TA737/Scope Consultation Comments
Page 1

Summary form

National Institute for Health and Care Excellence

Single Technology Appraisal (STA)

Pembrolizumab with platinum-based chemotherapy for untreated advanced oesophageal or gastroesophageal cancer Response to consultee and commentator comments on the draft remit and draft scope

Please note: Comments received in the course of consultations carried out by NICE are published in the interests of openness and transparency, and to promote understanding of how recommendations are developed. The comments are published as a record of the submissions that NICE has received, and are not endorsed by NICE, its officers or advisory committees.

Comment 1: the draft remit

Section Consultee/
Commentator
Comments [sic] Action
Wording Roche If the study did not allow investigators to choose different chemotherapy
regimens, please only include cisplatin plus fluorouracil as chemotherapy
option.
Thank you for your
comment. The
intervention included in
the remit has not been
changed. This is to
allow a broad remit to
be evaluated in line with
how the intervention is
likely to be used in
clinical practice. The
recommendations made
by the committee will be
based on the available
evidence and its
understanding of how
this reflects clinical
practice.

National Institute for Health and Care Excellence

Page 1 of 7 Consultation comments on the draft remit and draft scope for the technology appraisal of pembrolizumab with platinum-based chemotherapy for untreated advanced oesophageal or gastroesophageal cancer Issue date: November 2020

Page 2

Summary form

Section Consultee/
Commentator
Comments [sic] Action
Merck Sharp &
Dohme
The anticipated marketing authorisation wording is
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx. Please update
the draft remit wording to reflect the anticipated marketing authorization.
Thank you for your
comment. The remit
has been amended.
Timing Issues Roche No Comment Thank you.
Merck Sharp &
Dohme
The provisional scheduling for this topic is appropriate. Thank you for your
comment. This topic
has been scheduled
into the work
programme.
Additional
comments on the
draft remit
Merck Sharp &
Dohme
None Thank you.

Comment 2: the draft scope

Section Consultee/
Commentator
Comments [sic] Action
Background
information
Roche Consider adding information related to the efficacy of immunotherapy in
squamous cell carcinoma vs adenocarcinoma. It is well known and reported
that the two histological types respond differently to immunotherapy
treatments.
Thank you for your
comment. The
background section
provides a broad
overview of the disease
area and currently
available treatments. It

National Institute for Health and Care Excellence

Consultation comments on the draft remit and draft scope for the technology appraisal of pembrolizumab with platinum-based chemotherapy for untreated advanced oesophageal or gastroesophageal cancer Issue date: November 2020

Page 3

Summary form

Section Consultee/
Commentator
Comments [sic] Action
is not fully exhaustive.
No update required.
Merck Sharp &
Dohme
Background information is accurate and complete. Thank you for your
comment.
The technology/
intervention
Roche Indicate the use of cisplatin plus fluorouracil instead of chemotherapy if the
trial did not include other chemotherapy types.
Thank you for your
comment. The
intervention has not
been updated. This is to
allow a broad
intervention to be
evaluated in line with
how the intervention is
likely to be used in
clinical practice.
Merck Sharp &
Dohme
The description of the technology is accurate. Thank you for your
comment.
Population Roche PD-L1 status and tumour histology can be predictive or prognostic of
treatment response.
Thank you for your
comment. People with
PD-L1 positive
oesophageal cancer
have been added to the
scope as a subgroup of
interest.
Merck Sharp &
Dohme
Please update the population to reflect the marketing authorisation wording
above.
Thank you for your
comment. The

National Institute for Health and Care Excellence

Consultation comments on the draft remit and draft scope for the technology appraisal of pembrolizumab with platinum-based chemotherapy for untreated advanced oesophageal or gastroesophageal cancer Issue date: November 2020

Page 4

Summary form

Section Consultee/
Commentator
Comments [sic] Action
population has been
amended.
Comparators Roche No comment Thank you.
Merck Sharp &
Dohme
We agree with the proposed comparators. Thank you for your
comment.
Outcomes Roche Yes. Thank you for your
comment.
Merck Sharp &
Dohme
MSD considers that the outcome measures listed are appropriate. However, it
is known that the response to immunotherapies (immuno-oncology drugs)
may have a later onset but once triggered, is likely to be durable, bringing
unquantifiable long-term survival benefit for a subset of patients. This benefit
is not captured by the outcome measures listed, thus MSD suggests the
inclusion of “Duration of Response” as an additional outcome measure.
Thank you for your
comment. The list of
outcomes is not
exhaustive, but we note
that no change to the
scope is required as
this additional outcome
would be covered by
the outcome ‘response
rates’, which is already
stated in the scope.
Economic
analysis
Roche No comment Thank you.
Merck Sharp &
Dohme
No additional comments. Thank you.

National Institute for Health and Care Excellence

Consultation comments on the draft remit and draft scope for the technology appraisal of pembrolizumab with platinum-based chemotherapy for untreated advanced oesophageal or gastroesophageal cancer

Page 5

Summary form

Section Consultee/
Commentator
Comments [sic] Action
Equality and
Diversity
Roche No comment Thank you.
Merck Sharp &
Dohme
No additional comments. Thank you.
Other
considerations
Roche No comment Thank you.
Merck Sharp &
Dohme
No additional comments. Thank you.
Innovation Roche No comment Thank you.
Merck Sharp &
Dohme
MSD considers pembrolizumab to be innovative in its potential to make a
significant and substantial impact on health-related benefits.
Pembrolizumab has the potential to improve outcomes for oesophageal
patients, being a step-change in the management of locally advanced
unresectable or metastatic carcinoma of the oesophagus or HER-2 negative
gastroesophageal junction adenocarcinoma.
Thank you for your
comment. The
committee will consider
the innovation of this
technology during the
appraisal. No changes
to the scope have been
made.
Questions for
consultation
Roche No additional comments Thank you.
Additional
comments on the
draft scope
Merck Sharp &
Dohme
Question: Is oesophageal cancer clinically distinct to gastroesophageal
junction cancer?
Answer: In oesophago-gastric cancers, the main clinically relevant factor is
the histology (adenocarcinoma vs squamous cell carcinoma [SCC]), rather
Thank you for your
comment.

National Institute for Health and Care Excellence

Consultation comments on the draft remit and draft scope for the technology appraisal of pembrolizumab with platinum-based chemotherapy for untreated advanced oesophageal or gastroesophageal cancer Issue date: November 2020

Page 6

Summary form

Section Consultee/
Commentator
Comments [sic] Action
than the location (oesophagus, junction, stomach). However, there is a
correlation between location of the tumour and histology. Cancers located in
the proximal oesophagus tend to be more SCC, whereas junction and
stomach cancers are more adenocarcinoma.
At the metastatic stage, the location does not influence treatment for systemic
therapy (except for symptoms control), but histology does. At earlier stage,
location will influence treatment, with regards to surgery and radiotherapy.
**Question:**Have all relevant comparators for pembrolizumab with platinum-
based chemotherapy been included in the scope?
Answer: Yes, all relevant comparators have been included in the scope.
**Question:**Which treatments are considered to be established clinical
practice in the NHS for untreated unresectable locally advanced, or
metastatic oesophageal cancer?
Answer: The established clinical practice in the NHS is platinum-based
chemotherapy including doublet (cisplatin or oxaliplatin with fluorouracil or
capecitabine) and triplet treatments (cisplatin or oxaliplatin with fluorouracil or
capecitabine plus epirubicin).
**Question:**Are the outcomes listed appropriate?
Answer: We consider the listed outcomes to be appropriate. An additional
comment has been added in the relevant section above.
**Question:**Are there any subgroups of people in whom pembrolizumab with
platinum-based chemotherapy is expected to be more clinically effective and
cost effective or other groups that should be examined separately?
Subgroups based on
PDL1 status and
histology have been
added to the scope.

National Institute for Health and Care Excellence

Page 6 of 7 Consultation comments on the draft remit and draft scope for the technology appraisal of pembrolizumab with platinum-based chemotherapy for untreated advanced oesophageal or gastroesophageal cancer

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Summary form

Section Consultee/
Commentator
Comments [sic] Action
• If evidence allows, should squamous cell carcinoma, adenocarcinoma and
adenosquamous cell carcinoma be considered separately?
Answer: MSD considers pembrolizumab in combination with platinum-based
chemotherapy to offer clinical benefit within the ITT population of patients with
advanced or metastatic untreated oesophageal cancer, as per the results
from KEYNOTE-590. MSD recognises the sub-groups of importance are
according to histology and PD-L1 expression and, if the data allows, will
investigate these subgroups if appropriate.
**Question:**Where do you consider pembrolizumab with platinum-based
chemotherapy will fit into the existing NICE pathway, oesophageal and gastric
cancer?
Answer: We consider that pembrolizumab with platinum-based
chemotherapy will fit into the existing NICE pathway as a first-line treatment
option in patients with advanced/metastatic oesophageal carcinoma.

The following consultees/commentators indicated that they had no comments on the draft remit and/or the draft scope Pfizer

National Institute for Health and Care Excellence

Consultation comments on the draft remit and draft scope for the technology appraisal of pembrolizumab with platinum-based chemotherapy for untreated advanced oesophageal or gastroesophageal cancer