Problems in Pharmacoeconomic Analyses—Reply

To the Editor: The pharmaceutical industry in Australia is certainly aware that pharmacoeconomic analyses are complex and difficult to evaluate, as stated in the article by Dr Hill and colleagues,¹ but we disagree with its conclusions. It is also not obvious from the article that at least 2 of the authors were involved previously in more than 1 stage of the analysis of each submission. This brings their perspective into question.

As pointed out in the Editorial by Drs Rennie and Luft,² governments have biases, too. Kassirer and Angell³ have pointed out that cost-effectiveness analyses share many of the features of a review article. Both allow numerous judgment calls by the analyst, all of which may be biased.

In determining the relevance of the highlighted problems, it would have been helpful for Hill et al to describe their relationship to the recommendation of the Pharmaceutical Benefits Advisory Commitee (PBAC). Although they list this information in their Table 1, the authors supply no data that would have put in perspective the "problems with the interpretation of pharmacoeconomic analyses" within the unique Australian system and their relevance to the reimbursement decision.

The PBAC has a strong preference for economic evaluations based on head-to-head randomized clinical trials,⁴ so it is not surprising that the authors found that 62% of submissions had "uncertainty" in the estimates of comparative clinical efficacy, and 28.5% had "modelling issues." The Australian pharmaceutical industry suggests that many of these uncertainties and issues are matters of interpretation or a reflection of the uniqueness of the Australian system in contrast to the global drug development environment.

The role of economic analysis is to assist the decision-making process, not to supply perfect data unique to the Australian system.