Does it help that efficacy has been proven once we start discussing (added) benefit?

Abstract

Since the introduction of benefit assessment to support reimbursement decisions in Germany there seems to be the impression that totally distinct methodology and strategies for decision making would apply in the field of drug licensing and reimbursement. In this article, the position is held that, while decisions may differ due to differing mandates of drug licensing and reimbursement bodies, the underlying strategies are quite similar. For this purpose, we briefly summarize the legal basis for decision making in both fields from a methodological point of view, and review two recent decisions about reimbursement regarding grounds for approval. We comment on two examples, where decision making was based on the same pivotal studies in the licensing and reimbursement process. We conclude that strategies in the field of reimbursement are (from a methodological standpoint) until now more liberal than established rules in the field of drug licensing, but apply the same principles. Formal proof of efficacy preceding benefit assessment can thus be understood as a gatekeeper against principally wrong decision making about efficacy and risks of new drugs in full recognition that more is needed. We elaborate on the differences between formal proof of efficacy on the one hand and the assessment of benefit/risk or added benefit on the other hand, because it is important for statisticians to understand the difference between the two approaches.