Factors that led to the implementation of the efficiency frontier approach in health economic evaluation in Germany: Do not avoid the elephant in the room: Comment on Klingler et al. (Health policy 109 (2013) 270-280)

摘要

Klingier et al. claim that the following factors led to the adoption of the efficiency frontier (EF) approach in Germany: the rejection of a fixed threshold, focusing on clinical benefit instead of cost-effectiveness as decision parameter, (avoiding) healthcare rationing, methodological doubts regarding quality-adjusted life years (QALYs), and associating QALYs with healthcare rationing [1 ]. In our opinion, the authors may overlook the factual aim of the EF-approach: justification of setting ceiling prices instead of making reimbursement decisions. Furthermore, the role of a judicial review - a crucial veto point in the German regulatory space - has not been discussed. Both will briefly be explained below.