11 June 2021: OIA response | Upadacitinib budget impact analysis for rheumatoid arthritis

11 June 2021 

Dear [name and contact details withheld] 

REQUEST FOR INFORMATION 

Thank you for your request dated 18 May 2021 under the Official Information Act 1982 (OIA) for information relating to the funding application for upadacitinib. You requested: 

The budget impact analysis completed by PHARMAC for upadacitinib in rheumatoid arthritis, considered at the February 2021 PTAC meeting. The existence of this analysis is referenced in 9.27 of the PTAC record(external link): 

9.27: The Committee noted the patient numbers estimated by PHARMAC staff, which assumed an expansion in the population receiving biologic or tsDMARD treatment of 10%, and high early uptake reflective of a bolus of patients moving onto upadacitinib treatment. The Committee considered that the assumptions used by PHARMAC staff in the budget impact analysis were reasonable and consistent with prior clinical advice, and would likely be similar for tofacitinib. The Committee considered that there may be high uptake of oral tablets, and this would be driven by patient preference; the Committee also considered that, if funded with the same access criteria as adalimumab and etanercept, upadacitinib may be prescribed for greater than 40% of biologic-naïve patients with RA. 

Please find attached with this response letter, an excerpt of the paper to the Pharmacology and Therapeutics Advisory Committee (PTAC), considered at the meeting in February 2021. The excerpt details the assumptions used by PHARMAC staff. 

Please note that PHARMAC approaches its assessment of requests for information under the OIA on the basis that, once released, the information becomes publicly available - in other words once we release the information to you it becomes available to any other party in that exact form (whether by you distributing it to others or by virtue of us receiving the same request from a different third party). 

We have redacted a small amount of information from the documents as we consider this is necessary to:

  • protect information where the making available of the information would be likely to unreasonably prejudice the commercial position of the person who supplied or who is the subject of the information (section 9(2)(b)(ii));
  • protect information which is subject to an obligation of confidence or which any person has been or could be compelled to provide under the authority of any enactment, where the making available of the information would be likely to prejudice the supply of similar information, or information from the same source, and it is in the public interest that such information should continue to be supplied (section 9(2)(ba)(i)); and
  • enable PHARMAC to carry on, without prejudice or disadvantage, negotiations, including commercial negotiations (section 9(2)(j)). 

As required under the OIA, we also considered whether, in the circumstances, the withholding of this information was outweighed by other considerations which render it desirable, in the public interest, to make this information available. In this case we did not consider that the public interest outweighed the reasons for withholding the information. 

Please note you have the right, by way of complaint under section 28(3) of the OIA to an Ombudsman, to seek an investigation and review of our decision.

We trust that this information answers your queries. We are making our information more freely available, so we now publish selected OIA responses (excluding personal details) on our website. Please get in touch with us if you have any questions about this. 

Yours sincerely 

Rachel Read
Manager, Policy and Government Services