Pharmacoeconomics 2006; 24 (11): 1121-1131 1170-7690/06/0011-1121/$39.95/0 CONFERENCE PAPER 2006 Adis Data Information BV. All rights reserved. Information Created to Evade Reality (ICER) Things We Should Not Look to for Answers Stephen Birch1,2 and Amiram Gafni1 1 2 McMaster University, Hamilton, Ontario, Canada University of Manchester, Manchester, UK Abstract Cost-effectiveness analysis has been advocated in the health economics methods literature and adopted in a growing number of jurisdictions as an evidence base for decision makers charged with maximising health gains from available resources. This paper critically appraises the information generated by cost-effectiveness analysis, in particular the incremental cost-effectiveness ratio (ICER). It is shown that this ratio is used as comparative information on what are non-comparable options and hence evades the reality of the decision-maker’s problem. The theoretical basis for the ICER approach is the simplification of theoretical assumptions that have no relevance to the decision maker’s context. Although alternative, well established methods can be used for addressing the decision maker’s problem, faced with the increasing evidence of the theoretical and empirical failures of the cost-effectiveness approach, some proponents of the approach now propose changing the research question to suit the approach as opposed to adopting a more appropriate method for the prevailing and continuing problem. As long as decision makers are concerned with making the best use of available healthcare resources, cost-effectiveness analysis and the ICER should not be where we look for answers. Decision makers continue to struggle with the challenges of how to allocate whatever resources are made available for healthcare among the rapidly increasing number and range of possible ways of using those resources. Cost-effectiveness analysis (CEA) has been advocated in the health economics methods literature and adopted in a growing number of jurisdictions as an evidence base for decision makers charged with deciding whether to fund a particular intervention in the context of an objective of maximising health gains from available resources.[1-3] In this paper we critically appraise the information that is created by CEA, the incremental cost-effectiveness ratio (ICER). We first consider the calculation of the ICER and how it relates to the decision maker’s problem. We show that the ICER represents an attempt to provide comparative information on what are non-comparable (and therefore unreal) options and hence is irrelevant to, and evades the reality of, the decision maker’s problem. 1122 We then consider how information created in a way that evades the decision maker’s reality emerged as the recommended source of evidence for healthcare decision making. We show that the ICER approach is based on simplifying theoretical assumptions that have no relevance to the decision maker’s context. We briefly explain the appropriate approach for addressing the decision maker’s problem based on well established methods that have been presented in the literature over many years. Finally, we note that faced with increasing evidence of the theoretical and empirical failures of the CEA approach in addressing the basic decision-making problem, some proponents of CEA now propose changing the nature of the problem (i.e. reality) to suit the CEA method as opposed to adopting a more appropriate method for the prevailing and continuing real problem. 1. The Information Generated by Cost-Effectiveness Analysis The ICER is the analytical tool used in CEA to summarise information on the comparison of both costs and effects of two different interventions (usually a new intervention and the current intervention) for addressing a particular healthcare problem or patient group. Where the new intervention is more effective but not more costly, or where it is less costly but no less effective than the current intervention, no further consideration is required to establish the efficiency of allocating resources to the new intervention. Common sense is sufficient to determine that replacing the current intervention with the new intervention will increase benefits generated from available resources or release resources for other uses while maintaining benefits – either of which represents an unambiguous increase in efficiency. However, where incremental costs and effects are in the same direction (including the more typical case of new interventions that produce greater effects but only with an increase in costs) the implications for the efficient use of resources are less clear. 1 Birch & Gafni The ICER is given by the ratio of the betweenintervention difference in costs, i.e. incremental costs (measured in monetary units), and the between-intervention difference in effects, i.e. incremental effects (often measured in QALYs), and is expressed as the cost per additional unit of effect, for instance cost per QALY. It is argued that by comparing the ICER, or price per additional QALY, of the intervention under consideration with an ICER threshold associated with their own subjective assessment, or in relation to the ICER of other interventions, decision makers concerned with maximising health gain from available resources can determine whether the proposed intervention represents ‘value for money’.[1-3] Unfortunately, the ICER is of no use whatsoever in determining whether implementing the new intervention represents an efficient use of resources. Although dividing incremental costs by incremental effects produces a price per QALY, this does not mean that any number of QALYs (large or small) can be purchased at this price. On the contrary, this means that for an additional investment given by the incremental cost, additional health gains equal to the incremental effects could be produced. Thus, the ICER simply represents the average cost (or price) of these additional health gains. For example, Ubel et al.[4] cites a US study that estimated the ICER for sildenafil (the Viagra 1 drug) to be $US11 000 per QALY. But this does not mean that a decision maker can increase total health gain by one QALY for an additional $US11 000 to be found from existing expenditures, either within or outside the healthcare system. On the contrary, introducing sildenafil to a formulary would require substantially more resources (again to be found from existing expenditures either within or outside the healthcare system) in order to cover the cost of the drug to all those individuals eligible to receive it. In order to understand this better it is helpful to consider applying the same cost-effectiveness reasoning to an example of grocery shopping. The use of trade names is for product identification purposes only and does not imply endorsement. 2006 Adis Data Information BV. All rights reserved. Pharmacoeconomics 2006; 24 (11) ICER: Information Created to Evade Reality 2. Illustrating the Problem: Cost Effectiveness in Grocery Shopping The problem facing the decision maker corresponds to that of the shopper in the grocery store wondering which cornflakes packet to purchase from among the different sizes and brands of cornflakes available. Many grocery stores provide additional information in terms of a comparative price per standard unit (e.g. 100g of cornflakes). Imagine where this would leave the shopper if that were the only information provided on the different products. The temptation might be to choose the best ‘value for money’ or lowest ‘cost per 100g of cornflakes’. However, this leaves the shopper ignorant of how much this product costs and hence what other groceries (e.g. eggs, milk, flour, bread, etc.) have to be forgone to accommodate this purchase of cornflakes into the grocery budget. Imagine the shopper’s surprise when, on arrival at the checkout, he discovers that the cornflakes product, chosen because of its particularly low price per 100g, involves a quantity of 1000kg at a cost that represents more than the entire household budget for groceries for a month. Basing decisions only on the average price per unit has a tendency to increase total expenditures on that product. The shopper cannot make sensible decisions without information on the total cost and total content of each different cornflakes product (as well as knowledge of the available budget for groceries and the total costs and contents of all other grocery products on the shopping list). Dividing costs by content to generate a comparative ‘value for money’ indicator across products involves the loss of important information to the shopper. Where the price per package of the different cornflakes products differs, the different products are not directly interchangeable and hence cannot be assessed in terms of the average cost per 100g. An alternative way of looking at this is to consider the inverse of the ICER, in other words, the incremental effectiveness cost ratio or IECR. Instead of providing a cost per 100g of cornflakes, it now provides a measure of quantity of cornflakes per dollar expenditure. So products with the lowest cost per 100g of cornflakes would produce the great 2006 Adis Data Information BV. All rights reserved. 1123 est quantity of cornflakes per dollar. In other words, this represents a measure of the average rate of return on investment (in this case, investment in cornflakes purchases). As with the cost per 100g of cornflakes measure, this provides a comparative measure across different cornflakes products. But since the different products are non-interchangeable, i.e. they involve different levels of investment, the comparative measure is no use in determining efficient investment decisions. In a further example, how many of us have been attracted by adverts in in-flight magazines for high interest rates offered by offshore banks before the small print reveals a required minimum investment of say $US100 000? If the balance in my current onshore account is only $US20 000, a comparison of interest rates (or average rates of return) between the two investment options is meaningless – the plans are not interchangeable. I would need to forgo far more than my current on-shore account (e.g. also sell my $US30 000 car and take out an extra $US50 000 mortgage on my house) to be able to invest at the high average rate of return in the offshore account. It should be clear by now that the comparison of ICERs (or IECRs) as a basis for making investment decisions aimed at maximising health (or cornflakes) gains is only valid where the interventions being compared have identical total costs (i.e. the alternatives are truly interchangeable). But if the two alternatives have the same cost there is no need to calculate a ratio – common sense is again sufficient to determine that the intervention with the greater effectiveness represents the more efficient use of resources. However, it is not simply that calculating the ratio is unnecessary or unhelpful; in some situations it leads to interventions being adopted that prevent the maximisation of health gain from available resources occurring.[5] 3. Determining the Incremental Cost-Effectiveness Ratio (ICER) Threshold: The Silence of the λ Notwithstanding the problem of ‘comparing the non-comparable’ discussed in section 2, researchers Pharmacoeconomics 2006; 24 (11) 1124 and decision makers have persisted in using the ICER as an important tool in determining the efficiency of allocating resources to individual interventions by reference to a threshold ICER (commonly referred to as the λ value).[1-3,6,7] But if decision makers are to achieve their objectives of maximising health benefits from available resources, consideration needs to be given to how any chosen λ value (or range of values) relates to this stated objective. Claxton et al.[8] note that the maximisation of health benefits from available resources requires information on the shadow price of the decision maker’s budget constraint, which represents the marginal opportunity cost of available resources. Remarkably little attention has been given in the literature to how particular ICER thresholds are selected and, more importantly, how they relate to the opportunity cost considerations of the constrained maximisation problem facing the decision maker.[9] Consider the example of the UK National Institute for Health and Clinical Excellence (NICE),[2] the most widely discussed example of the institutionalisation of economics as a basis for healthcare decision making. The stated objective of the NICE guidelines is the maximisation of health gain from whatever resources are committed to the NHS in England and Wales. NICE specifies two different λ values, a lower threshold of £20 000 per QALY and a higher threshold of £30 000 per QALY. Interventions with ICERs below the lower threshold are judged primarily on their ICER value (i.e. other considerations are irrelevant, as the ICER value is sufficiently low to warrant that the intervention be adopted). Interventions with ICERs between the two thresholds are judged not exclusively on their ICER value but also on other factors (uncertainty, the innovative nature of the intervention, features of the condition and populations being treated, and the wider societal costs and benefits). In other words, although the ICER is above the lower threshold, these other factors might be sufficient to warrant adoption of the intervention. Finally, interventions with ICERs above the higher threshold require ‘increasingly strong’ justification beyond the ICER 2006 Adis Data Information BV. All rights reserved. Birch & Gafni value. In other words, these interventions are unlikely to warrant adoption, because the high ICER value would, except in very special circumstances, trump all other factors. No attempt is made to rationalise these chosen thresholds with the maximisation of health benefits from NHS resources. Instead, the approach of NICE is to consider ICER values of interventions that are currently funded by the NHS as ‘a legitimate reference’ for decision makers. Hence, if the NHS currently funds something with a higher ICER than the new intervention under consideration, then funding the new intervention would represent an improvement in efficiency, irrespective of how that new intervention is to be funded. The use by NICE of two different ICER thresholds further questions the ability of the approach to satisfy the objectives of the exercise. It probably represents more a case of a ‘sophisticated decision rule’[10] in which the ICER values are only one input into the decision-making process. Other inputs (uncertainty, innovative nature of the intervention, features of the condition and populations being treated, and the wider societal costs and benefits) are important to the decision-making process. However, no information is provided on how these considerations are to be incorporated into the sophisticated decision rule to be used to determine which interventions increase total health benefits from available NHS resources and which interventions do not. In the absence of any clear theoretical and/or empirical basis for the NICE thresholds, it is not surprising that alternative algorithms have been suggested. For example Rawlins and Culyer[11] acknowledge the arbitrary nature of the thresholds and argue that decisions are based on a case-by-case basis. “As the incremental cost effectiveness ratio increases, the likelihood of rejection on grounds of cost effectiveness rises.” However, no empirical or theoretical basis is provided for these authors’ assigned ranges of £5000–15 000 and £25 000–35 000 for the lower and upper thresholds. Williams[12] acknowledges that there is no practical way to determine the threshold and suggests instead “a bit of common sense.” He argues that in the UK there are Pharmacoeconomics 2006; 24 (11) ICER: Information Created to Evade Reality £18 000 of real resources per citizen to provide for all needs (e.g. food, shelter, transport) and suggests adopting this figure as the ICER threshold because “we could do it at the margin for few people without imposing great hardships on the bulk of the population but we could not do it for many.” No attempt is made to rationalise this threshold with the NICE objective of maximising total health gains from NHS resources, and no attention is given to dealing with ‘cost-effective’ interventions that relate to treating conditions with a prevalence that extends beyond ‘a few people’. Similar approaches in other jurisdictions also fail to provide any justification for the chosen ICER thresholds as means of maximising health gain from available resources.[9,13] For example, in 1992 Laupacis et al.[14] recommended thresholds of $Can20 000 per QALY and $Can100 000 per QALY for new interventions in Canada. When questioned on the basis of these thresholds, Laupacis admitted “we made them up.”[15] So, in the absence of applied research literature offering any clear explanation of how the chosen ICER thresholds help achieve the goal of benefit maximisation from available resources, what does the theoretical literature have to offer on what determines the ICER threshold for deciding whether a new intervention represents an efficient use of available resources? 4. The Theoretical Foundation of the Threshold ICER The origin of the ICER as a tool for determining whether an intervention represents an efficient use of available resources is found in Weinstein and Zeckhauser[16] (the WZ model). Using assumptions of perfect divisibility and constant returns to scale for all interventions, they show that total health benefits are maximised where: • all interventions are ranked from the lowest to the highest ICER and selected in descending order until available resources are exhausted (league table approach); or • specification of the ‘critical ratio’, λ, given by the opportunity cost of the resources at the margin, 2006 Adis Data Information BV. All rights reserved. 1125 and implementation of all interventions with an ICER less than or equal to λ (threshold ICER approach). Note that for the league table approach, information on the incremental costs and effects of all current and potential interventions is required. Similarly, for the threshold ICER approach, in order to determine the critical ratio λ, the marginal intervention must be identified, which also requires information on the incremental costs and effects of all current and potential interventions. In the real world, information for healthcare decision makers is incomplete. Consequently, complete rankings of interventions cannot be produced and therefore λ cannot be determined.[4,6,17,18] Restricted league tables based on rankings of those interventions for which information is available can be used, but such tables cannot determine the opportunity cost of marginal resources and hence cannot determine if a particular intervention contributes to the maximisation of total health benefits from available resources. Suppose complete information was to be available to decision makers. Several important implications emerge from this theoretical model. First, the marginal opportunity cost of resources, λ, depends crucially on, inter alia, the quantity of available resources (i.e. the size of the budget).[19] Hence, communities with the same healthcare needs but different budgets will have different values of λ against which to judge the efficiency of interventions. Secondly, any change in healthcare resources generates a change in λ, the ICER threshold below which an intervention represents an efficient use of resources.[20] Thirdly, because the costs and effects of all interventions are subject to uncertainty, λ, given by the marginal intervention funded, is also uncertain.[21] Finally, as new interventions are funded and others replaced, the marginal funded intervention changes. Hence the value and distribution of λ, given by the ICER of the marginal funded intervention, are dynamic.[21] As a result, no generalised statement can be made about the efficiency of an intervention in isolation from the precise setting in which it is being considered. A simple, single λ value, or range of values, cannot be specified for Pharmacoeconomics 2006; 24 (11) 1126 determining the efficiency of interventions across different settings and over time.[20] Even under the assumptions of the WZ model, the λ value consistent with the maximisation of total health benefits from available resources will be context specific and continuously changing.[20] Notwithstanding the non-generalisable nature of λ, the WZ model from which it emerges is based on assumptions (perfect divisibility and constant returns to scale of all interventions) that are highly theoretical and not valid in most, if not all, decisionmaking settings.[19] Under perfect divisibility, all interventions can be purchased in incremental units (e.g. 1 minute of a dialysis machine) while constant returns to scale require that the marginal health benefits of an intervention are constant, no matter how many increments are purchased (e.g. if one dialysis machine is associated with producing an additional 50 QALYs per year, then one-tenth of a dialysis machine produces five additional QALYs per year and 1000 machines produce 50 000 additional QALYs in the population). The empirical studies on which ICER calculations are based normally compare a new intervention with a current intervention based on a particular size of intervention (usually chosen for statistical analysis reasons). Rarely, if ever, are the consequences of varying the size of the intervention/patient group for the incremental costs and effects considered. Instead, the ICER is used to create an average (and an implicitly assumed constant) additional cost per unit QALY. When the theoretical assumptions of the WZ model do not hold, then the ICER threshold approach does not guarantee that available resources are being used in ways that maximise health benefits[19,21,22] and the conclusions of the WZ model are no longer valid (see Gafni and Birch[23] and Birch and Gafni[13] for numerical examples). As Doubilet et al.[24] note, “there is no theoretical justification for asserting that the strategy with the lowest costeffectiveness ratio is the most desirable one”. 5. Pursuing Efficiency: Back to the Future “To improve efficiency, decision-makers need information on what economists call opportunity cost 2006 Adis Data Information BV. All rights reserved. Birch & Gafni – the benefits forgone when scarce resources are used one way rather than another… In absence of any information about opportunity cost, however, they cannot attempt to achieve the efficient use of resources.”[25] As we have shown, the use of an ICER threshold to determine the efficiency of a new intervention is at best based on underlying assumptions that are inconsistent with the decision maker’s real problem. Notwithstanding the serious limitations introduced by these assumptions, lack of information prohibits determining the theoretically correct λ value or even a range within which λ lies. As a result, in practice λ is determined arbitrarily and without any explanation of how application of the λ value leads to the efficient use of available resources. Weinstein[26] describes the proper use and interpretation of ICERs where interventions compete for limited resources. He acknowledges the underlying assumptions of the WZ model but suggests that these assumptions can be relaxed without abandoning the simple basic (cost-effectiveness) paradigm. However, unlike the WZ model, no mathematical proof is given for how the use of ICERs achieves the efficient use of resources once the theoretical assumptions are relaxed. He notes that if there are ethical or technical constraints on providing an intervention to only a fraction of the population in need, then a generalised optimisation framework would be necessary to address the decision maker’s problem. He directs the reader to our own work[27] for solutions and explains that computer programs exist to solve these optimisation problems. It is worth noting that the recognition of the need for a generalised optimisation framework to address the decision maker’s real problem is not new. Torrance et al.[28] in 1972 described the use of a standard mathematical programming model to solve the optimisation problem of maximisation of total health benefits from available resources. Similarly in 1976, Chen and Bush[29] provided a framework for maximising healthcare output subject to political and administrative constraints using mathematical programming techniques. Drummond[30] noted that the use of mathematical programming techniques was Pharmacoeconomics 2006; 24 (11) ICER: Information Created to Evade Reality “the only approach” that could rank interventions under a resource constraint while Drummond et al.[31] and Mason et al.[32] acknowledged that the information provided in ICER league tables is not sufficient to determine the efficiency of individual interventions and that such problems require the use of mathematical programming techniques. Finally, Birch and Donaldson[33] and Birch and Gafni[22] presented integer programming solutions for dealing with the problems of indivisibilities and non-constant returns to scale in the context of a constrained maximisation problem, while Stinnett and Paltiel[34] provided a flexible extension to integer programming. These mathematical programming techniques require information on the costs and effects of all current and potential new interventions, together with the resources available for investment. Although these data requirements may be difficult to satisfy, they reflect the complex nature of the decision maker’s problem. The use, instead, of a restricted league table of ICER values or an arbitrarily determined ICER threshold might offer an intuitive shortcut to resolving the decision maker’s problem, but as Williams noted, “reality is horrendously complicated…the more complex the reality is, the more dangerous it is to rely on intuitive short-cuts rather than careful analysis.”[12] Faced with inadequate information to solve the problem of maximisation of health benefits from available resources, we previously provided a less data-intensive approach aimed at a modified objective of an unambiguous improvement in efficiency (i.e. achieving an increase in total health benefits from available resources).[22,35] This requires that the increase in health generated by the new intervention exceeds the increases in health generated by that combination of interventions to be given up in order to fund the new intervention. This approach does not rely on any arbitrary threshold values to ascertain the efficiency of the intervention, and is not dependent on unrealistic assumptions about perfect divisibility and constant returns to scale. Instead, the source of the additional resource requirements of the new intervention is identified directly and the impli 2006 Adis Data Information BV. All rights reserved. 1127 cations of cancelling these interventions (i.e. the opportunity cost of the new intervention) to generate these resources form an explicit part of the analysis. The approach has been extended to deal with the uncertain nature of costs and outcomes.[21] 6. Discussion “The basic economic problem is how to allocate scarce resources so as to best satisfy human wants. This may be contrasted with the romantic point of view that fails to recognise scarcity of resources and is misled into confusing the real world with the Garden of Eden.”[36] Guidelines for economic evaluation based on CEA and the use of ICERs have already become an important part of healthcare decision making in several jurisdictions,[1-3] while calls continue to be made for its adoption in jurisdictions that to date have remained ‘guideline free’.[37] In both cases, the use of CEA is seen by researchers and policy makers as the long-awaited solution or at least a major contribution to addressing the challenge of how to maximize health gains from available healthcare resources. For example, in the UK, NICE uses CEA for deciding which interventions to recommend for funding under the NHS.[2] This has been described by Williams as “the closest anyone has come to fulfilling the economist’s dream,”[12] while Smith has suggested that NICE may prove to be “one of Britain’s greatest cultural exports, along with Shakespeare, Newtonian physics, the Beatles, Harry Potter and the Teletubbies.”[38] But does this confuse the real world with the Garden of Eden? We have shown that CEA and the use of ICER thresholds cannot be used to determine whether a new intervention represents an efficient use of available healthcare resources. Elsewhere we have shown that applications of the ICER approach to healthcare decision making have been associated with increased expenditures on healthcare interventions and concerns about the sustainability of public funding for those interventions without any evidence of increases in total health gains.[9,17,23] In other words, instead of the analysis helping decision makers produce ‘the biggest bang for the healthcare Pharmacoeconomics 2006; 24 (11) 1128 bucks’ it has been associated with ‘bigger healthcare bucks for the bang’.[13] Some have suggested that one way of dealing with the statistical problems arising from the calculation of the ICER (i.e. the assumptions involved in dividing incremental costs by incremental effects) is to use a net-benefits approach by converting the incremental costs into a negative benefits expression and determining if the intervention represents a net increase in benefits.[39] Unfortunately, this does not escape the problem of the ICER threshold since the conversion of incremental costs to negative benefits is performed using the ICER threshold and hence all of the problems associated with the ICER threshold discussed in the previous sections are reintroduced. Other researchers have proposed the use of costeffectiveness acceptability curves[40,41] in which information is provided to decision makers on the probability that an intervention has an ICER that is less than or equal to a given level or range of λ values. Again, λ (or the range of λ) is required as an input, which undermines the approach as a means of determining whether an intervention represents an efficient use of resources. Others have argued that despite the theoretical as well as empirical limitations with the ICER approach, because decision makers are unable to establish what the opportunity costs of a new intervention will be, the question about the efficiency of a new intervention can only be answered by establishing (implicitly or explicitly) “our generic willingness to pay (WTP) for an additional unit of effect.”[42] For example, Ubel et al.[4] argue that physicians’ scepticism about using CEA may be because they feel that ICER thresholds used in decision making are too low. They acknowledge that currently used thresholds are arbitrary but suggest the use of $US200 000 or more per QALY as a new threshold, arguing that the actual threshold should be set “by consensus process, such as that used by the US Public Health Service when it established standards for the field of cost-effectiveness in the mid 1990s.” However, the cost-effectiveness standards referred to[6] acknowledged that no absolute standard exists for deciding whether a specific ICER value repre 2006 Adis Data Information BV. All rights reserved. Birch & Gafni sents a cost-effective use of resources or not. Moreover, despite calling for a consensus-based ICER threshold, the authors[4] acknowledge that the use of such a threshold would lead to continual increases in per capita healthcare costs, an outcome that is inconsistent with the efficient use of available resources. Suggestions for the use of a ‘generic’ ICER threshold that in some way measures society’s willingness to pay for a QALY fail to consider how the use of such a measure is consistent with the maximisation of health benefits from available resources. As Claxton et al.[8] note in relation to the NICE threshold, “it is not the societal valuation that is relevant…but the shadow price of the…budget constraint.” Despite these ‘fatal’ limitations of the ICER threshold approach as a solution to the constrained maximisation problem, considerable research attention has been given to dealing with issues of uncertainty, sample size requirements[43] and the determination of the value of additional information,[44,45] all based on the ICER and the threshold ICER approach. Hence, while they each may represent important contributions to a theoretical model, they offer no help to decision makers faced with choices between different ways of allocating available resources. Where the incremental cost of a new intervention is positive, the question facing decision makers is not simply the choice between the new intervention and the old intervention it is intended to replace. The new intervention involves an opportunity cost that exceeds the health benefits of the old intervention. Because the ICER approach is restricted to comparative information on the new and old interventions (i.e. two interventions involving different resource requirements), it implies that there is an indeterminate stream of additional resources available for investment in new interventions at a constant marginal opportunity cost.[19,21,46] In reality, marginal opportunity costs of resources are likely to be increasing (the bigger the additional resource requirements the further you have to go in cutting current programmes, from least productive to most productive, in order to generate the required resources). Moreover, differences in prevailing circumstances Pharmacoeconomics 2006; 24 (11) ICER: Information Created to Evade Reality (e.g. overall health profiles of populations, healthcare budgets etc.) both between settings and over time mean that the efficiency of a particular intervention will be context specific.[20] Some authors have defended the use of CEA by distancing themselves from the constrained maximisation problem. For example, Rawlins and Culyer[11] see the use of CEA by NICE as simply a way to judge ‘value for money’; in other words, whether something ought to be purchased from within the resources made available while the total cost of all interventions deemed suitable for purchase is a separate matter of ‘affordability’. But matters of efficiency cannot be separated from matters of affordability.[9,23] Because money represents only command over resources, value for money is determined in relation to what it can purchase. Hence, whether a particular intervention represents ‘value for money’ is determined by what is forgone in order to ‘afford it’. As Williams notes, if affordability could be separated from efficiency there would be no need for a threshold.[12] Baltussen et al.[47] acknowledge that the comparison of interventions based on ICER values cannot provide solutions to context-specific decisions and that the solution of such problems requires “more complex optimal resource allocation planning models.” As a result, they argue that “CEA can be most useful with more modest goals.” However, they do not explain what these more modest goals are that CEA can address or whether these goals are compatible with the problem of constrained maximisation facing the decision-making processes that CEA is intended to inform. Similarly, Sculpher et al.[48] suggest that economic evaluation should focus more on tackling the needs of social decision making than on the underlying principles of welfare economics, implying that the two are incompatible. They argue “for this research to be relevant to policy, it needs to be seen less as economic evaluation and more as evaluation.” But if social decision makers are faced with the problem of constrained maximisation and the economics discipline provides the only approach for solving such problems, how is a departure from 2006 Adis Data Information BV. All rights reserved. 1129 economic principles and the concept of opportunity cost ‘relevant to policy’? 7. Conclusion In summary, the ICER represents Information Created to Evade the decision maker’s Reality. No justification exists for the ICER thresholds used (or any other ICER threshold) being compatible with the decision maker’s goal of maximising health benefits from available resources. Evidence from Ontario (Canada), England and Australia shows that the adoption of the ICER approach has been associated with substantial unplanned increases in healthcare expenditures without any evidence of any increase in total health benefit.[9,13] For example, the estimated additional resources absorbed by NICE-recommended technologies in the first 2.5 years after the implementation of NICE exceeded £575 million.[49] What would have happened to expenditures in these jurisdictions in the absence of ICER-based approaches to decision making is unknown. However, estimating the counterfactual fails to address the stated objectives of the ICER-based approaches – maximisation of health gains from whatever level of resources is committed to healthcare interventions. Maynard et al.[50] have suggested imposing a notional budget for the ICER-based adoption of new interventions to encourage organisations to examine the effect of their decisions on overall health gains in the system. But as we have shown previously,[13] maximisation of benefits from a given budget cannot be determined based on the ICERs of possible interventions. Questions concerned with the maximisation of efficiency require information on the total costs and total effects of all interventions. More modest objectives of improving efficiency require corresponding information on the new interventions being considered for adoption and the possible interventions to be forgone to provide funding for the new interventions.[21] Hence, where the questions that decision makers face are concerned with making the best use of available resources, we should not look to CEA, and the ICER threshold approach on which it is based, for answers. Pharmacoeconomics 2006; 24 (11) 1130 Birch & Gafni Acknowledgements No sources of funding were used to assist in the preparation of this article. The authors have no potential conflicts of interest that are directly relevant to the contents of this article. References 1. 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