiplatelet therapies, and thrombin receptor antagonists.21 The
recommended dosage for prevention of cardiovascular events is 2.5 mg twice daily with or
without food, in combination with ASA (75-100 mg) once daily.6
Icosapent Ethyl
Icosapent ethyl (Vascepa®, Amarin Pharma, Inc.) is a purified ethyl ester of the omega-3 fatty
acid known as eicosapentaenoic acid (EPA), which was initially approved in 2012 as an adjunct
to diet to treat severe hypertriglyceridemia (triglyceride levels ≥500 mg/dL). Following the
completion of a Phase III trial in patients with established CVD or at high risk of cardiovascular
events,9 the manufacturer filed for an expanded indication in March of 2019, with an expected
FDA decision date of September 28, 2019.7 On August 8, 2019, the company announced that
they had received notification from the FDA that an advisory committee meeting had been
scheduled for November 14, 2019, with extension of the deadline for an FDA decision to late
December.35 At the time of publication of this report, no details are currently available
regarding the reasons for an advisory committee or specific questions or concerns posed by the
FDA.
Populations
The population of focus for the review is adults with established CVD who are currently treated
with optimal medical management. For the assessment of icosapent ethyl, we also reviewed
evidence for patients without known CVD but at high risk for cardiovascular events.
Where data were available, we examined evidence for key subgroups suggested by clinical
experts, including the following:
1. Diagnosis of diabetes mellitus
2. Diagnosis of CAD alone versus CAD and concomitant PAD (rivaroxaban only)
3. Levels of high-sensitivity C-reactive protein (hsCRP) at baseline (i.e., ≤2 mg/l or >2 mg/l)
as well as changes in hsCRP from baseline to follow-up
4. Subgroups defined by level of cardiovascular risk at baseline
5. Renal dysfunction
6. Diagnosis of heart failure
Interventions
The list of interventions was developed with input from patient organizations, clinicians,
manufacturers, and payers on which drugs to include. The full list of interventions is as follows:
1. Rivaroxaban + ASA
• Patients are assumed to also be receiving optimal medical management
2. Icosapent ethyl
• Patients are assumed to also be receiving optimal medical management
including statins
Comparators
Comparators were defined to reflect the input of clinicians and other stakeholders on treatment
strategies that would be considered relevant alternatives for the overall population of interest
or a prominent subset, as well as the comparators as defined in major clinical studies of
icosapent ethyl and rivaroxaban.
Outcomes
Timing
Evidence on intervention effectiveness were derived from studies of at least one year’s duration
and evidence on harms from studies of at least three month’s duration.
Settings
All relevant settings were considered, with a focus on outpatient management in the US.
Figure 1.1. Analytic Framework: Rivaroxaban and Icosapent Ethyl for CVD
ASA: aspirin, CV: cardiovascular, CVD: cardiovascular disease, DAPT: dual antiplatelet therapy, hsCRP: high-
sensitivity C-reactive protein, LDL-C: low-density lipoprotein cholesterol, OMM: optimal medical management,
TEAE: treatment-emergent adverse event, TG: triglyceride
*For the assessment of icosapent ethyl, we will also review evidence for patients without known CVD but at
high risk for CV events.
The diagram begins with the population of interest on the left. Actions, such as treatment, are
depicted with solid arrows which link the population to outcomes. For example, a treatment may
be associated with specific clinical or health outcomes. Outcomes are listed in the shaded boxes:
those within the rounded boxes are intermediate outcomes (e.g., change in blood pressure), and
those within the squared-off boxes are key measures of clinical benefit (e.g., health-related
quality of life). The key measures of clinical benefit are linked to intermediate outcomes via a
dashed line, as the relationship between these two types of outcomes may not always be
validated. Curved arrows lead to the AEs of an action (typically treatment), which are listed
within the blue ellipsis.1
Modified ISTH major bleeding (used in COMPASS trial of rivaroxaban): Fatal bleeding,
symptomatic bleeding into a critical organ, bleeding into a surgical site requiring
reoperation, and bleeding that led to a visit to an acute care facility with or without an
overnight stay.21
Global Utilization of Streptokinase and Tissue Plasminogen Activator for Occluded Coronary
Arteries (GUSTO) severe bleeding: Fatal bleeding events, intracranial hemorrhages, or bleeding
that causes hemodynamic compromise requiring blood or fluid replacement, inotropic support,
or surgical intervention.17
Rankin Scale: A 6-point scale used to measure disability in individuals who have suffered a
stroke or other cause of neurologic disability. Scores range from 0, indicating no symptoms or
disability, to 6, indicating death; a score of 3 represents moderate disability.12-14
Ischemic stroke: Occurs when a blood vessel supplying blood to the brain becomes
obstructed.37
Hemorrhagic stroke: Occurs when a blood vessel in the brain leaks or ruptures.37
We were unable to identify any NCDs or LCDs relating to the use of any of these therapies.38 A
summary of our other findings is as follows:
Rivaroxaban
Rivaroxaban is listed as “preferred” on the preferred drug list of both surveyed Medicaid
plans.38,39 Minnesota based payer, HealthPartners, lists rivaroxaban as a tier three drug on its
standard private plan and BCBSKC lists it as a tier-two drug—neither require prior
authorization.39,40 Aetna and Cigna’s standard national plans both list rivaroxaban as a preferred
brand on their respective drug lists.41,42 It is also a preferred brand on Aetna’s standard
Medicare plan.43
Clopidogrel, a generic anti-platelet agent, and ticagrelor, a brand anti-platelet agent, are the
preferred generic and preferred brand drugs respectively on both surveyed Medicaid plans.38
As the generic option, clopidogrel is consistently a tier one or preferred generic drug, while
ticagrelor is a tier two or three drug, or the preferred brand drug, on all surveyed private plans,
both regional and national, and on Aetna’s standard Medicare plan. None of these plans listed
any prior authorization criteria for either drug, although members are alerted that they may pay
more for the brand drug should they forego the generic.39-43
Icosapent ethyl is listed as “non-preferred” on the preferred drug list of both surveyed Medicaid
plans.38 HealthPartners lists icosapent ethyl as a “non-formulary” drug on its standard private
plan, explaining that depending on an individual’s plan this medication is either not covered, or
covered at a higher out-of-pocket cost. If it is covered, it requires a prior authorization stating:
“reserved for patients with an inadequate response to two or more preferred products, such as
generic Lovaza, gemfibrozil, and fenofibrate.”39
BCBSKC lists icosapent ethyl as a tier-two drug but requires no prior authorization.40 Cigna’s
standard national plans lists it as a tier-three, non-preferred brand drug.42 Aetna’s standard
national plan lists icosapent ethyl on its preferred brand drug list, with no additional
information41, but it’s standard Medicare plan lists it as a non-preferred brand.43
American Heart Association (AHA) and the American College of Cardiology Foundation (ACCF)
The AHA/ACCF guidelines for secondary prevention in patients with coronary or other
atherosclerotic vascular disease state that all patients with CAD should take daily ASA unless
contraindicated. DAPT (which refers to ASA plus a PY212 inhibitor such as clopidogrel and
ticagrelor) is recommended for patients after acute coronary syndrome (ACS) and for patients
with symptomatic PAD. The guidelines also state that DAPT may be considered in patients with
stable CAD.44
In 2016, AHA/ACCF published a focused update on guidelines for the use and duration DAPT.
The guidelines state that for patients with ACS, regardless of whether or not they have been
treated with revascularization or fibrinolytic therapy, DAPT therapy should continue for no
fewer than 12 months and if is well tolerated without bleeding complications, it may be
reasonable to continue DAPT for longer than 12 months. For patients with non-ST elevation ACS
treated with medical therapy alone, and in patients with ACS treated with DAPT after coronary
stent implantation, the guidelines state it is reasonable to prefer ticagrelor to clopidogrel for
P2Y12 maintenance therapy.45
The AHA/ACCF guidelines for secondary prevention in patients with CAD note that “it may be
reasonable” to recommend omega-3 fatty acids from fish oil or capsules to patients whose non-
HDL cholesterol levels remain elevated despite appropriate statin therapy. They also note that
omega-3 fatty acids from fish oil or capsules may be used to reduce the risk of CVD in all
patients.44
In August of 2019, the American Heart Association released a “Science Advisory” stating that
four grams per day of prescription omega-3 fatty acids (EPA+DHA or EPA-only) is effective
therapy for reducing triglycerides, either as monotherapy or in conjunction with lipid-lowering
agents. The advisory noted that, in contrast to other cited perspectives, the EPA+DHA
formulation only raises low-density (LDL) lipoprotein in the setting of very high triglycerides
(≥500 mg/dL). The advisory also counseled against patients self-treating with fish oil
supplements not approved by the FDA.46
The ADA’s Standards of Medical Care in Diabetes guidelines recommend that all patients with
diabetes and a history of atherosclerotic CVD take ASA as part of their secondary prevention
strategy. They also state that DAPT is reasonable for a year after ACS.
The guidelines were also recently updated to include the recommendation that icosapent ethyl
be considered in patients with diabetes and atherosclerotic CVD, or other cardiac risk factors,
who have controlled low-density lipoprotein (LDL) cholesterol on a statin, but whose
triglycerides remain elevated.47
The ESC’s 2013 Guidelines on the Management of Stable Coronary Artery Disease recommend
low dose ASA for all patients with established CAD. These guidelines also note that N-3
polyunsaturated fatty acids, consumed mainly through fish oil, could have potential benefit on
cardiac risk factors, but trial results have shown mixed results for reducing cardiovascular
events.48
In 2017, the ESC released a focused update on guidelines for DAPT stating that for patients with
stable CAD, there is no indication for DAPT (unless overridden by a concomitant or prior
indication). For patients with ACS who have been treated with percutaneous coronary
intervention (PCI) or who are managed with medical therapy alone, DAPT is recommended to
continue for 12 months. If the patient is at high risk for bleeding, DAPT is recommended for six
months.49
In 2019, the ESC released an updated guideline that incorporated results from the REDUCE-IT
trial. The update recommends that treatment with omega-3 fatty acids, including icosapent
ethyl 2 g twice daily, in combination with statins should be considered for high-risk patients with
triglycerides between 135 and 499 mg/dL.50
3.2 Methods
Procedures for the systematic literature review assessing the evidence on additive therapies for
CVD followed established best research methods.51,52 We conducted the review in accordance
with the Preferred Reporting Items for Systematic Reviews and Meta-Analyses (PRISMA)
guidelines.53 The PRISMA guidelines include a checklist of 27 items, which are described further
in Appendix Table A1.
To supplement the database searches, we performed manual checks of the reference lists of
included trials and systematic reviews and invited key stakeholders to share references germane
to the scope of this project. We also supplemented our review of published studies with data
from conference proceedings, regulatory documents, information submitted by manufacturers,
and other grey literature when the evidence met ICER standards (for more information, see
http://icer-review.org/methodology/icers-methods/icer-value-assessment-framework/grey-
literature-policy/).
Subsequent to the literature search and removal of duplicate citations, references went through
two levels of screening at both the abstract and full-text levels. Two reviewers independently
screened the titles and abstracts of all publications identified using DistillerSR (Evidence
Partners, Ottawa, Canada); a third reviewer worked with the initial two reviewers to resolve any
issues of disagreement through consensus.
Citations accepted during abstract-level screening were reviewed as full text. The review
followed the same procedures as the title/abstract screening. Reasons for exclusion were
categorized according to the PICOTS elements.
Two reviewers extracted key information from the full set of accepted studies (See Appendix D).
Elements included a description of patient populations, sample size, duration of follow-up, study
design features (e.g., double-blind), interventions (agent, dosage, dosing frequency, method of
administration), results, and quality assessment for each study. Extracted data were reviewed
for logic and were validated by a third investigator for additional quality assurance.
We used criteria employed by the US Preventive Services Task Force ([USPSTF], see Appendix D)
to assess the quality of clinical trials and comparative cohort studies, using the categories
“good,” “fair,” or “poor.”54
We used the ICER Evidence Rating Matrix to evaluate the level of certainty in the available
evidence of a net health benefit for rivaroxaban + ASA and icosapent ethyl relative to the
comparators of focus.55
Assessment of Bias
As part of our quality assessment, we evaluated the evidence base for the presence of potential
publication bias. Given the emerging nature of the evidence base for newer treatments, we
performed an assessment of publication bias for rivaroxaban + ASA and icosapent ethyl using
the ClinicalTrials.gov database of trials. We scanned the site to identify studies completed more
than two years ago that would have met our inclusion criteria and for which no findings have
been published. Any such studies may indicate whether there is bias in the published literature.
For this review, we did not find evidence of any study completed more than two years ago that
has not subsequently been published.
Data on relevant outcomes were abstracted into evidence tables (see Appendix Tables D1-D15)
and are described in the text below. Data informing the comparison of rivaroxaban + ASA to
DAPT were also synthesized quantitatively in a network meta-analysis (NMA) with a focus on
prevention of cardiovascular events. The NMA included data from the subgroup of patients
with a MI within two years of randomization. An NMA extends pairwise meta-analyses by
simultaneously combining both the direct estimates (i.e., estimates obtained from head-to-head
comparisons) and indirect estimates (i.e., estimates obtained from common comparator[s]).
The NMA was conducted in a Bayesian framework with fixed effects on the treatment
parameter using the gemtc package in R.56 A fixed effects approach was taken given the small
size of the evidence network (i.e., single-study connections throughout). The log hazard ratios
for the composite outcome of cardiovascular death, stroke, or MI were analyzed using a normal
likelihood and identity link. Inputs used for the analysis are reported in Appendix Table D9.
Tabular results are presented for the treatment effects (hazard ratio) of each intervention
versus ASA along with 95% credible intervals (95% CrI) in Section 3.3. Note that we attempted
an NMA specification for major bleeding events, but differences in definitions of this outcome
across relevant clinical trials precluded such an analysis.
3.3 Results
Study Selection
Our literature search identified 808 potentially relevant references, of which 10 met the full
PICOTS criteria (Appendix A, Figure A1). The primary reasons for exclusion included study
population outside of our scope (e.g., acute coronary syndromes), dosing or combination
therapy outside of the FDA-labeled indication (e.g., >2.5 mg BID of rivaroxaban, rivaroxaban +
DAPT), and lack of outcomes of interest (e.g., studies that only reported on changes in
laboratory parameters).
Although we did not systematically review the available literature on DAPT, we searched for
RCTs that evaluated the initiation of DAPT with ticagrelor or clopidogrel in combination with
ASA. We selected two DAPT initiation trials in patients with established CVD for inclusion in an
NMA of cardiovascular outcomes. Results of the NMA are presented in the sections that follow;
evidence from four references related to the two DAPT RCTS are additionally summarized for
context in Appendix D.
We rated the two key studies of rivaroxaban and icosapent ethyl, respectively, to be of good
quality using criteria from the USPSTF (Appendix D). The trials had adequate blinding of
patients, investigators, and outcome assessors. The groups were comparable at baseline and
there was non-differential follow-up.
Our review of rivaroxaban was primarily informed by the Phase III COMPASS trial.11 Patients
were eligible to participate in the trial if they had CAD, PAD, or both. Patients with CAD under
the age of 65 were also required to have documented atherosclerosis in at least two vascular
beds or to have at least two additional risk factors (e.g., diabetes mellitus, heart failure). Key
exclusion criteria included a high bleeding risk, recent stroke, severe heart failure, advanced
kidney disease, and the use of other antithrombotic therapies. Additional inclusion and
exclusion criteria can be found in Appendix Table D2.
Eligible patients (n=28,275) first entered a 30-day run-in period during which they received 100
mg of ASA once daily in combination with placebo twice daily; 8.2% (2,320) of patients were
excluded after the run-in phase, with 729 withdrawing consent and 1,645 citing adherence
concerns. Patients who recently underwent coronary artery bypass graft (CABG) (n=1,448),
were exempt from the run-in phase and randomized within four to 14 days of the procedure.
Following the run-in, patients who adhered to therapy and who did not have any AEs were
randomized 1:1:1 to combination therapy with rivaroxaban 2.5 mg twice daily and 100 mg once
daily of ASA (n=9,152), 100 mg once daily of ASA alone (n=9,126), or 5 mg twice daily of
rivaroxaban alone (n=9,117); in a second randomization, the COMPASS trial also compared
pantoprazole, a proton-pump inhibitor (PPI), to placebo to assess upper gastrointestinal (GI)
complications.61 Pantoprazole randomization occurred equally across the rivaroxaban + ASA,
rivaroxaban alone, and ASA alone treatment groups. As rivaroxaban was only approved in
combination with ASA for patients with CAD or PAD, evidence pertaining to the rivaroxaban
alone arm of COMPASS was not summarized in this review.
At baseline, 91% of patients had documented CAD and 27% had a history of PAD. 11
Approximately 62% of patients had a prior MI, 4% had a previous stroke, 38% had diabetes
mellitus, and 22% had heart failure. Patients were on a number of other background
medications, including angiotensin-converting enzymes and angiotensin-receptor blockers
(71%), beta-blockers (70%), and lipid-lowering agents (90%). Based on a planned interim
analysis, the COMPASS trial was stopped early (after a mean of 23 months of follow-up) due to
evidence of significant clinical benefit. Key characteristics of the COMPASS trial are summarized
in Table 3.1 below.
The COMPASS trial’s primary endpoint was a composite of cardiovascular death, stroke, or MI;
major bleeding, which was defined using modified criteria from ISTH, was a key safety outcome.
Additional secondary and tertiary outcomes included individual components of the primary
composite endpoint, acute limb ischemia, hospitalization, revascularization, and limb
amputation.
Summary: Compared to treatment with ASA alone, rivaroxaban + ASA reduced the risk of
cardiovascular death, stroke, or MI in patients with stable CVD. Patients treated with
rivaroxaban + ASA experienced significantly fewer strokes (including disabling or fatal
strokes), less cardiovascular death, and fewer cardiovascular-related hospitalizations. No
significant effect of rivaroxaban on hemorrhagic stroke or MI was observed.
As noted above, the primary outcome of the COMPASS trial was a composite endpoint
consisting of the first occurrence of cardiovascular death, stroke, or MI.11 In the time to event
analysis, the hazard ratio for the primary outcome was 0.76 (95% CI: 0.66, 0.86; p<0.001;
number needed to treat [NNT]: 77). Patients treated with rivaroxaban + ASA had statistically
significantly fewer primary outcome events (4.1%) compared to patients in the ASA alone group
(5.4%); for the ASA alone group, this translates into an annual event rate of approximately 3%,
suggesting a relatively high-risk population. As mentioned above, these results led the
independent data and safety monitoring board to recommend early termination of the trial
after the first formal interim analysis (50% of planned events) for efficacy.
Individual Events
Individual components of the primary and secondary composite outcomes are presented in
Table 3.3. Patients treated with rivaroxaban + ASA experienced significantly fewer strokes, and
less cardiovascular death, death from coronary heart disease, and death from any cause. In an
exploratory analysis, rivaroxaban + ASA reduced the risk of disabling or fatal strokes (i.e., strokes
defined as a score between 3 and 6 on the modified Rankin Scale) by 42% (HR 0.58; 95% CI: 0.37
to 0.89; p=0.01).12-14 Hemorrhagic strokes occurred in more patients in the rivaroxaban + ASA
group but differences did not reach statistical significance.
Hospitalization
Hospitalization for cardiovascular causes (Appendix Table D4) occurred less in patients
randomized to rivaroxaban + ASA versus ASA alone (14.2% vs. 15.3%; HR 0.92; 95% CI: 0.86 to
1.00; p=0.04). The non-cardiovascular-related hospitalization rate was not statistically different
between arms.
Quality of Life
We did not identify any evidence related to quality of life for rivaroxaban + ASA, although the
European Quality of Life-5 Dimensions (EQ-5D) was implemented as a tertiary outcome in the
COMPASS trial. As of the time of this report, these data have not been published or presented
publicly.
Harms of Rivaroxaban
Summary: Patients treated with rivaroxaban + ASA experienced a significant increase in major
bleeding events, which led to permanent discontinuation of therapy in approximately 3% of
patients. Most major bleeding events occurred in the GI tract; proton pump inhibitor therapy
(PPI) had a protective effect on gastroduodenal bleeding (although not upper GI bleeding),
which was not statistically different between patients randomized to rivaroxaban + ASA and
ASA alone.
The COMPASS trial’s primary safety endpoint was major bleeding, which was assessed using a
modified definition from ISTH. The modified ISTH criteria included fatal bleeding, symptomatic
bleeding into a critical organ, bleeding into a surgical site requiring reoperation, or bleeding
leading to hospitalization (or an acute care visit that did not require an overnight stay); bleeding
events that did not meet the ISTH criteria were counted as minor. The most severe bleeding
event was recorded among patients with more than one event; the rate of total bleeding events
was not reported.
Major bleeding events occurred in significantly more patients treated with rivaroxaban + ASA
compared to ASA alone (3.1% vs. 1.9%; HR 1.70; 95% CI: 1.40 to 2.05; p<0.001); 2.7% of patients
in the rivaroxaban + ASA group permanently discontinued treatment due to bleeding, compared
to 1.2% in the ASA alone group.6,11 Selected bleeding outcomes are presented in Table 3.4 and
all bleeding outcomes are reported in Appendix Table D5.
The most common bleeding site was the GI tract (1.5% vs. 0.7%; HR 2.15; 95% CI: 1.60 to 2.89;
p<0.0001). As previously noted, the COMPASS trial evaluated whether the addition of a PPI,
pantoprazole (40 mg once daily), could reduce the risk of upper GI bleeding.61 Clinically
significant upper GI bleeding was defined as a composite of overt bleeding (i.e., hematemesis
and/or melena) with a gastroduodenal lesion (peptic ulcer or neoplasia), overt upper GI
bleeding of unknown origin, occult bleeding (drop in hemoglobin of 2 g per deciliter or more),
symptomatic gastroduodenal ulcer with at least three days of GI pain, or at least five
gastroduodenal erosions with at least three days of GI pain, and upper GI obstruction or
perforation. Statistical differences in the occurrence of clinically significant upper GI bleeding
were not observed between the pantoprazole and placebo arms on the composite bleeding
endpoint, although pantoprazole did reduce the risk of gastroduodenal bleeding events (0.2%
vs. 0.4% for the pantoprazole and placebo groups, respectively; HR 0.52; 95% CI: 0.28 to 0.94).
There was no statistically significant interaction between pantoprazole and randomization to
rivaroxaban + ASA or ASA alone. Additional results from this study are reported in Appendix
Table D6.
Serious adverse events (SAEs) occurred in 7.9% of patients in the rivaroxaban + ASA arm versus
7.3% of patients on ASA alone; discontinuation due to non-bleeding AEs was not reported. The
FDA label for rivaroxaban carries a black box warning for premature discontinuation and
spinal/epidural hematoma.6 The warning states that discontinuing any oral anticoagulant,
including rivaroxaban, increases the risk of thrombotic events. Patients who are receiving
neuraxial anesthesia or are undergoing spinal puncture are at increased risk of epidural or spinal
hematomas, which may result in long-term paralysis. Data related to these warnings were not
reported in the COMPASS trial. The FDA label also includes a warning for serious and fatal
bleeding, and advises that an agent to reverse the anti-factor Xa activity of rivaroxaban is
available.
To evaluate the balance or benefits and bleeding risk, COMPASS trial investigators assessed a
net-clinical-benefit outcome, which they defined as cardiovascular death, stroke, MI, fatal
bleeding, or symptomatic bleeding into a critical organ. The risk of this composite outcome was
lower with rivaroxaban + ASA than with ASA alone (HR 0.80; 95% CI: 0.70 to 0.91; p<0.001).11
Subgroup Analyses
Summary: Subgroup analyses in patients with CAD, PAD, renal dysfunction, mild-to-moderate
heart failure, recent CABG surgery, and in patients with high-risk features demonstrated a
consistent benefit for rivaroxaban + ASA as well as a consistently elevated risk of major
bleeding. In patients with PAD, rivaroxaban + ASA reduced the risk of major adverse limb
events, including major amputations.
Patients with CAD comprised 91% of the COMPASS trial and patients with PAD represented 27%
of the trial population; rivaroxaban + ASA reduced the risk of major adverse cardiac events and
increased the risk of bleeding in both subgroups.
In patients with PAD, rivaroxaban + ASA significantly lowered the risk of major adverse limb
events, defined as the development of acute or chronic limb ischemia during trial follow-up (HR
0.54; 95% CI: 0.35 to 0.84; p=0.0054).57,59 Rivaroxaban + ASA also reduced the risk of major
amputations by approximately 70% (HR 0.30; 95% CI: 0.11 to 0.80; p=0.011).
Renal Function
Patients with mild or moderate heart failure represented 22% of the COMPASS trial’s
population; patients with severe heart failure (i.e. left ventricular ejection fraction <30% or New
York Heart Association Class III or IV symptoms) were not eligible to participate. In prespecified
subgroup analyses in patients with and without a diagnosis of heart failure, rivaroxaban + ASA
significantly reduced the risk of the composite primary endpoint of cardiovascular death, stroke,
or MI (Table 3.7; p=0.28 for interaction).62 Rivaroxaban + ASA reduced the risk of death from
any cause compared to ASA alone (HR 0.66; 95% CI: 0.50 to 0.86) in patients with heart failure
but statistical differences were not observed in patients who did not have a history of heart
failure (p-value for interaction=0.05). The risk of major bleeding was increased in both
subgroups treated with rivaroxaban + ASA.
Table 3.7. Clinical Benefit and Safety of Rivaroxaban Subgroups Defined by Diagnosis of Heart
Failure62
Overall COMPASS Mild to Moderate
No Heart Failure
Population Heart Failure
HR (95% CI) HR (95% CI) HR (95% CI)
Primary 0.76
CV death, stroke, or MI 0.79 (0.68-0.93) 0.68 (0.53-0.86)
Endpoint (0.66-0.86)
Fatal bleeding,
symptomatic bleeding into
a critical organ, bleeding
Major 1.70
into a surgical site 1.79 (1.45-2.21) 1.36 (0.88-2.09)
Bleeding (1.40-2.05)
requiring reoperation, and
bleeding that led to a
hospital visit
ALI: acute limb ischemia, ASA: aspirin, CHD: coronary heart disease, CI: confidence interval, CV: cardiovascular,
HR: hazard ratio, MI: myocardial infarction
Additional subgroup analyses focusing on patients randomized following CABG surgery or those
with one or more high-risk features such as diabetes, ≥2 vascular beds affected, and renal
insufficiency, suggest treatment effects that are similar to or greater than those in the overall
population.64,65
Our literature search did not identify any studies directly comparing rivaroxaban + ASA to DAPT
in the population of focus. Although we did not systematically review DAPT versus ASA alone,
we searched for RCTs that evaluated new initiation of DAPT (as opposed to continuation of
current DAPT therapy) in patients with stable CVD. We identified two RCTs of ticagrelor + ASA
and clopidogrel + ASA, respectively.15-18 These trials are summarized in Appendix D for context.
We also indirectly compared DAPT to rivaroxaban + ASA through an NMA of major adverse
cardiovascular events in patients with a recent MI (see below).
NMA
We performed an NMA in the subgroup of patients with a recent MI (i.e., in the two years prior
to randomization for the studies of rivaroxaban and ticagrelor, and at a median of two years
prior to randomization for the study of clopidogrel) to compare ticagrelor + ASA and clopidogrel
+ ASA with rivaroxaban + ASA. The analysis estimated the comparative risk of a composite
endpoint of cardiovascular death, stroke, or MI between each of the regimens of focus. The
results of our NMA, presented in Table 3.8, do not reveal statistical differences between
therapies. However, given the elevated risk of major bleeding that is associated with each of
the regimens, any analysis of comparative effectiveness is incomplete without an accompanying
analysis of comparative safety. We endeavored to also compare the incidence of major
bleeding between therapies but were unable to quantitatively synthesize the data due to the
use of important differences in definitions of major bleeding. Data informing the NMA as well
as a network diagram are reported in Appendix D.
Rivaroxaban + ASA
0.91
Ticagrelor + ASA
(0.61 to 1.36)
0.91 1.00
Clopidogrel + ASA
(0.58 to 1.40) (0.75 to 1.32)
0.70 0.77 0.77
ASA
(0.48 to 1.02) (0.66 to 0.90) (0.61 to 0.98)
Each box represents the estimated hazard ratio and 95% credible interval for the combined direct and
indirect comparisons between two drugs. Estimates in bold signify that the 95% credible interval does
not contain one.
Evidence on icosapent ethyl was primarily derived from the REDUCE-IT trial.19 REDUCE-IT was a
multinational, double-blind, Phase III trial that randomized patients at increased risk of ischemic
events to 2 g twice daily of icosapent ethyl (n=4089) or a placebo (n=4090) that contained
mineral oil to resemble the color and consistency of icosapent ethyl. Patients were eligible to
enroll in the trial if they were at least 45 years of age with established CVD (secondary
prevention cohort) or at least 50 years of age with diabetes mellitus and at least one additional
risk factor for CVD (primary prevention cohort). Patients were required to have elevated fasting
triglyceride levels (≥135 and <500 mg/dL) and well-controlled LDL cholesterol levels (>40 and
≤100 mg/dL) while on a stable dose of statins for at least four weeks. Key exclusion criteria
included severe heart failure, severe liver disease, planned coronary intervention, glycated
hemoglobin >10%, acute or chronic pancreatitis, or known hypersensitivity to fish or shellfish.
Additional inclusion and exclusion criteria can be found in Appendix Table D11.
At baseline, 71% of patients had established CVD and 29% made up the high-risk primary
prevention cohort.19 Approximately 58% of included patients had type 2 diabetes mellitus, 87%
had hypertension, and 48% had a prior MI. Most patients (93%) were receiving moderate-to-
high intensity statin therapy. Patients were followed for a median of 4.9 years. Additional
baseline characteristics are reported in Appendix Table D12.
The primary endpoint of the REDUCE-IT trial was a composite of cardiovascular death, nonfatal
MI, nonfatal stroke, coronary revascularization, and unstable angina in a time-to-event analysis.
Per suggestions from the FDA, a protocol amendment in 2016 designated a composite of
cardiovascular death, nonfatal MI, and nonfatal stroke as a key secondary endpoint. Additional
endpoints included time-to-event analyses of the individual components of the composite
endpoints as well as all-cause mortality. The effect of icosapent ethyl on total events (first plus
subsequent) was examined in prespecified analyses for both the primary and key secondary
composite endpoints.20
Summary: Compared to optimal medical management alone (i.e., placebo), icosapent ethyl
reduced the risk of a composite outcome of cardiovascular death, stroke, MI, coronary
revascularization, or unstable angina in patients with established CVD or diabetes mellitus
and additional risk factors. Icosapent ethyl significantly reduced the risk of all individual
components of the primary composite endpoint as well as the composite secondary outcome
of cardiovascular death, MI, or stroke. A treatment benefit was also observed in analyses of
the first, subsequent, and total major adverse cardiovascular events.
As noted above, the REDUCE-IT trial evaluated a composite of cardiovascular death, MI, stroke,
coronary revascularization, or unstable angina as its primary endpoint. In the time-to-event
analysis, icosapent ethyl reduced the risk of a primary endpoint event by 25% (HR 0.75; 95% CI:
0.68 to 0.83; p<0.001).19 At a median follow-up of 4.9 years (maximum 6.2 years), 17.2% of
patients treated with icosapent ethyl and 22.0% treated with placebo had a first primary
endpoint event (number needed to treat [NNT]: 21; 95% CI: 15 to 33). The annual event rate in
the placebo arm was approximately 4.4%, suggesting a very high-risk population.
The REDUCE-IT trial’s key secondary endpoint (cardiovascular death, MI, or stroke) also occurred
in fewer patients treated with icosapent ethyl compared to those receiving placebo (11.2% vs.
14.8%, respectively; HR 0.74; 95% CI: 0.65-0.83; p<0.001; NNT: 28; 95% CI: 20 to 47).19
Individual Events
Individual components of the primary composite endpoint are presented in Table 3.10.
Icosapent ethyl significantly reduced the risk of cardiovascular death by 20%, nonfatal MI by
Total Events
The effect of icosapent ethyl on total events (first and subsequent) was examined in a pre-
specified analysis using a negative binomial regression model.20 A hierarchical approach was
used for event identification, in which a cardiovascular death superseded nonfatal events
occurring on the same day, and multiple nonfatal events occurring on the same day were
counted as one event.
The risk of total primary endpoint events, including cardiovascular death, MI, stroke,
revascularization, and unstable angina, was reduced by 30% with icosapent ethyl compared to
placebo (rate ratio (RR): 0.70; 95% CI: 0.62, 0.78). Treatment with icosapent ethyl resulted in a
28% risk reduction compared to placebo (RR: 0.72; 95% CI: 0.63-0.82) on the REDUCE-IT trial’s
key secondary endpoint of cardiovascular death, stroke, or MI.
In a prespecified supportive analysis, hazard ratios for the time to first, second, and third events
were calculated using the Wei-Lin-Weissfeld method, and the rate ratio for fourth or
subsequent events was calculated using the negative binomial regression model. Icosapent
ethyl reduced the risk of first primary endpoint events by 25%, second primary endpoint events
by 32%, third primary endpoint events by 31%, and fourth or subsequent primary endpoint
events by 48%; in contrast, the hazard ratios for secondary endpoint events remained relatively
consistent across the event sequence (Table 3.11).20
Summary: Rates of serious TEAEs were similar in patients treated with icosapent ethyl and
placebo. A greater proportion of patients treated with icosapent ethyl experienced serious
bleeding-related disorders, as well as peripheral edema, constipation, and atrial fibrillation.
The incidence of serious and non-serious TEAEs leading to treatment discontinuation was
similar for both treatment arms.
The incidence of serious TEAEs was similar in the icosapent ethyl and placebo arms of the
REDUCE-IT trial (30.6% vs. 30.7%, respectively).19 Serious TEAEs leading to death occurred in
2.3% of patients treated with icosapent ethyl and 2.5% of patients who received placebo.
Serious bleeding-related disorders, identified using the Medical Dictionary for Regulatory
Activities (MedDRA), occurred in a greater proportion of patients treated with icosapent ethyl,
although the difference was not statistically significant (2.7% vs. 2.1%, p=0.06). No fatal
bleeding events occurred in either group and rates of hemorrhagic stroke, central nervous
system bleeding, and GI bleeding did not statistically differ. TEAEs that occurred in
proportionately more patients treated with icosapent ethyl included peripheral edema (6.5% vs.
5.0%, p=0.002), constipation (5.4% vs. 3.6%, p<0.001), and atrial fibrillation (5.3% vs. 3.9%,
p=0.003).19 Hospitalization for atrial fibrillation or flutter was significantly higher in the
icosapent ethyl arm compared to placebo (3.1% vs. 2.1%; p=0.004).
Approximately 11% of patients randomized to placebo and 10% randomized to icosapent ethyl
discontinued the study early.9 The rate of TEAEs leading to discontinuation of the study drug
was similar for patients treated with icosapent ethyl and placebo (7.9% vs 8.2%, respectively) as
was the rate of drug discontinuation due to serious TEAEs (2.2% vs 2.3%, respectively). The rate
of all-cause study drug discontinuation was not reported for the entire trial population but was
reported for patients who had a primary endpoint event. At the time of a first primary endpoint
event, 18.7% of patients randomized to icosapent ethyl and 18.2% of patients randomized to
placebo had discontinued the study drug.20
Subgroup Analyses
Summary: Analyses of the primary and key secondary endpoints from the REDUCE-IT trial did
not reach statistical significance in the primary prevention subgroup. A consistent treatment
benefit was observed for icosapent ethyl in subgroups of patients with and without diabetes
mellitus, with and without renal dysfunction, with and without elevated triglyceride levels,
and with and without elevated levels of the inflammation marker hsCRP.
The effect of icosapent ethyl on the risk of primary and key secondary composite endpoint
events were reported for various subgroups of interest (Table 3.12). For patients with
established CVD at baseline (secondary prevention cohort), icosapent ethyl statistically-
significantly reduced the risk of the composite primary endpoint of cardiovascular death, MI,
stroke, revascularization, or unstable angina by 27%. The risk of the key secondary composite
endpoint, cardiovascular death, MI, or stroke, was reduced 28% with icosapent ethyl in the
secondary prevention cohort (Table 3.12).9 For patients in the primary prevention cohort, there
were no statistically significant risk reductions for either the primary or key secondary
composite endpoints (Table 3.12). At a prespecified alpha level of 0.15, there was evidence of a
significant differential effect between the secondary and primary prevention subgroups on the
primary composite endpoint (p-value for interaction=0.14) but not the secondary composite
endpoint.
A consistent treatment benefit was observed for both the primary and key secondary composite
endpoints in subgroups with and without diabetes mellitus, with and without renal dysfunction
(eGFR<60 vs. ≥60 mL/min/1.732), with and without elevated triglyceride levels (≥150 vs. <150
mg/dL and ≥200 vs. <200 mg/dL), and in subgroups stratified by hsCRP level at baseline (≤2 vs >2
mg/L) (Table 3.12).9
As stated earlier, the placebo used in REDUCE-IT contained mineral oil to resemble the color and
consistency of icosapent ethyl. Patients receiving placebo had marked increases in LDL
cholesterol (LDL-C) levels at year one compared to icosapent ethyl (median percent change:
10.2% vs. 3.1%, p<0.001) and in hsCRP levels at year two (32.3% vs. -13.9%, p<0.001). These
unexpected increases may indicate that the mineral oil used was not biologically inert and may
have resulted in an overstated treatment effect of icosapent ethyl relative to placebo. In
response to these concerns, the manufacturer posted the results of a post-hoc analysis on their
website, which stratified patients with and without on-trial increases in LDL-C in the placebo
arm.68 The post-hoc analysis suggested that treatment with icosapent ethyl resulted in
significant reductions in the risk for both the primary and key secondary composite endpoints,
irrespective of whether patients in the placebo arm experienced an increase in LDL-C (Table
3.13). To the best of our knowledge, however, similar analyses have not been performed in
relation to changes in hsCRP from baseline.
While the available evidence for both rivaroxaban and icosapent ethyl is indicative of a potential
net clinical benefit, there are several concerns with the design and results of these trials that
should be considered along with data on clinical outcomes and potential harms of these
treatments. Concerns are organized by intervention of interest in the sections that follow.
Rivaroxaban
The generalizability of the COMPASS trial population is subject to a number of uncertainties. For
one, study entry criteria of stable CAD and PAD as well as documentation of atherosclerosis in at
least two vascular beds among patients age <65 years ensured a population at high risk of
recurrent cardiovascular events, but exclusion of patients at high bleeding risk and further
exclusion of 8% patients not tolerating or adherent to run-in ASA therapy likely resulted in a
sample at reduced bleeding risk relative to the potential candidate population for
rivaroxaban.21,22
In addition, we cannot exclude the possibility that the clinical benefits observed in COMPASS are
somewhat overstated due to the trial having been stopped early for benefit after a mean of 23
months of follow-up.23 The Kaplan-Meier estimates provide some reassurance that benefits
observed after approximately one year of follow-up continued until the trial was stopped21, but
the balance of event reduction and bleeding risks beyond this point is currently unknown.
Relatedly, while the trial considered a measure of “net benefit” that included both
cardiovascular and bleeding events and found a statistically-significant 20% reduction in risk,
this definition only included fatal bleeding and symptomatic bleeding into a critical organ, and
no other definitions of major bleeding that comprised the primary safety outcome. Our own
calculations of risk-benefit using the full event definitions indicate an NNT of 77 for
The decision to separately randomize patients to receive the PPI pantoprazole or placebo within
the rivaroxaban + ASA, rivaroxaban alone, and ASA alone groups is a puzzling one, given that
clinical guidelines recommend routine use of PPIs for gastroprotection in patients receiving
combination anticoagulation + ASA therapy24 but not for anticoagulants or ASA alone. Recently-
reported results from COMPASS suggest that pantoprazole does not reduce the risk of upper GI
bleeding but does reduce bleeding from gastroduodenal lesions relative to placebo, and that
this finding is consistent regardless of the anticoagulation strategy used.69 It is unclear how this
finding would change clinical practice, however, given the well-established benefit-risk profile
and generic availability of PPIs.70-72
Finally, while the indications for combination treatment with rivaroxaban and DAPT with a P2Y12
inhibitor do not completely overlap, there is a large subset of patients with a recent MI event
who could conceivably be candidates for either treatment approach. Indeed, some clinicians
have called for further research comparing DAPT to combination therapy with ASA and a factor
Xa inhibitor (e.g., rivaroxaban).25,26 In the absence of head-to-head trials at the time of this
report’s publication, we attempted to compare the regimens indirectly through a network meta-
analysis. However, while only small differences exist in the definitions of clinical events across
the major trials of these regimens, the same cannot be said for definitions of major bleeding,
which differed substantially across trials; in some cases, a common definition was used but
modified to enough of an extent that we could not attempt quantitative comparisons with any
confidence. While this is a source of frustration for producers of comparative effectiveness
research like us, the real harm done is to the patient-clinician shared decision. Patients, in
particular, deserve to know how the major benefits and risks compare for treatments they
expect to receive over a lifetime. Standard and well-accepted definitions of both cardiovascular
events and bleeding risks exist, and the fact that they have not been used consistently and
without modification in as important a clinical area as this is a disservice to patients and the
clinicians who care for them.
Icosapent Ethyl
As noted previously, the placebo vehicle used in the REDUCE-IT trial (as well as earlier trials of
icosapent ethyl) contained mineral oil to mimic the viscosity of the active agent. Biomarker
changes observed in the trial raise the possibility that the mineral oil used was not biologically
inert, however; patients in the placebo arm experienced a threefold-higher percentage increase
in LDL-C at year one (10.2% vs. 3.1% for icosapent ethyl, p<0.001 for between-group difference)
and a substantial increase in the inflammation marker hsCRP at year two (32.9% vs. -13.9%,
p<0.001), adding to documented concerns regarding the mineral oil’s potential interference
Other findings from REDUCE-IT give rise to additional uncertainties. For example, a separate
publication described a larger effect size for icosapent ethyl when total ischemic events (rather
than time to first event) are considered, as well as improved levels of risk reduction with each
subsequent event.20 This type of analysis is controversial, however, given the relation that often
exists between event types (e.g., nonfatal MI followed by revascularization or death) and the
consequent inflation of event rates.73 The authors addressed this by bundling multiple events
occurring on the same day into one and specifying multiple statistical models. Subsequent
events were evaluated using the Wei-Lin-Weissfeld model, however, which has been previously
criticized for overstating the population at risk of subsequent events, which may lead to
overestimates of reductions in the risk of these events.74,75 Other model specifications not
subject to this form of bias, such as the Prentice-Williams-Petersen and kinetic modeling
techniques,73,75 were not employed in this analysis.
We also note that the results of this trial stand apart from many prior studies of omega-3
preparations that showed little to no cardiovascular benefit.27 Indeed, when a Bayesian
approach is taken to the overall evidence base, the interpretation of REDUCE-IT’s findings will
differ depending on whether prior expectations for these results are pessimistic, realistic, or
optimistic.28
Several possible explanations for differences between REDUCE-IT’s conclusions and those of
previous studies have been posited, including use of an EPA-only formulation. Docosahexaenoic
acid (DHA), another common component of omega-3 preparations, has been found to increase
LDL-C levels when used alone or in combination with EPA,76 although findings from a recent AHA
science advisory indicate this is only the case in patients with very high triglycerides, and
recommend prescription forms of EPA+DHA and EPA alone for triglyceride reduction.46 Other
possible reasons include a higher daily dose than previously studied, and the possibility of
metabolic effects of EPA other than triglyceride-lowering alone.9 Indeed, patients in the
REDUCE-IT trial had baseline elevations in triglyceride levels, but subgroup analyses suggested
that the effect of icosapent ethyl may be similar across triglyceride categories.
It is worth noting that reductions in cardiovascular events of approximately 20% were observed
in a prior EPA-only trial (JELIS), which randomized approximately 19,000 Japanese patients to
1.8 g of EPA in addition to statin therapy versus statins alone over a mean of 4.6 years of follow-
up.29 However, the JELIS trial was open-label and showed no reductions in cardiovascular death,
so its relevance to the results of REDUCE-IT is unclear. The JELIS trial was also conducted in a
Regardless of issues of trial design or interpretation, the greatest uncertainty may be in how
generalizable the REDUCE-IT results are and therefore what the most appropriate target
population will be. As with COMPASS, the patients enrolled in REDUCE-IT were at very high risk
of cardiovascular events, as illustrated by a placebo event rate of approximately 4.4% per year
over the 4.9-year median duration of follow-up.9 Patients also were on statin therapy, and it is
unclear whether icosapent ethyl would be effective in patients not treated with statins. How
the benefits of icosapent ethyl translate to an eligible population that is certain to be both
broader and at lower risk than the trial population remains to be seen.
Using the ICER Evidence Matrix (Figure 3.1), we assigned evidence ratings to rivaroxaban + ASA
and icosapent ethyl relative to the comparators of interest for this review (Table 3.14).
Compared to ASA alone, rivaroxaban + ASA significantly reduced the risk of cardiovascular
death, stroke, or MI in patients with stable CVD. Patients treated with rivaroxaban + ASA
experienced significantly fewer strokes (including disabling or fatal strokes), less cardiovascular
death, less all-cause mortality, fewer major adverse limb events, and fewer cardiovascular-
related hospitalizations. Although rivaroxaban + ASA significantly increased the risk of major
bleeding events, the COMPASS trial’s inclusion of bleeds leading to presentation at an acute
care facility in its primary safety analysis of major bleeding may have led to the inclusion of both
consequential and somewhat inconsequential bleeding events in this analysis. Bleeding events
of greatest severity—i.e., fatal bleeding, symptomatic bleeding into a critical organ, and nonfatal
symptomatic intracranial hemorrhages—were not significantly increased by adding rivaroxaban
to ASA. We therefore have high certainty that rivaroxaban + ASA provides a small-to-substantial
net health benefit in patients with CAD, PAD, or both conditions (“B+”).
We did not identify any head-to-head studies that directly compared rivaroxaban + ASA to DAPT
in patients with stable CVD. Although an indirect comparison of the risk of major adverse
cardiovascular events in patients with a recent MI suggested that DAPT may provide a similar
cardioprotective benefit as rivaroxaban + ASA, clinically significant differences in the way major
bleeding was defined in the clinical trials of focus precluded a companion analysis of relative
bleeding risks. We also note that those with a recent MI represented a relatively small subset of
patients in the COMPASS trial, so the comparative benefits and risks of these two strategies in
the remaining CAD and PAD population are unknown. We therefore have low certainty of
whether rivaroxaban + ASA provides a negative, comparable, or positive net health benefit
compared to DAPT in patients with CAD or PAD (“I”).
Icosapent ethyl reduced the risk of major adverse cardiovascular events in patients with
established CVD or diabetes mellitus and additional risk factors compared to optimal medical
management alone (i.e., placebo). The therapy was generally well-tolerated, despite a slight
increase in the incidence of major bleeding disorders. However, over 4.9 years of follow-up, no
fatal bleeding events occurred, and rates of TEAEs were comparable between the icosapent
ethyl and placebo arms. Although we are uncertain whether the use of mineral oil may have
caused some harm to the placebo group, we do not believe that this theory can account for the
entire benefit observed in the REDUCE-IT trial. We believe that the results of REDUCE-IT likely
apply across a range of baseline triglyceride levels but are uncertain whether the results
generalize to patients not treated with statins. For adults with established CVD or at high risk of
cardiovascular events who are being treated with statins, we have high certainty that icosapent
ethyl provides a small-to-substantial net health benefit (“B+”).
4.2 Methods
Model Structure
The Markov model focused on an intention to treat analysis, with a hypothetical cohort of adult
patients with established CVD (or at high CVD risk) being treated with optimal medical
management entering the model. The model included health states that define the pathways of
CVD and that have been used in previous modeling efforts.77-81 The base-case health states
included major cardiovascular events of MI and stroke, as well as post-event health states and
death (from cardiovascular and other causes). A scenario analysis included other cardiovascular
events beyond MI and stroke (e.g., revascularization or unstable angina) in the event and post-
event health states. Additional consequences such as major adverse limb events for
rivaroxaban, as well as SAEs, were tracked in the model. For these additional consequences, we
assumed event probabilities were equal for all living health states and therefore did not require
additional health states in the model structure.
Specifically, the CVD cohort began on treatment and could stay in that state, pass into event
states of MI or stroke, or death (Figure 4.1). Patients who experienced a cardiovascular event
moved into post-event health states, where they may have had higher likelihood for death as
compared to the general CVD prevention population. Patients remained in the model until they
died. All patients could transition to death from all-causes from any of the alive health states.
Death could have occurred from all-cause or cardiovascular event/post-event related morality.
As patients moved through the model over the course of their lifetime, they collected costs and
health utility weights related to the management and treatment of specific cardiovascular
Post-event states:
post-MI or post-
stroke
Target Population
The population of focus was adults with established CVD being treated with optimal medical
management. For the assessment of icosapent ethyl, patients without known CVD but at high
risk for cardiovascular events were also considered. The modeled populations’ characteristics
were consistent with the average across trial arms in the pivotal trials (Tables 4.1 and 4.2). The
population of study for rivaroxaban was, on average, 68 years old, 78% male, 21% with smoking
history, 38% with diabetes, 62% with prior MI, 4% with prior stroke, 22% with heart failure, and
with a number of commonly prescribed therapies as part of their medical management. The
population of study for icosapent ethyl was, on average, 64 years old, 71% male, 15% with
smoking history, 58% with diabetes, and 71% with prior CVD events. These model
characteristics have limited impact within the model, by influencing the time-varying clinical
event rate estimates (see Transition Probabilities).
Table 4.2. Base-Case Model Patient Characteristics for Icosapent Ethyl Evaluation
Characteristic Overall Source
19
Age, Years, Median (IQR) 64.0
Male (%) 71.2
High-Density Lipoprotein, mg/dL, Median (IQR) 40.0
Low-Density Lipoprotein, mg/dL, Median (IQR) 75.0
Triglycerides, mg/dL, Median (IQR) 216
84
Smoking (% Yes) 15.2
19,84
Diabetes – Type 2 (% Yes) 57.8
19
Prior CVD Events (% Yes) 70.7
CVD: cardiovascular disease, IQR: interquartile range
*Data not available in publicly disclosed sources.
Treatment Strategies
Interventions
The list of interventions was developed with input from patient organizations, clinicians,
manufacturers, and payers. The full list of interventions is as follows:
1. Rivaroxaban + ASA
• Patients are assumed to also be receiving optimal medical management.
2. Icosapent ethyl
• Patients are assumed to also be receiving optimal medical management,
including statins.
Comparators were defined to reflect the input of clinicians and other stakeholders on treatment
strategies that would be considered relevant alternatives for the overall population of interest
or a prominent subset, as well as the comparators as defined in major clinical studies of
rivaroxaban and icosapent ethyl.
1. Rivaroxaban comparators:
• Optimal medical management including ASA without an additional antiplatelet
agent.
• DAPT with clopidogrel (scenario analysis only).
2. Icosapent ethyl comparator:
• Optimal medical management including statin therapy.
Model cycle length was one year, based on what was observed in prior published economic
models and clinical data. The base-case analysis assumed a lifetime horizon, consistent with the
ICER Value Framework. The base-case analysis took a health care sector perspective and thus
focused on direct medical care and drug costs only. Costs and outcomes were discounted at 3%
per year. Key model assumptions are described in Table 4.3.
Model Inputs
Model inputs were estimated from the evidence review, published literature, and information
provided by stakeholders. The inputs that informed the models for rivaroxaban and icosapent
ethyl are described below.
Clinical Inputs
Key clinical inputs for the model included validated CVD risk prediction models, baseline trial-
based clinical markers (e.g., cholesterol, triglycerides), baseline comorbid conditions (e.g.,
diabetes), and other baseline factors (e.g., smoking, event history, etc.).
Transition Probabilities
Cardiovascular events included in the base-case model were: MI, stroke, and cardiovascular-
related mortality. Validated cardiovascular risk calculators91 were used to estimate time-varying
annualized event rates within the control arm (Table 4.4). The control arm’s 10-year risk of
cardiovascular events was calibrated such that the model produced consistent first
cardiovascular events observed over the same period as within the trial.
For rivaroxaban, the model calibration varied baseline risk while holding constant the
proportion of MI (59% of non-fatal first events restricted to MI and stroke only), stroke (41% of
non-fatal first events restricted to MI and stroke only), and death derived from first event trial-
based results (37% of non-fatal MI, non-fatal stroke, and cardiovascular death). For rivaroxaban,
the mean treatment follow-up duration was 23 months. At the beginning of the model, the
control arm’s annualized cardiovascular event rate was determined by comparing the observed
first cardiovascular event and cardiovascular death over an average of 23 months to that of the
model’s estimates at the end of two years (24 months). These annualized rates in the model
varied with time based on the validated cardiovascular risk calculators.91
Subsequent events were included in the model as well as first events. We assumed that the risk
of subsequent events would be the same as that of first events even if the risk calculator91
suggested lower likelihood of non-fatal cardiovascular events, given the relatively high severity
of the populations in the COMPASS and REDUCE-IT trials and the challenges inherent in
evaluating subsequent event risks in situations with event types that are not independent from
one another. Once calibrated to the trial’s control arm first observed events, these same risk
calculator parameters were also used in the model’s treatment arm in combination with the
treatment- and event-specific hazard ratios.
Table 4.4. Sources for Baseline Risk Equations for First Future Events, Subsequent Events, and
Mortality
Baseline Risk Equations Values Source
First Future Event (MI or Stroke) Varies by age and risk factors
91
Subsequent Future Events (MI or
Varies by age and risk factors
Stroke)
Calibrated to death from first
Event-Specific Mortality event using trial-based results
*Multiple sources20,21,85-
from standard of care arms 90,92
Increased mortality relative risk of
Mortality Post-MI or Stroke
2.5
Mortality, All-Cause Varies by age US Life Tables93
* An earlier version of this report incorrectly detailed these sources. It has been corrected here.
MI: myocardial infarction
The treatment- and event-specific hazard ratios for endpoints from the treatment-specific
clinical trials were applied to baseline risk estimates to model the transition from the
established CVD to the cardiovascular event health states at the end of each model cycle (each
year). Efficacy estimates for each intervention are detailed in Tables 4.5 and 4.6. The base case
assumed efficacy estimates from time to first event. Alternatives such as the relative risk of
total events and the inclusion of other cardiovascular events (revascularization and unstable
angina) were evaluated in a scenario analysis.
Treatment discontinuation rates were based on trial-specific data for each comparison. For
rivaroxaban, 16.5% of patients in the rivaroxaban + ASA arm had permanently discontinued
treatment at the final study visit (mean follow-up duration of 23 months).83
For icosapent ethyl, after an average follow-up of approximately two years, 18.7% of patients in
the icosapent ethyl arm had discontinued treatment at the time of a first event.20
Beyond two years duration in the model for rivaroxaban and five years duration for icosapent
ethyl, we assumed an annualized discontinuation based on SAE-related discontinuation of 2.7%
for rivaroxaban and 2.2% for icosapent ethyl. The observed trial-based hazard ratios were
assigned for all patients in the first two or five years of the model (no matter the discontinuation
status, i.e., consistent with an intention to treat analysis) for rivaroxaban and icosapent ethyl,
respectively. For model cycles beyond two years (rivaroxaban) and five years (icosapent ethyl),
the proportion remaining on active treatment were assigned the observed trial-based hazard
ratios whereas the proportion who discontinued treatment were assigned the costs and
outcomes consistent with optimal medical management.
Utilities
To adjust for quality of life, health state utilities were derived from publicly available literature
and applied to health states. Utility values were primarily from a study on preference-based EQ-
5D index scores for chronic conditions, based on survey results for a nationally representative
sample of the US adult population.94 We used consistent health state utility values across both
comparisons. We assigned higher disutilities to MI and stroke events compared to the post-
event states, consistent with prior studies (Table 4.7). Disutilities for AEs were applied to the
proportion of the cohort with an event within each cycle.
Since the severity of stroke can differ with patients experiencing a wide range of symptoms and
disability, we compared the disutility values for stroke listed in Table 4.7 to a weighted average
stroke utility value that incorporates stroke severity. The Modified Rankin Scale (mRS) is a
commonly used clinical outcome measure to classify strokes based on symptom severity, with
severity ranging from 0 (no symptoms) to 6 (dead). The COMPASS trial classified the severity of
all stroke events using the mRS, and the associated utilities for each stroke category have been
published in the literature95 (Appendix Table E5). We weighted the utility values for mRS
categories by the proportion of patients in the COMPASS control arm who experienced a stroke
in each mRS category to estimate a weighted average stroke utility (Appendix Table E5). This
weighted average utility value is 0.6615, which is higher than the utility value applied to a
patient in our model cohort who experiences an event cycle stroke (0.5976). While the severity
differed for COMPASS patients who experienced a stroke, the risk reduction for stroke with
rivaroxaban + ASA versus ASA alone was consistent across all mRS categories.14
Adverse Events
The model included all reported treatment-related SAEs and bleeding events for each of the two
comparisons. Each SAE had an associated cost and disutility (if available) that was applied for
each occurrence of the event. Inputs related to SAEs for each intervention are detailed in Tables
4.8 and 4.9.
For the rivaroxaban comparison, major bleeding events occurred more frequently in patients in
the rivaroxaban + ASA group than in the ASA alone group (3.1% vs. 1.9%). The annualized
probability for each treatment arm was used within the model.83
For the icosapent ethyl comparison, overall AE rates were low in both treatment arms and none
of the AEs were fatal. There was an observed trend toward increased serious bleeding in the
icosapent ethyl arm. The evidence on icosapent ethyl did not suggest significant increases in
serious central nervous system bleeding, GI bleeding, or adjudicated hemorrhagic stroke and
therefore no difference in major bleeding was assumed within the model. There was a small,
statistically significant increase in hospitalization for atrial fibrillation or flutter endpoints that
was included in the model.20
Drug Utilization
The following inputs were used to model drug utilization and associated costs for each
intervention:
• Duration of treatment
• Schedule of doses for each drug
Economic Inputs
For both drugs, we obtained net pricing estimates from SSR Health, LLC,32 which combine data
on unit sales with publicly-disclosed US sales figures that are net of discounts, rebates,
concessions to wholesalers and distributors, and patient assistance programs to derive a net
price. We estimated net prices by comparing the four-quarter averages (i.e., 2nd quarter of
2018 through 1st quarter of 2019) of both net prices and wholesale acquisition cost (WAC) per
unit to calculate a mean discount from WAC for the drug. Finally, we applied this average
discount to the most recently available WAC (July 1, 2019) to arrive at an estimated net price
per unit.
Rivaroxaban’s WAC is $7.47 per 2.5 mg tablet. The average discount from WAC was 59.41% for
rivaroxaban, leading to an estimated net price of $3.03 per dose.
Icosapent ethyl’s WAC for a one-month supply of 4 g/day is $303.65 (each bottle contains 120
each of 1 g capsules). The average discount from WAC was 56.04% for icosapent ethyl, leading
to an estimated net price of $1.11 per dose.
Please refer to the ICER Reference Case for more details on drug pricing.
Non-Drug Costs
Health state costs were derived from literature-based estimates. Indirect costs were not
included in the base-case analysis but were included in a scenario analysis. All costs were
inflated to year 2019 levels using the health care component of the personal consumption
expenditure index,100 in accordance with the ICER Reference Case.101
Sensitivity Analyses
We ran one-way sensitivity analyses to identify the key drivers of model outcomes, using
available measures of parameter uncertainty (i.e., standard errors) or reasonable ranges for
each input described in the model inputs section above. Probabilistic sensitivity analyses were
also performed by jointly varying all model parameters over 5,000 simulations, then calculating
95% credible range estimates for each model outcome based on the results. Additionally, we
performed a threshold analysis by systematically altering the price of rivaroxaban and icosapent
Scenario Analyses
Multiple scenario analyses were conducted to evaluate the impact of key model choices and
assumptions on the robustness of the results and conclusions. First, the perspective was
expanded to a modified/restricted societal one that included productivity losses. Evidence
suggests that workers have workplace absenteeism and short-term disability equal to 13.6
hours per month within the first year after a cardiovascular event, but no differences beyond
the first year.105 We assumed these first-year annualized hours, 163.2 hours, would apply to all
individuals in the model who experienced a cardiovascular event.106 The average hourly wage of
$27.71 was assumed to apply to all hours no matter the working status of the individual.
Second, the addition of other cardiovascular events, such as revascularization and unstable
angina, were included in the cardiovascular event health state within the model. Coronary
revascularization and unstable angina requiring hospitalization were pre-specified
subcomponents of the primary composite endpoint in the icosapent ethyl trial. Third, the
composite primary endpoints and corresponding hazard ratios from the intervention-specific
trials were modeled instead of the individual subcomponents of the primary endpoints. Fourth,
DAPT with clopidogrel was modeled as a comparator to rivaroxaban + ASA (Appendix Table E2-
E4). Due to differences in severe bleeds, the clinical review was not able to produce a hazard
ratio that indirectly compared the rates of major bleeding with DAPT with clopidogrel to
rivaroxaban + ASA. The annualized bleeding rate for the ASA alone arm of the “CAPRIE-like
subgroup” (documented prior MI, ischemic stroke, or symptomatic PAD) from CHARISMA was
0.0065.18 Rate ratios between 1 and 5 (for rivaroxaban + ASA versus DAPT with clopidogrel)
were modeled and compared versus commonly cited thresholds. Finally, we estimated the
potential cost effectiveness of the interventions versus their respective optimal medical
management comparator by assuming the same baseline cardiovascular risk through averaging
the baseline risk across the two interventions’ trial populations, but assuming the same
intervention-specific hazard ratios.
Model Validation
We used several approaches to validate the model. First, we provided preliminary methods and
results to manufacturers, patient groups, and clinical experts. Based on feedback from these
groups, we refined data inputs used in the model. Second, we varied model input parameters
to evaluate face validity of changes in results. We performed model verification for model
calculations using internal reviewers. As part of ICER’s efforts to increase modeling
transparency, we will also share the model with relevant manufacturers for external verification
and feedback shortly after publishing the draft report for this review. Finally, we compared
results to other cost-effectiveness models in this therapy area.
Base-Case Results
The base-case lifetime undiscounted clinical events are found in Tables 4.13 and 4.14 for
rivaroxaban and icosapent ethyl, respectively. Over a lifetime horizon, we present the
percentage of the modeled cohort who experienced their first modeled event as an MI or as a
stroke. Separately, we present the proportion of the modeled cohort who experienced death
due to CVD or due to all other causes. Further, we present the cumulative incidence of
cardiovascular events (MI, stroke, and cardiovascular death). The column percentage sum of
death due to CVD and all other causes approximates to 100 but may differ slightly due to
rounding. For both rivaroxaban and icosapent ethyl, lower lifetime first MI, first stroke, and
death due to CVD were observed. The major adverse cardiovascular event cumulative incidence
including MI, stroke, and cardiovascular-related death was lower for both interventions as
compared to optimal medical management alone. Note that subsequent events were also
tracked within the model alongside associated costs and disutilities but are not reported here.
Table 4.14. Icosapent Ethyl Long-Run Clinical Outcomes (Lifetime Horizon, Undiscounted)
Lifetime Events
Absolute
Event Intervention Medical Management
Difference
First Event MI 29% 35% -6%
First Event Stroke 9% 11% -2%
Death (CV) 38% 46% -8%
Cumulative CV events (MI, Stroke, and CV Death) 81% 98% -17%
Death (All Other Cause) 61% 54% N/A
CV: cardiovascular, MI: myocardial infarction
Base-case discounted costs and outcomes from the model are listed in Table 4.15 for
rivaroxaban and in Table 4.16 for icosapent ethyl. Rivaroxaban was associated with
approximately $17,000 in discounted lifetime intervention costs, whereas icosapent ethyl was
associated with $15,000 in lifetime intervention costs. Although additional medical
management intervention and non-intervention costs are likely within the modeled cohorts,
Table 4.15. Base-Case Discounted Results for Rivaroxaban Compared to Optimal Medical
Management including ASA
Non-
Intervention
Treatment Intervention Total Costs Life Years evLYG QALYs
Costs
Costs
Rivaroxaban $17,000 $20,000 $38,000 10.86 9.07 9.06
Medical
$200 $24,000 $24,000 10.45 8.69 8.69
Management
evLYG: equal value of life years gained, QALY: quality-adjusted life year
Table 4.16. Base-Case Discounted Results for Icosapent Ethyl Compared to Optimal Medical
Management including Statins
Non-
Intervention
Treatment Intervention Total Costs Life Years evLYG QALYs
Costs
Costs
Icosapent
$15,000 $25,000 $40,000 12.26 10.21 10.19
Ethyl
Medical
$800 $30,000 $31,000 11.73 9.69 9.69
Management
evLYG: equal value of life years gained, QALY: quality-adjusted life year
Base-case discounted incremental results are shown in Table 4.17, with rivaroxaban versus
optimal medical management yielding $36,000 per QALY gained. Icosapent ethyl versus optimal
medical management yields $18,000 per QALY gained. Discounted incremental life year results
were slightly lower than the incremental cost-per-QALY findings. Discounted incremental equal
value life years gained (evLYG) evenly measures any gains in length of life, regardless of the
impact on patients’ quality of life. Results for the incremental evLYG were slightly lower than
the cost-per-QALY findings given there is a life extension to each therapy over medical
management. Incremental cost per major adverse cardiovascular event avoided could be
interpreted as the expected costs to achieve one less major adverse cardiovascular event (MI,
stroke, or cardiovascular death) when treating a population with rivaroxaban versus optimal
medical management or separately, when treating a population with icosapent ethyl versus
optimal medical management. The incremental cost per major adverse cardiovascular event
avoided should be interpreted with caution, given that this metric does not have a known
threshold for an understanding of value and does not include the differential timing or the
differential importance of major adverse cardiovascular events. Note that the intervention-
specific incremental findings are modeled using intervention-specific populations and therefore
should not be directly compared across treatments.
Cost per
Incr. Incr. Incr. Incr. Cost Cost per Cost per
Intervention* MACE
Costs LYs evLYG QALYs per LY evLYG QALY
Avoided
Icosapent
$17,000 $17,000 $18,000 $53,000
Ethyl vs.
$9,000 0.54 0.52 0.50 per LY per evLYG per QALY per MACE
Medical
gained gained gained avoided
Management
ICER: incremental cost-effectiveness ratio, Incr.: Incremental, LY: life year, MACE: major cardiovascular event,
QALY: quality adjusted life year
*Modeled populations differed across interventions; results for the interventions are not directly comparable.
To demonstrate effects of uncertainty on both costs and health outcomes, we varied input
parameters using available measures of parameter uncertainty (i.e., standard errors) or
reasonable ranges to evaluate changes in cost per additional QALY. Key drivers of uncertainty
for rivaroxaban versus optimal medical management included the clinical event hazard ratios for
MI, stroke, and cardiovascular death, with smaller impacts observed from uncertainty in utility
and cost inputs (Figure 4.2). Similarly, key drivers of uncertainty for icosapent ethyl versus
optimal medical management included the clinical event hazard ratios for MI, stroke, and
cardiovascular death, with smaller impacts observed from uncertainty in utility and cost inputs
(Figure 4.3).
Input Name Lower Input ICER Upper Input ICER Lower Input Upper Input
Relative Risk – Non-Fatal MI $23,914 $52,746 0.70 1.05
Relative Risk – Non-Fatal
$26,651 $45,463 0.44 0.76
Stroke
Relative Risk – CV Death $29,304 $40,500 0.64 0.96
Health Utility – Treated
Population without $34,981 $31,854 0.81 0.89
Observed Events
Health State Cost – Stroke $34,698 $31,582 $42,894 $77,477
Health State Cost – CV Death $33,937 $32,461 $13,350 $24,113
Health State Cost – MI $33,647 $32,797 $40,262 $72,724
Health State Cost – Post MI $33,131 $33,394 $1,986 $3,586
Health State Cost – Post
$33,349 $33,142 $4,179 $7,549
Stroke
Disutility – Post Event Stroke $33,302 $33,202 0.19 0.21
CV: cardiovascular, MI: myocardial infarction, ICER: incremental cost-effectiveness ratio
Ninety two percent of iterations suggested that rivaroxaban met the $50,000/QALY threshold.
Icosapent ethyl results suggested that nearly 100% of iterations met the $50,000/QALY
threshold (Table 4.18). Both interventions achieved 100% of iterations that met the
$100,000/QALY and $150,000/QALY thresholds.
A scenario analysis was conducted with the addition of other cardiovascular events such as
revascularization and unstable angina included in the cardiovascular event health state within
the icosapent ethyl evaluation. This broader inclusion of other cardiovascular events shifted the
incremental cost per QALY from $18,000/QALY (base-case) to $16,000/QALY (Table 4.20).
A scenario analysis was conducted using the composite primary endpoints instead of individual
primary endpoints from the intervention-specific trials. This scenario yielded higher but similar
incremental cost-per-QALY findings (Table 4.21).
A scenario analysis was conducted comparing rivaroxaban + ASA to DAPT with clopidogrel +
ASA. We present the incremental findings assuming the ASA annualized major bleed rate of
0.0065 (Table 4.22) for both rivaroxaban + ASA as well as for DAPT with clopidogrel (i.e.,
assuming this rate did not differ between treatment strategies). Further, we present the
incremental findings assuming the ASA annualized major bleed rate of 0.0065 for DAPT with
clopidogrel and solved for the rate ratio that would generate an incremental cost-effectiveness
ratio per QALY of $100,000 (rivaroxaban + ASA vs. DAPT with clopidogrel). The rate ratio for
major bleed was 2.83 (rivaroxaban + ASA vs. DAPT with clopidogrel) to generate an incremental
cost-effectiveness ratio of $100,000 per QALY (results not shown).
We estimated the potential cost effectiveness of the interventions versus their respective
optimal medical management comparator by assuming the same baseline cardiovascular risk by
averaging the baseline risk across the two interventions’ trial populations but assuming the
base-case intervention-specific hazard ratios. The incremental results for both treatments move
toward one another with rivaroxaban’s incremental cost-per-QALY of $33,000/QALY and
icosapent ethyl’s incremental cost-per-QALY of $19,000/QALY. However, given the lack of
formal direct or indirect treatment comparisons, the results for the interventions may not be
directly comparable.
Table 4.25 presents the threshold results for each drug at thresholds of $50,000, $100,00 and
$150,000 per equal value life year gained (evLYG). An analysis of the evLYG is included to
Model Validation
Model validation followed standard practices in the field. We tested all mathematical functions
in the model to ensure they were consistent with the report (and supplemental Appendix
materials). We also conducted sensitivity analyses with null input values to ensure the model
was producing findings consistent with expectations. Further, independent modelers tested the
mathematical functions in the model as well as the specific inputs and corresponding outputs.
We reported on the model calibration findings to suggest that over a time horizon consistent
with the randomized controlled trials, the model produced first event MI, first event stroke, and
cardiovascular death rates within small margins of error of the randomized controlled trial
findings (Appendix Table E7-Table E8).
Model validation was also conducted in terms of comparisons to other model findings. We
searched the literature to identify models that were similar to our analysis, with comparable
populations, settings, perspective, and treatments. Fonarow et al. evaluated the cost
effectiveness of evolocumab in patients with atherosclerotic CVD when added to standard
background therapy.107 They used a Markov cohort state-transition model from a US societal
perspective assuming a lifetime time horizon to capture the progression of atherosclerotic CVD
in adults. We used inputs from this study in our model to validate against the Fonarow model
findings and achieved agreeable estimates (Appendix Table E6).
In our review of prior economic models, Fonarow et al. evaluated the cost effectiveness of the
proprotein convertase subtilisin/kexin type 9 inhibitor evolocumab in patients with
atherosclerotic cardiovascular disease when added to standard background therapy.107 A
Markov cohort state-transition model was used, integrating US population-specific
©Institute for Clinical and Economic Review, 2019 Page 55
Additive CVD Therapies – Final Evidence Report Return to Table of Contents
demographics, risk factors, background therapy, and event rates, along with trial-based event
risk reduction. In the base case, using patients with atherosclerotic cardiovascular disease,
evolocumab had an ICER of approximately $269,000 per QALY gained (approximately $166,000
using a discounted price based on an average rebate of 29% for branded pharmaceuticals).107
Sensitivity and scenario analyses demonstrated ICERs ranging from approximately $100,000 to
$489,000 per QALY, with an ICER of approximately $414,000 per QALY when using trial patient
characteristics. At its list price of $14,523, the addition of evolocumab to standard background
therapy in patients with atherosclerotic cardiovascular disease exceeded generally accepted
cost-effectiveness thresholds.107
A study by Kazi et al. estimated the cost effectiveness of PCSK9 inhibitors in patients with
heterozygous familial hypercholesterolemia (FH) or atherosclerotic cardiovascular disease
(ASCVD).102 A simulation model of US adults aged 35 to 94 years, called the Cardiovascular
Disease Policy Model, was used to evaluate the cost effectiveness of PCSK9 inhibitors or
ezetimibe in heterozygous FH or ASCVD.102 Adding PCSK9 inhibitors to statins in heterozygous
FH was estimated to prevent 316,300 MACE at a cost of $503,000 per QALY gained compared
with adding ezetimibe to statins (80% uncertainty interval [UI], $493,000-$1,737,000).102 In
ASCVD, adding PCSK9 inhibitors to statins was estimated to prevent 4.3 million MACE compared
with adding ezetimibe, at $414,000 per QALY (80% UI, $277,000-$1,539,000).102 In this study,
PCSK9 inhibitor use in patients with heterozygous FH or ASCVD did not meet generally
acceptable incremental cost-effectiveness thresholds.102
Two studies assessed the cost effectiveness of rivaroxaban and aspirin compared to aspirin
alone in patients with stable cardiovascular disease and in patients with peripheral or carotid
artery disease from the Australian perspective.78,79 Ademi et al. developed a Markov model
using input data from the COMPASS trial. Compared to aspirin alone, rivaroxaban plus aspirin
was estimated to have an ICER of AUD$31,436/QALY gained.79 The authors concluded that
compared to aspirin, rivaroxaban in combination with aspirin is likely to be cost-effective in
preventing recurrent cardiovascular events in patients with stable atherosclerotic vascular
disease.79 Similarly, Zomer et al. estimated that rivaroxaban plus aspirin therapy prevented 143
non-fatal cardiovascular disease events, 118 major adverse limb events and 10 deaths
compared to aspirin therapy alone, resulting in an ICER of AUD$26,769 per QALY. 78 The authors
concluded that in patients with peripheral artery disease or carotid artery disease, rivaroxaban
plus aspirin therapy was cost-effective in the prevention of recurrent cardiovascular disease
compared to aspirin therapy alone.78
Other published economic evaluations included the assessment of eicosapentaenoic acid (EPA)
in CVD prevention in the settings of the US and Japan.80,81 The results of the US model showed
that combining EPA with statin therapy for secondary prevention of cardiovascular disease may
be a cost-saving option compared to statin monotherapy.81 In the Japanese assessment, EPA
plus statin combination therapy showed acceptable cost effectiveness for secondary prevention,
but not primary prevention, of CVD in patients with hypercholesterolemia.80
Limitations
Our analyses had important limitations and assumptions. We assumed three-component major
adverse cardiovascular events, MI, stroke, and cardiovascular death, to form the base-case
health states within the model structure for both rivaroxaban and for icosapent ethyl.
Acknowledging that other potential cardiovascular events are problematic to model due to
potential double-counting and competing events, we did not cost out or apply disutilities to any
other potential differences in cardiovascular events such as revascularization. This model
structure was consistent with prior ICER evaluations within established CVD.108 A scenario
analysis that broadened major adverse cardiovascular events to include other events suggested
similar but lower cost-effectiveness findings for icosapent ethyl. For all evaluated treatments,
the evidence was more uncertain when quantifying the cumulative incidence of subsequent
events as well as the relative impacts that the treatments had on subsequent events. Base-case
assumptions held treatment-specific first-event relative reductions constant for subsequent
events. Icosapent ethyl trial evidence suggested this assumption is appropriate or slightly
conservative for the purposes of estimating cost effectiveness. Patient-level projections of trial
evidence could aid in supporting or refuting our model assumptions surrounding ASA
cumulative incidence of subsequent events as well as the relative impact of treatment.
An additional limitation of this analysis was the model calibration to the observed clinical trial
event rates for optimal medical management. Many unknowns were a part of the model
calibration exercise. We opted to calibrate the model to first MI, first stroke and cardiovascular
Conclusions
In conclusion, the findings of our analysis suggest that the additive CVD therapies of focus for
this review provide gains in quality-adjusted survival and overall survival over optimal medical
management. Assuming clinical signals within the trial hold for patients treated with these
interventions and current net prices, the base-case results suggest that costs for treatment with
either rivaroxaban or icosapent ethyl would fall below commonly cited thresholds for cost
effectiveness. The results were relatively robust to sensitivity and scenario analyses. When
comparing rivaroxaban + ASA to clopidogrel + ASA, the incremental results are more uncertain,
but generally fall below $100,000/QALY.
Each ICER review culminates in a public meeting of an independent voting Council of clinicians,
patients, and health services researchers. As part of their deliberations, Council members will
judge whether a treatment may substantially impact the considerations listed in Table 5.1. The
presence of substantial other benefits or contextual considerations may shift a council
member’s vote on an intervention’s long-term value for money to a different category than
would be indicated by the clinical evidence and cost-effectiveness analyses alone. For example,
a council member may initially consider a therapy with an incremental cost-effectiveness ratio
of $150,000 per QALY to represent low long-term value for money. However, the Council
member may vote for a higher value category if they consider the treatment to bring substantial
other benefits or contextual considerations. Conversely, disadvantages associated with a
treatment may lead a Council member to vote for a lower value category. A Council member
may also determine that there are no other benefits or contextual considerations substantial
enough to shift their vote. All factors that are considered in the voting process are outlined in
ICER’s value assessment framework. The content of these deliberations is described in the last
chapter of ICER’s Final Evidence Report, which is released after the public meeting.
This section, as well as the Council’s deliberation, provides stakeholders with information to
inform their decisions on a range of issues, including shared decision-making between patients
and clinicians, coverage policy development, and pricing negotiations.
Because both agents represent new mechanisms of action, they represent important treatment
options that may be complementary to existing treatment mechanisms (e.g., PCSK9 inhibition),
and may offer benefit if adherence to existing treatment is sub-optimal. They also appear to
offer further risk reductions in patients already optimally managed on other medications,
however, an important consideration given the high residual risk of cardiovascular events in
those with established disease.
There are no expected benefits with regard to reduction in disparities, return to work, or other
aspects of disease management and treatment.
While icosapent ethyl and rivaroxaban represent new treatment mechanisms for CVD, there are
multiple other options available, including antithrombotics and multiple classes of lipid-lowering
agents and antihypertensives, many of which are available in generic form. The incremental
benefit of adding either of these two treatments to current medical management relative to
adding another relatively new treatment such as a PCSK9 inhibitor is unclear, as are the
potential benefits of all of these agents in combination.
The Phase III COMPASS trial of rivaroxaban was stopped early due to evidence of clinical benefit,
so the evidence base is limited to a median of approximately two years of follow-up. While this
introduces a fair degree of uncertainty to the assessment of long-term clinical benefits,
uncertainty around long-term risks is likely greater. For example, guideline statements for long-
term use of dual antiplatelet therapy use cautionary language specifically because of the
relatively short-term nature of clinical trials and concerns regarding bleeding risks over the long-
term.109 In contrast, the Phase III REDUCE-IT trial of icosapent ethyl included a median of nearly
five years of follow-up. Residual uncertainty among the clinical community is primarily focused
on the poor previous track record of other omega-3-based products in reducing cardiovascular
risks.
The benefits of rivaroxaban were robust among most patient subgroups, except for the very
elderly (≥75 years) as well as those with PAD only and without baseline dyslipidemia, although
these were small subsets of the COMPASS trial.21 Similarly, icosapent ethyl’s effects were
relatively consistent across subgroups, although the 95% confidence interval around the hazard
ratio estimate did include 1.0 in primary-prevention patients, those receiving ezetimibe, and
patients with baseline triglycerides <150 mg/dL; again, the latter two subsets were quite small.9
As mentioned above, however, the major challenge in interpretation of the trial data is in
generalizability, as patients were at very high risk of recurrent CVD events and optimally
managed on current therapy, conditions unlikely to be replicated with real-world use.
For rivaroxaban, price changes of approximately 4% discount to 39% over the list price (WAC)
would be required to reach the $100,000 to $150,000 per QALY threshold prices, respectively.
For icosapent ethyl, prices approximately 70% to 149% above WAC would achieve $100,000 to
$150,000 per QALY threshold prices (Table 6.1).
Table 6.1. Value-Based Price Benchmarks for Rivaroxaban and Icosapent Ethyl
Change from WAC
Annual Price at Annual Price at
Annual WAC to Reach Threshold
$100,000 Threshold $150,000 Threshold
Prices
Rivaroxaban
Per QALY Gained $5,457 $5,223 $7,597 -4% to +39%
Per evLYG $5,369 $7,780 -2% to +43%
Icosapent Ethyl
Per QALY Gained $3,699 $6,282 $9,204 +70% to +149%
Per evLYG $6,501 $9,423 +76% to +155%
WAC: wholesale acquisition cost; evLYG: equal value life year gained; QALY: quality-adjusted life year
We are including results for price per evLYG to ensure that policymakers are aware of the
complementary information these results can provide to the cost per QALY findings. The annual
price at which rivaroxaban meets the $100,000 to $150,000 per evLYG range for use in these
patients is $5,369 to $7,780. For icosapent ethyl, the relevant cost per evLYG price range is
$6,501 to $9,423 for the $100,000 to $150,000 per evLYG thresholds. The cost per evLYG price
range is quite similar to the cost per QALY range for both rivaroxaban and icosapent ethyl.
7.2 Methods
We used results from the same model employed for the cost-effectiveness analyses to estimate
total potential budget impact. Potential budget impact was defined as the total differential cost
of using each new technology for the eligible population in this indication, calculated as
differential health care costs (including drug costs) minus any offsets in these costs from
avoided treatments and averted health care events. We assumed that patients matching those
in the respective trials would be eligible for rivaroxaban and icosapent ethyl. All costs were
undiscounted and estimated over a five-year time horizon, given the potential for cost offsets to
accrue over time and to allow a more realistic impact on the number of patients treated with
these new therapies.
For rivaroxaban, to estimate the size of the eligible prevalent population, we used a baseline
estimate for CAD of 6.7% of the US population (age≥20) based on a recent update from the AHA
in conjunction with the National Institutes of Health and other agencies.2 We then applied this
estimate to the average of the projected 2019 to 2023 US population (age≥20) to derive the
eligible population over the next five years. This resulted in an eligible population size for
rivaroxaban of approximately 16,908,000 patients over five years, or an estimated 3,385,000
patients each year.
For icosapent ethyl, to estimate the secondary prevention group, we used the same baseline
estimate for CAD of 6.7% of the US population (age≥20).2 In addition, we accounted for the
prevalence of patients with stroke (2.5%).2 To estimate the primary prevention population with
diabetes and one additional risk factor, we used an estimate of diabetes mellitus prevalence in
the US population of 9.8%2 and assumed 87% of these patients would have an additional risk
factor, based on the estimated proportion of diabetes patients with metabolic syndrome. 110 We
applied these estimated proportions for patients in the secondary prevention group and for
patients of age ≥50 years in the primary prevention group to the projected average of the 2019
to 2023 US population to derive the estimated eligible population over the next five years. This
resulted in an eligible population size for icosapent ethyl of approximately 33,522,000 patients
over five years, or an estimated 6,704,000 patients each year.
ICER’s methods for estimating potential budget impact are described in detail elsewhere111 and
have been recently updated. ICER recalculates the potential budget impact threshold each
To estimate potential budget impact, we evaluate a new therapy that would take market share
from one or more existing therapies and calculate the blended budget impact associated with
displacing use of existing therapies with the new intervention. For this analysis, we evaluated
the potential budget impact of rivaroxaban and icosapent ethyl as additive therapies to optimal
medical management in patients with established CVD, and in the case of icosapent ethyl, also
in patients without evidence of CVD but with diabetes and at least one additional risk factor.
For each treatment, we assumed equal uptake over five years, with treatment duration ranging
from one year (for the year-five cohort) to five years (for the year-one cohort). In other words,
patients initiating therapy in year one would accrue all drug costs and cost offsets over the full
five years, but those initiating in other years would only accrue a proportional amount of the
five-year costs. Note that the purpose of these analyses is to estimate the potential budget
impact, not to predict actual uptake or expected budget impact.
7.3 Results
For rivaroxaban, per-patient budget impact calculations are based on the WAC price of $5,457
per year, the net price of $2,215 per year, and the prices to reach $150,000, $100,000, and
$50,000 per QALY thresholds (at $7,597, $5,223, and $2,849 per year, respectively).
The average five-year annualized per patient potential budgetary impact when using the WAC
price and the net price were approximately $3,800 and $1,450, respectively. The average five-
year annualized potential budgetary impact at the three cost-effectiveness threshold prices
ranged from approximately $5,900 per patient using the annual price to achieve $150,000 per
QALY to approximately $2,000 using the annual price to achieve a $50,000 per QALY cost-
effectiveness threshold.
As shown in Figure 7.1, the ICER budget impact threshold of $819 million would be crossed if
greater than approximately 2% of eligible patients were treated in a given year with rivaroxaban
at the WAC price. When using the net price, the threshold would be reached when
approximately 6% of eligible patients were treated in a given year with rivaroxaban.
Approximately 1%, 2% and 4% of patients could be treated in a given year without crossing the
budget impact threshold at the $150,000, $100,000, and $50,000 per QALY threshold prices.
Although the per patient budget impact is relatively small, due to the very large population of
$8,000
$150,000 per QALY
$7,000
$6,000
WAC price
$5,000 $100,000 per QALY
Annual Price
$4,000
Net price
$2,000
$1,000
$0
0% 20% 40% 60% 80% 100%
For icosapent ethyl, per-patient budget impact calculations are based on the WAC price of
$3,699 per year, the net price of $1,625 per year, and the prices to reach $150,000, $100,000,
and $50,000 per QALY thresholds (at $9,204, $6,282, and $3,433 per year, respectively).
The average five-year annualized per patient potential budgetary impact when using the WAC
price and the net price were approximately $2,500 and $960, respectively. The average five-
year annualized potential budgetary impact at the three cost-effectiveness threshold prices
ranged from approximately $7,200 per patient using the annual price to achieve $150,000 per
QALY to approximately $2,450 using the annual price to achieve a $50,000 per QALY cost-
effectiveness threshold.
As shown in Figure 7.2, the ICER budget impact threshold of $819 million would be crossed if
greater than approximately 2% of eligible patients were treated in a given year with icosapent
ethyl at the WAC price. When using the net price, the threshold would be reached if
approximately 4% of eligible patients were treated in a given year with icosapent ethyl.
Between 1% and 2% of patients could be treated in a given year without crossing the budget
impact threshold at the $150,000, $100,000, and $50,000 per QALY threshold prices. As with
rivaroxaban, the relatively small budget impact per patient, when combined with the very large
population of patients potentially eligible for treatment, has the potential to exceed the budget
impact threshold.
$10,000
$8,000
$7,000
$5,000
$2,000
Net price
$1,000
$0
0% 20% 40% 60% 80% 100%
Acknowledging that any judgment of evidence is strengthened by real-life clinical and patient
perspectives, subject matter experts are recruited for each meeting topic and provide input to
Midwest CEPAC Panel members before the meeting to help clarify their understanding of the
different interventions being analyzed in the evidence review. The same clinical experts serve
as a resource to the Midwest CEPAC Panel during their deliberation and help to shape
recommendations on ways the evidence can apply to policy and practice.
After the Midwest CEPAC Panel votes, a policy roundtable discussion is held with the Midwest
CEPAC Panel, clinical experts, patient advocates, payers, and when feasible, manufacturers. The
goal of this discussion is to bring stakeholders together to apply the evidence to guide patient
education, clinical practice, and coverage and public policies. Participants on policy roundtables
are selected for their expertise on the specific meeting topic, are different for each meeting, and
do not vote on any questions.
At the September 26, 2019 meeting, the Midwest CEPAC Panel discussed issues regarding the
application of the available evidence to help patients, clinicians, and payers address important
questions related to the use of rivaroxaban and icosapent ethyl. Following the evidence
presentation and public comments (public comments from the meeting can be accessed
[https://www.youtube.com/watch?v=2LFCTqW_hSc&feature=youtu.be], starting at minute
[1:28:55]), the Midwest CEPAC Panel voted (votes from the meeting can be accessed
[https://www.youtube.com/watch?v=ATMvwRQ_RPk&feature=youtu.be], starting at minute
[0:02:23]), on key questions concerning the comparative clinical effectiveness, and potential
other benefits and contextual considerations related to rivaroxaban and icosapent ethyl. These
questions are developed by the ICER research team for each assessment to ensure that the
questions are framed to address the issues that are most important in applying the evidence to
support clinical practice, medical policy decisions, and patient decision-making. The voting
results are presented below, along with specific considerations mentioned by Midwest CEPAC
Panel members during the voting process.
There are four elements to consider when deliberating on long-term value for money (see
Figure 8.1 below):
• Estimated incremental cost effectiveness is the average incremental cost per patient of
one intervention compared to another to achieve a desired “health gain,” such as an
additional stroke prevented, case of cancer diagnosed, or gain of a year of life.
Alternative interventions are compared in terms of cost per unit of effectiveness, and
the resulting comparison is presented as a cost-effectiveness ratio. Relative certainty in
the cost and outcome estimates continues to be a consideration. As a measure of cost
effectiveness, the Midwest CEPAC voting panel follows common academic and health
technology assessment standards by using cost per quality-adjusted life year (QALY),
with formal voting on “long-term value for money” when the base-case incremental
cost-effectiveness ratio is between $50,000 per QALY and $175,000 per QALY.
• Potential other benefits refer to any significant benefits or disadvantages offered by the
intervention to the individual patient, caregivers, the delivery system, other patients, or
the public that would not have been considered as part of the evidence on comparative
clinical effectiveness. Examples of potential other benefits include better access to
treatment centers, mechanisms of treatment delivery that require fewer visits to the
clinician’s office, treatments that reduce disparities across various patient groups, and
new potential mechanisms of action for treating clinical conditions that have
demonstrated low rates of response to currently available therapies. Other
disadvantages could include increased burden of treatment on patients or their
caregivers. For each intervention evaluated, it will be open to discussion whether
potential other benefits or disadvantages such as these are important enough to factor
into the overall judgment of long-term value for money. There is no quantitative
measure for potential other benefits or disadvantages.
• Contextual considerations include ethical, legal, or other issues (but not cost) that
influence the relative priority of illnesses and interventions. Examples of contextual
considerations include whether there are currently any existing treatments for the
condition, whether the condition severely affects quality of life or not, and whether
Clinical Evidence
a) Is the evidence adequate to demonstrate that the net health benefit of rivaroxaban
plus ASA is superior to that provided by ASA alone?
A majority of the Council determined that the evidence was adequate to demonstrate
that the net health benefit of rivaroxaban plus ASA is superior to that provided by ASA
alone.
The Council member who voted in the negative was concerned that the absolute
difference between the two options was quite small, and there is no certainty that the
benefit would be maintained over a lifetime. In addition, given the inclusion criteria in
the COMPASS trial, the bleeding risk of patients in the trial is likely substantially lower
than that of patients in the real world.
The Council unanimously judged that the evidence was inadequate to demonstrate a
superior net health benefit of rivaroxaban plus ASA compared to that provided by ASA
as part of dual antiplatelet therapy (DAPT) with an oral P2Y12 inhibitor (e.g., ticagrelor or
clopidogrel) in patients with cardiovascular disease. Given the lack of head-to-head
trials and the different ways that bleeding was measured across trials, panelists
concluded there was not yet evidence to make a determination on rivaroxaban plus ASA
compared to DAPT.
c) Is the evidence adequate to demonstrate that the net health benefit of icosapent ethyl
added to optimal medical management (including statin therapy) is superior to that
provided by optimal medical management (including statin therapy) alone?
A majority of the Council determined that the evidence was adequate to demonstrate a
net health benefit of icosapent ethyl added to optimal medical management (including
statin therapy).
The Council members who voted in the negative expressed concerns regarding the
unexpected results in the REDUCE-IT trial compared to the many previous studies
investigating fish oil that showed no benefit to cardiovascular health, and questioned
whether these results could be replicated. One council member argued that the
potential benefit of icosapent ethyl is relatively small when considering absolute effects.
The other dissenting voter was concerned about the confounding factor of mineral oil
being used in the placebo arm and potentially inflating the results. Council members did
discuss the specific DHA and EPA composition of icosapent ethyl as it compares with
other fish oil interventions currently on the market, as this composition may be
responsible for the divergent results produced by the REDUCE-IT trial. However, they
agreed that additional study is required to gain any certainty on this question.
d) Does treating patients with rivaroxaban plus ASA offer one or more of the following
potential “other benefits or disadvantages” compared to ASA alone? (Select all that
apply).
This intervention will significantly reduce caregiver or broader family burden. 1/11
This intervention offers a novel mechanism of action or approach that will allow 6/11
successful treatment of many patients for whom other available treatments have
failed.
This intervention will have a significant impact on improving patients’ ability to 1/11
return to work and/or their overall productivity.
There are other important benefits or disadvantages that should have an important No vote
role in judgements of the value of this intervention.
Approximately half of the council judged that treating patients with rivaroxaban plus
ASA offers a novel mechanism of action or approach that will allow successful treatment
of many patients for whom other available treatments have failed. One Council member
felt that treating patients with rivaroxaban plus ASA will significantly reduce caregiver or
broader family burden, and one member voted that it will have a significant impact on
improving patients’ ability to return to work and/or their overall productivity. Prior to
voting, one Council member reiterated that, given the inclusion criteria in the COMPASS
trial, the bleeding risk of patients in the trial is likely substantially lower than that of
patients in the real world. The Council decided that this issue pertains to generalizability
and clinical effectiveness and does not represent an important disadvantage that should
have an important role in judgements of the value of this intervention. Another council
member mentioned that rivaroxaban’s introduction to the market could increase the
decision-making burden for patients and caregivers, as it is a potential addition to
patients’ already long and complex list of drug therapies. However, the Council agreed
that this is not a disadvantage specific to rivaroxaban plus ASA. No other important
benefits or disadvantages were raised, and the council did not vote on the final
question.
e) Does treating patients with icosapent ethyl offer one or more of the following
potential “other benefits or disadvantages” compared to optimal medical
management (including statin therapy) alone? (Select all that apply).
This intervention will significantly reduce caregiver or broader family burden. 0/11
This intervention offers a novel mechanism of action or approach that will allow 7/11
successful treatment of many patients for whom other available treatments have
failed.
This intervention will have a significant impact on improving patients’ ability to 0/11
return to work and/or their overall productivity.
There are other important benefits or disadvantages that should have an important No vote
role in judgements of the value of this intervention.
f) Are any of the following contextual considerations important in assessing the long-
term value for money of rivaroxaban plus ASA? (Select all that apply).
This intervention is intended for the care of individuals with a condition of 6/11
particularly high severity in terms of impact on length of life and/or quality of life.
This intervention is intended for the care of individuals with a condition that 6/11
represents a particularly high lifetime burden of illness.
There is significant uncertainty about the long-term risk of serious side effects of this 9/11
intervention.
There is significant uncertainty about the magnitude or durability of the long-term 9/11
benefits of this intervention.
There are additional contextual considerations that should have an important role in N/A
judgements of the value of this intervention.
This intervention is intended for the care of individuals with a condition of 6/11
particularly high severity in terms of impact on length of life and/or quality of life.
This intervention is intended for the care of individuals with a condition that 6/11
represents a particularly high lifetime burden of illness.
There is significant uncertainty about the long-term risk of serious side effects of this 5/11
intervention.
There is significant uncertainty about the magnitude or durability of the long-term 7/11
benefits of this intervention.
There are additional contextual considerations that should have an important role in No vote
judgements of the value of this intervention.
T
As described in ICER’s value assessment framework, questions on long-term value for money are
subject to a value vote when incremental cost-effectiveness ratios for the interventions of
interest are between $50,000 and $175,000 per QALY in the primary “base-case” analysis. The
base-case estimates of the cost per QALY for both rivaroxaban + ASA and icosapent ethyl are
below the lower end of this range, and therefore the treatment is deemed “high long-term
value for money” without a vote unless the CEPAC determines in its discussion that the Evidence
Report base-case analysis does not adequately reflect the most probable incremental cost-
effectiveness ratio for either treatment.
ICER’s value assessment framework also describes that the CEPAC does not take Long-Term
Value For Money votes on treatments for which the evidence is considered inadequate during
the Clinical Vote. Such is the case for rivaroxaban + ASA versus DAPT therapy. Thus, no Value
vote was taken for rivaroxaban + ASA versus DAPT therapy (e.g. clopidogrel).
The roundtable discussion was facilitated by Dr. Steven Pearson, MD, MSc, President of ICER.
The main themes and recommendations from the discussion are organized by audience and
summarized below.
Payers
Although subgroups in trials of rivaroxaban were comparable to some trial populations in which
DAPT was evaluated, looking at these subgroups limited the population size and increased
imprecision in results. Additionally, bleeding outcomes were reported differently and were not
comparable. ICER concluded the evidence was insufficient to compare the net benefits of
rivaroxaban and DAPT.
Other considerations for key prior authorization criteria for rivaroxaban are shown below:
a. Severity of disease: The FDA indication for rivaroxaban allows for treatment in a
broader population than the high-risk patients enrolled in COMPASS, yet there is no
strong evidence-based approach to defining a narrower set of eligibility criteria for
coverage.
b. Bleeding risk: Patients at high risk of major bleeding were excluded from the COMPASS
trial of rivaroxaban. Payers might consider instituting coverage criteria requiring
clinicians to attest that patients have not had a prior major bleed and/or are not
currently at high risk for future bleeds. However, balancing bleeding risk with CV event
Provider Criteria:
2. Icosapent ethyl has not yet received FDA approval and therefore the specific language of
the label is unknown. While awaiting the FDA decision, payers should consider parameters of
coverage criteria related to the eligibility criteria of the pivotal trial: a) definition of risk for
coronary artery disease; b) concurrent use of statins; and c) triglyceride level of 135-499
mg/dL.
a. Definition of risk of CAD: Patients in the REDUCE-IT trial were required to either have
established CVD or be 50 or older with diabetes and at least one additional risk factor.
Many primary prevention patients would have a constellation of risk factors creating a
similar risk to that in the primary prevention cohort of the trial, and the evidence does
not strongly support the use of the specific trial criteria around risk. Payers may wish to
consider coverage criteria based on total risk rather than based on the trial criteria.
b. Concurrent use of statins: The REDUCE-IT trial required patients to be on a stable dose
of a statin and to have an LDL-cholesterol level of 41-100 mg/dL. Given uncertainties
around the mechanism of benefit of icosapent ethyl and whether it would be effective in
patients not receiving statins, payers may consider requiring that patients be taking
statin therapy when prescribed icosapent ethyl. Payers face a challenging situation for
patients who are statin intolerant—they could limit eligibility, or they could use this as
an opportunity to get patients on a statin, since many patients felt to be statin
“intolerant” are able to take statins with appropriate clinical support.
c. Triglyceride level greater than 135: The REDUCE-IT trial did not suggest that the
benefits of icosapent ethyl were related to baseline triglyceride level, and other
evidence has also suggested that therapies that reduce triglycerides do not necessarily
reduce CV risk. As such, there is no strong reason to believe that icosapent ethyl is more
effective at reducing CV risk for patients with triglyceride levels meeting the entry
criteria for the trial. While payers could decide to limit icosapent ethyl coverage to
match the trial eligibility criteria, if the FDA label does not include a triglyceride level
requirement, then plans may choose also not to have a criterion related to triglyceride
level.
3. Clinicians, when thinking about the apparent benefit of rivaroxaban in the clinical trial,
should remember that patients at high risk of bleeding were excluded.
Clinicians should individualize decisions about adding treatments that decrease CV risk but
increase risk of bleeding based on patients’ individual risks for these events. Patients at high
risk of bleeding are likely to have a different net benefit from what was seen in the COMPASS
trial of rivaroxaban.
Patients with CVD are already treated with many medications each with their own regimens and
side effects. Medications include statins, aspirin or DAPT, angiotensin-converting-enzyme (ACE)
inhibitors, beta blockers, and potentially many more medications for comorbidities such as
diabetes. In this milieu, adding one or two additional therapies may be overwhelming for
patients. Shared decision making and patient support through education, caregivers, and
potentially the use of health coaches may assist in mitigating the cognitive and emotional
burden on patients from having so many therapies to manage.
5. Develop a decision algorithm and/or tool for clinicians to use in determining the most
appropriate additive therapies to consider for a given patient.
In addition to the therapies evaluated in this report, treatments that can be considered for
residual CV risk include PCSK9 inhibitors, GLP-1 receptor agonists, and SGLT-2 inhibitors, among
others. There is overlap in the populations eligible for many of these therapies, and evidence-
based guidance around how to order considerations of these treatments for different patients
could standardize decision making and improve outcomes.
6. Ensure that any clinical guideline statements regarding rivaroxaban clearly warn against
assuming a class effect for direct oral anticoagulants.
While there are other direct oral anticoagulants (DOACs) available on the market, none
currently share rivaroxaban’s indication for prevention of cardiovascular events. The DOACs
also vary significantly in terms of dosing, and an observational study conducted in a Medicare
population suggests that the benefit-risk profile of these agents also differs when used for
stroke prevention in atrial fibrillation.112 Clinical societies should therefore direct clinicians to
consider only low-dose rivaroxaban for cardioprotection until similar evidence is available for
other DOACs.
Given the nature and findings of REDUCE-IT, payers may require patients to be on statin therapy
concurrently with icosapent ethyl. Yet many patients, if not strictly statin-intolerant, are
unwilling to take statins, and such a requirement might exacerbate this problem and prevent
some patients from receiving what could be a promising intervention. The manufacturer should
conduct additional clinical trials to assess the clinical performance of icosapent ethyl in patients
not receiving statins.
8. Ensure that future trial recruitment reflects the demographics of the CVD population.
COMPASS and REDUCE-IT were large, multicenter clinical trials, yet trial patients were not
reflective of the CVD population at large in important ways. For example, African Americans are
35% more likely to develop CVD than their white counterparts113 and have rates of stroke that
are twice as high.114 Yet only 1% of COMPASS participants were black. Enrollment of more
representative CVD populations will not only increase generalizability but can also potentially
provide reassurance that treatment effects persist across appropriately sized and pre-specified
subgroups.
Regulators
9. The FDA, manufacturers, and the clinical research community should work to solidify a
common, single, outcomes definitions for key outcomes -- such as major bleeding -- so
clinicians and patients have the information they need to make informed decisions.
As noted in the report and discussed during the roundtable, standard definitions of key
outcomes such as major bleeding have been developed, yet they have been modified to such an
extent that formal indirect comparisons of results from clinical trials of competing treatment
options were not possible. This represents a disservice to patients and clinicians, who need to
understand how to best weigh the risks and benefits of the alternatives available to them.
Given that these standard definitions exist, regulators, manufacturers, and the research
community should come together to identify a core outcome definition that can be used across
trials and treatments.
Researchers
10. Researchers should develop explicit head-to-head evidence of the comparative benefits
and risks of rivaroxaban + ASA versus dual antiplatelet therapy in patients who have
completed an initial course of DAPT (12-30 months).
There is an important need for head-to head comparative analyses of DAPT and rivaroxaban +
ASA. Prolonged use (i.e., 12-30 months) of dual antiplatelet therapy (DAPT) after an MI is
currently standard clinical practice. After an initial course of DAPT, some patients may benefit
11. Researchers should conduct a real-world observational study to confirm the benefits of
icosapent ethyl.
The results of REDUCE-IT, while impressive, have not eliminated uncertainty regarding the
potential effects of the placebo composition in the trial, as well as the largely unimpressive
evidence from prior omega-3 studies. In addition, the FDA is unlikely to require a second
confirmatory clinical trial for this indication. A rigorous prospective observational study of
icosapent ethyl that had results consistent with those seen in the REDUCE-IT trial would help
alleviate concerns, while a conflicting result would suggest the need for a second randomized
trial.
****
This is the first ICER review of rivaroxaban and icosapent ethyl for CVD.
70 citations excluded
84 references assessed for 7 Population
eligibility in full text 7 Intervention
35 Outcome
21 Study Type
14 total references
related to 4 RCTs
1 RCT of Rivaroxaban
1 RCT of Icosapent Ethyl
2 RCTs of DAPT*
3 references included in
quantitative synthesis
1 Rivaroxaban
2 DAPT*
*DAPT: dual antiplatelet therapy
Canadian Agency for Drugs and Technologies in Health (CADTH) Common Drug Review:
Rivaroxaban (Xarelto) 2019
Although Health Canada approved rivaroxaban + ASA for CAD with or without PAD, CADTH
recommended that rivaroxaban be reimbursed only for patients with concomitant CAD and PAD.
CADTH’s reimbursement recommendation was informed by a review of the COMPASS trial,21 a
manufacturer-provided NMA comparing rivaroxaban to DAPT, and a manufacturer-submitted cost-
utility analysis. Based on this analysis, CADTH concluded that rivaroxaban + ASA is cost-effective in
patients with concomitant CAD and PAD compared with ASA alone, at an incremental cost-
effectiveness ratio of Can$17,764 per QALY gained. Reviewers noted a few gaps in the available
evidence, including uncertainties about the generalizability of the COMPASS trial results, the long-
term efficacy and safety of rivaroxaban + ASA, the optimal duration of therapy, whether
rivaroxaban + ASA improves health-related quality of life or daily function, and the comparative
efficacy and safety of rivaroxaban + ASA versus DAPT.
NICE: Rivaroxaban for Preventing Major Cardiovascular Events in People with Coronary or
Peripheral Artery Disease [ID1397], Expected publication date August 28, 2019
NICE recommends the use of rivaroxaban plus aspirin within its marketing authroitization, as an
option for preventing atherothrombotic events in adults with coronary artery disease or
symptomatic peripheral artery disease who are at high risk for ischemic events. Additionally, NICE
recommends assessing a person’s risk for bleeding before considering rivaroxaban.
Canadian Agency for Drugs and Technologies in Health (CADTH) Common Drug Review: Icosapent
Ethyl [SR0619-000], Review temporarily suspended.
CADTH is currently evaluating the clinical and cost effectiveness of icosapent ethyl for the
prevention of ischemic events in statin-treated patients with elevated triglyceride levels with CVD
or at high risk for CVD, however the review has been temporarily suspended pending receipt and
review of information.
At baseline, the mean age across studies was 64.0 years, 23.6% were female, 83.9% underwent or
had a history of PCI, and 29.6% had diabetes.115 Results from the meta-analysis showed treatment
with DAPT reduced the risk of the primary composite endpoint (cardiovascular death, MI, or stroke)
by 22% compared to ASA alone (6.4% vs. 7.5%, respectively, risk ratio [RR] 0.78; 95% CI: 0.67 to
0.90; p=0.0001). Patients treated with DAPT also experienced a significant reduction in
cardiovascular death (RR 0.85; 95% CI: 0.74 to 0.98; p=0.03), MI (RR 0.70; 95% CI: 0.55 to 0.88;
p=0.003), and stroke (RR 0.81; 95% CI 0.68 to 0.97; p=0.02).
The six trials measured the incidence of major bleeding using a variety of definitions; three trials
used the TIMI definition, two trials used the GUSTO definition, and one trial used the STEEPLE
definition. Nevertheless, the investigators conducted a meta-analysis of major bleeding endpoints
and found treatment with DAPT significantly increased the risk of major bleeding compared to ASA
alone (1.9% vs. 1.1%; RR: 1.73; 95% CI: 1.19 to 2.50, p=0.004), but not fatal bleeding (0.14% vs
0.17%; RR 0.91; 95% CI: 0.53 to 1.58; p=0.75) or intracranial hemorrhage (0.41% vs. 0.31%; RR 1.34;
95% CI: 0.89 to 2.02; p=0.17).
Arm 6: ASA +
ticagrelor → ASA +
rivaroxaban
NCT02926027 Exclusion
• A contraindication to fish or
fish oils
• Use of non-study lipid
altering medications or
supplements
• Bleeding disorder
• Uncontrolled hypertension
• MI, stroke, life-threatening
arrhythmia within prior six
months
Exclusion:
• Acute coronary syndrome or
coronary revascularization
within prior three months
• Planned coronary
revascularization or
angiography
• Inadequately controlled
diabetes mellitus
• Active bleeding or bleeding
tendency
Exclusion:
• Use of fibrates, bile acid
sequestrants, or niacin
within four weeks
Sources: www.ClinicalTrials.gov (NOTE: studies listed on site include both clinical trials and observational studies); UMIN Clinical Trials Registry (UMIN-CTR)
https://www.umin.ac.jp/ctr/index.htm
US Preventive Services Task Force (USPSTF) Criteria for the Quality Assessment
of Clinical Trials and Comparative Cohort Studies
Good: Meets all criteria: Comparable groups are assembled initially and maintained throughout the
study; reliable and valid measurement instruments are used and applied equally to the groups;
interventions are spelled out clearly; all important outcomes are considered; and appropriate
attention is paid to confounders in analysis. In addition, intention to treat analysis is used for RCTs.
Fair: Studies were graded "fair" if any or all of the following problems occur, without the fatal flaws
noted in the "poor" category below: Generally comparable groups are assembled initially but some
question remains whether some (although not major) differences occurred with follow-up;
measurement instruments are acceptable (although not the best) and generally applied equally;
some but not all important outcomes are considered; and some but not all potential confounders
are addressed. Intention to treat analysis is done for RCTs.
Poor: Studies were graded "poor" if any of the following fatal flaws exists: Groups assembled
initially are not close to being comparable or maintained throughout the study; unreliable or invalid
measurement instruments are used or not applied equally among groups (including not masking
outcome assessment); and key confounders are given little or no attention. For RCTs, intention to
treat analysis is lacking.
Note that case series are not considered under this rating system – because of the lack of
comparator, these are generally considered to be of poor quality.
We used the ICER Evidence Rating Matrix (see Figure D1) to evaluate the evidence for a variety of
outcomes. The evidence rating reflects a joint judgment of two critical components:
The magnitude of the difference between a therapeutic agent and its comparator in “net health
benefit” – the balance between clinical benefits and risks and/or adverse effects AND
The level of certainty in the best point estimate of net health benefit.55
Ticagrelor + ASA
PEGASUS-TIMI 54 was a Phase III randomized controlled trial that evaluated the efficacy and safety
of DAPT with ticagrelor (90 mg or 60 mg) + ASA compared to ASA alone.15 Patients were eligible to
participate if they had had a MI one to three years before enrollment, were at least 50 years of age,
and had at least one additional risk factor, including ≥65 years of age, diabetes mellitus, a second
prior MI, multivessel CAD, or chronic renal dysfunction. Eligible patients were randomized 1:1:1 to
receive 90 mg of ticagrelor orally (n=7050), 60 mg of ticagrelor orally (n=7045), or placebo
(n=7067); all patients received 75-150 mg of ASA daily. At baseline, patients had a mean age of 65,
32% had diabetes, 60% had multivessel CAD, and the median time since the qualifying MI was 1.7
years. Background medications at baseline included statins (93%), beta-blockers (82%), and ACE
inhibitors or ARBs (81%). Patients were followed for a median of 33 months (IQR 28-37).15
The two ticagrelor doses (90 mg and 60 mg) significantly reduced the risk of the composite primary
endpoint of cardiovascular death, MI, or stroke. In a pooled analysis of both ticagrelor doses versus
placebo, ticagrelor reduced the risk of the composite endpoint by 16% (HR: 0.84; 95% CI (0.76 to
0.94); p=0.001); results for each dose arm compared to ticagrelor are reported in Table D6. 15 When
stratified by time from MI (<2 years vs. ≥2 years), patients whose MI occurred <2 years before
enrollment appeared to derive a greater benefit from ticagrelor (60 mg) than those who had a MI
≥2 years prior to enrollment (p-value for interaction=0.09; Table D6); results for the 90 mg dose of
ticagrelor were similar in these subgroups.15,16
The PEGASUS trial’s primary safety endpoint was Thrombolysis in Myocardial Infarction (TIMI)
major bleeding, defined as intracranial bleeding, clinically overt signs of hemorrhage (drop in
hemoglobin ≥5 g/dL or fall in hematocrit ≥15%), or a bleeding event that led to death within seven
days.15 Both doses of ticagrelor significantly increased the rate of major bleeding (90mg: 2.6%;
60mg: 2.3%) versus ASA (1.1%; p<0.001 for both comparisons, see Table D6). Bleeding led to the
discontinuation of study drug in significantly more patients treated with ticagrelor (7.8% and 6.2%
for the 90 mg and 60 mg arms, respectively) versus ASA (1.5%; p<0.001 for both comparisons).
Clopidogrel + ASA
CHARISMA was a Phase III, multicenter, double-blind study evaluating the efficacy and safety of 75
mg of clopidogrel + ASA (75-162 mg/day; n=7802) versus ASA alone (n=7801).17 Patients were
eligible for the study if they were at least 45 years of age and had multiple atherothrombotic risk
factors, documented coronary disease, cerebrovascular disease, or symptomatic PAD. At baseline,
the median age of patients was 64, 42% had diabetes, 78% had documented vascular disease, and
34% had a prior MI. Background medications at baseline included statins (77%), beta-blockers
(55%), ACE inhibitors (46%), and ARBs (26%). Patients were followed for a median of 28 months.
The CHARISMA trial’s primary safety endpoint was Global Utilization of Streptokinase and Tissue
Plasminogen Activator for Occluded Coronary Arteries (GUSTO)-defined severe bleeding; fatal
bleeding events, intracranial hemorrhages, or bleeding that caused hemodynamic compromise
requiring blood or fluid replacement, inotropic support, or surgical intervention were considered
severe.17 The rate of severe bleeding was 1.7% for clopidogrel + ASA versus 1.3% for ASA alone
(relative risk [RR] 1.25 (95% CI 0.97 to 1.61; p=0.09); moderate bleeding, i.e., bleeding that led to a
transfusion and a statistically significant increase in moderate bleeding but did not meet the severe
definition, occurred in 2.1% of the clopidogrel + ASA arm and 1.3 % of the ASA alone arm (RR: 1.62;
95% CI 1.25 – 2.08; p<0.001).
Riv +
Clop +
ASA
ASA
ASA
Tic +
ASA
The cost per evLYG considers any extension of life at the same “weight” no matter what
treatment is being evaluated. Below are the stepwise calculations used to derive the evLYG.
i) First, we attribute a utility of 0.851, the age- and gender-adjusted utility of the
general population in the U.S. that are considered healthy.118
ii) For each cycle (cycle i) in the model where using the intervention results in
additional years of life gained, we multiply this general population utility with the
additional life years gained (ΔLYG).
iii) We sum the product of the life years and average utility (cumulative LYs/cumulative
QALYs) for cycle i in the comparator arm with the value derived in step 2 to derive
the equal value of life years (evLY) for that cycle.
iv) If no life years were gained using the intervention versus the comparator, we use the
conventional utility estimate for that cycle i.
v) The total evLY is then calculated as the cumulative sum of QALYs gained using the
above calculations for each arm.
vi) We use the same calculations in the comparator arm to derive its evLY.
vii) Finally, the evLYG is the incremental difference in evLY between the intervention
and the comparator arms.
A video recording of all comments can be found here, beginning at minute 01:28:55. Conflict of
interest disclosures are included at the bottom of each statement for each speaker who is not
employed by a pharmaceutical manufacturer.
On behalf of my colleagues at Amarin Pharma, Inc, thank you for the opportunity to submit
comments for the record following the September 26, 2019 Midwest Comparative Effectiveness
Public Advisory Council (CEPAC) Institute for Clinical and Economic Review’s (ICER) Public
Meeting on additive therapies for cardiovascular (CV) disease. We thank ICER and the Midwest
CEPAC for the opportunity to meet with experts in the field, the public, and fellow
manufacturers, and to share Amarin’s position on ICER’s Draft Evidence Report.
Amarin takes very seriously its mission of developing innovative, life-saving, and quality-of-life
enhancing medicines for patients and in conducting rigorous, high-quality science to clearly
evaluate their benefits.
While statin use and optimal medical management have reduced cardiovascular risk and
improved patient health outcomes over the last few decades, substantial residual cardiovascular
risk remains. This residual risk represents an important unmet medical need for patients and
accounts for significant health care and economic burden.
With regard to ICER’s economic analysis, Amarin believes that it’s essential to use all of the
evidence from REDUCE-IT in the economic analysis, including (1) using all five components of
the prespecified primary endpoint in the Markov model base-case analysis and (2) using total
event data. We believe it is beneficial to use a patient-level, microsimulation approach to
modeling as well as incorporating more recent US national cost data for cardiovascular events.
and should be included in the base-case cost-effectiveness and budget impact analyses due to
the high quality of this scientific evidence.
On behalf of Amarin, we again thank ICER and the Midwest CEPAC for the opportunity to submit
comments and to be part of an open dialogue around the clinical and economic benefits of
icosapent ethyl to patients, payers, and society. Amarin is dedicated to working with relevant
stakeholders to ensure access for eligible and appropriate patients to innovative, life-saving, and
quality-of-life-enhancing therapies such as icosapent ethyl.
Why am I here? Eighteen years ago my life changed. In my early 40’s I was busy raising three
boys, exercising, eating healthy, just living a busy life, however my heart had other ideas. After
several trips to my GP, complaining of being exhausted, having numbness in my left arm and
feeling short of breath, I was diagnosed with Coronary Artery Disease. I had 99% blockage in my
LAD. Angioplasty was preformed unexpectedly the day of my stress test. Five months later
stents had closed, bypass surgery followed by several months of rehab all while adding on to our
home. My life, my family’s life had changed.
Why am I here? As one of the first women to participate in WomenHeart’s Science and
Leadership Symposium, I learned about the science of my disease as well as understanding that
it was also a disease that touches your confidence, emotional balance, and depth of
understanding for what I am now living with. Understanding that I would forever be on
medications that might cause side effects, cause damage to other organs, make a difference in
so many ways other than how it helps my heart was just the start. Through WomenHeart I
learned the value of participating in drug trials and research studies. With patient help, the
research might be of value to so many and not just me.
Why am I here? In 2005 just as we are getting ourselves settled after my diagnosis, my husband
is diagnosed with a meningioma. His easy surgery was anything but. After a month in the
hospital and weeks in a rehab center learning to walk, swallow, and talk again, our home
became a full time health care center. I was no longer the patient I had become the caregiver.
The navigation of the medical world was truly an eye opening experience. My husband endured
10 years of medical chaos and disconnected care. We quickly learned the ropes and had the
where with all to be able to seek additional advice. Our nonstop research and inquiring about
treatments or to try new drugs and explore how we could keep David with us longer kept us
going. We sought out holistic treatments, acupuncture, therapeutic massages, exercise and
meditation all in the name of trying to make a difference.
drugs, dose adjustments, lack of sleep or being constantly tired. Stomach problems, headaches,
and weight gain, long-term effects. The drugs caused emotional ups and down’s. Remembering
to take them at the right time. The expense.
The effects of the variety of drugs my husband was given changed his personality, made him
grumpy, made a difference on what he could and wanted to eat. In so many ways it controlled
his life. Every time he went to the doctor there were new prescriptions. What do we do with the
old medicine we have hardly used? How does someone who is ill keep track of when they are to
take what drug? How do patients know if drug A or B causing the side effect? How does a drug
interact with other meds? How will it help me?
I am here today to make a small contribution to something I would hope helps others navigate
the world of medical diagnosis and the drugs we take to make us feel better.
Taylor Kelly
Law Clerk at DCBA Law & Policy, Policy Advisor at Aimed Alliance
Aimed Alliance is pleased that the Institute for Clinical and Economic Review (ICER) has deemed
rivaroxaban and icosapent ethyl to be cost effective. Yet, we remain concerned that its analysis
and recommendations will impact patient access by encouraging the use of restrictive policies
on plan formularies, such as prior authorization and step therapy, to control costs. Such policies
can be unethical and inconsistent with standards of care, interfere with the patient-practitioner
relationship, and result in significant delays to prescribed treatments.
Moreover, ICER’s analysis does not appear to incorporate several important considerations into
its potential budget impact analysis and value-based benchmark prices, such as data that
represents the patient perspective; data from two of the REDUCE-IT trial’s primary endpoints –
coronary revascularization and hospitalization; and adequate data about the risk of subsequent
adverse events. We believe that the exclusion of such pertinent data does not adequately
capture the full value that these therapies provide to patients.
Finally, Aimed Alliance reiterates its long-standing opposition to the use of QALYs. QALYs can
result in inappropriate health care rationing and discrimination based on age and health status,
unfairly favoring younger and healthier populations. QALYs put a price tag on the value of a
human life that merely reflects the individual’s diagnosis and deems those with chronic,
debilitating, and rare conditions, such as cardiovascular disease, as being worth less than the
rest of us.