AMF and AHS Submit Public Comment to ICER

ICER weighs the value of CGRP-inhibitors for migraine prevention

The Institute for Clinical and Economic Review (ICER) is currently investigating the effectiveness and value of Calcitonin Gene-Related Peptide (CGRP) inhibitors for preventing episodic or chronic migraine. Earlier this year, the AMF Board of Directors provided ICER with patient perspectives and information about the migraine experience to inform the report.

During the recent open comment period, the AMF worked with its sister organization, the American Headache Society, to provide feedback on ICER’s Draft Evidence Report (DER). After review of the report, our organizations had several remaining concerns over the current quantitative analysis. Our public comment response covered the following points:

  • Patient values should be the top consideration in evaluation.
  • The DER does not fairly account for indirect costs and societal burden of migraine.
  • Lack of long-term data undervalues new migraine treatments.
  • The emphasis on “therapeutic gain” values from placebo-controlled trials may lead to underestimation of efficacy.
  • Lack of consideration of discontinuation of migraine treatments overestimates costs.

The AMF and AHS jointly concluded that improved migraine treatments are imperative and that the migraine community has a collective responsibility to help patients in need.

Download our complete public comment to ICER here.