Comments on Draft Scoping Document for Severe Asthma Therapies

As noted in ICER’s scoping document, uncontrolled asthma is a substantial problem that, according to the Centers for Disease Control and Prevention, afflicts 38.4 percent of children with asthma and 50 percent of adults with asthma. It is not clear from the scoping document, however, that ICER will adequately incorporate into its analysis several key issues associated with uncontrolled asthma.

These issues include:

(1) The fundamental differences among alternative long-term asthma control medicines

(2) Both the quantifiable and unquantifiable costs that uncontrolled asthma imposes on patients

(3) The income and demographic characteristics of the disease.

IfPA requests the following as ICER evaluates biologic medicines for long-term asthma control.

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