TA875/Scope Consultation Comments
Page 1

Summary form

National Institute for Health and Care Excellence

Single Technology Appraisal (STA)

Semaglutide for managing overweight and obesity [ID3850]

Response to consultee and commentator comments on the draft remit and draft scope (pre-referral)

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
Appropriateness Novo Nordisk Yes. Comment noted.
GlaxoSmithKline Yes. Comment noted.
British Obesity
Society
We agree that this is an appropriate topic for NICE to appraise. Given its
association with COID-19 morbidity and mortality, obesity management is
important and a high priority.
Thank you for your
comment. No change to
the scope required.
The UK Obesity
Organisation
Yes – There are limited treatment options available for people living with
obesity currently. Semaglutide offers a treatment that fits in between diet and
exercise and bariatric surgery.
There needs to be more options for PLWO because one size does not fit all.
Thank you for your
comment. No change to
the scope required.
Wording Novo Nordisk Yes. Comment noted.
GlaxoSmithKline Yes. Comment noted.

National Institute for Health and Care Excellence

Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021

Page 2

Summary form

Section Consultee/
Commentator
Comments [sic] Action
British Obesity
Society
Yes. Comment noted.
The UK Obesity
Organisation
Yes – I think the wording reflects the issues correctly. Comment noted.
Timing Issues Novo Nordisk Given the high unmet need for additional clinically effective treatments for
obesity and overweight in the NHS, the urgency of the proposed appraisal is
high.
Thank you for your
comment. No change to
the scope required.
British Obesity
Society
We agree that this is an appropriate topic for NICE to appraise. Given its
association with COVID-19 morbidity and mortality, obesity management is
important and a high priority.
Thank you for your
comment. No change to
the scope required.
The UK Obesity
Organisation
COVID-19 has highlighted the need for more support and treatment options
for people living with obesity. So I would say the urgency is pretty high for
this.
Thank you for your
comment. No change to
the scope required.

Comment 2: the draft scope

Section Consultee/
Commentator
Comments [sic] Action
Background
information
Novo Nordisk Based on the guidance outlined TA664 liraglutide is recommended alongside
a reduced-calorie diet and increased physical activity for use in in adults who:

Have a body mass index (BMI) of at least 35 kg per m2

Have pre-diabetes (non-diabetic hyperglycaemia (defined as a
haemoglobin A1c level of 42 to 47 mmol per mol [6.0 to 6.4%] or a
fasting plasma glucose level of 5.5 to 6.9 mmol per litre)

Have a high risk of cardiovascular disease based on risk factors such
as hypertension and dyslipidaemia
Thank you for your
comment. A description
of the recommendations
for liraglutide has been
added to the
background section of
the scope.

National Institute for Health and Care Excellence

Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021

Page 3

Summary form

Section Consultee/
Commentator
Comments [sic] Action

It is prescribed in secondary care by a specialist multidisciplinary tier 3
weight management service.
GlaxoSmithKline No additional comment Comment noted.
British Obesity
Society
This information is accurate and complete to date. Comment noted.
The UK Obesity
Organisation
Please consider use of people first language in the document. The word
obese is deemed as stigmatising.
Thank you for your
comment. The scope
has been amended to
reflect this approach.
“People who are
overweight or obese”
has been changed to
“People living with
overweight or obesity”.
The technology/
intervention
Novo Nordisk Current wording:
Semaglutide (Rybelsus, Novo Nordisk) binds to and activates the glucagon-
like peptide-1 (GLP-1) receptor in order to increase insulin levels and
suppress glucagon secretion. This action leads to the slowing of glucose
absorption and lower post-meal blood glucose levels. It is administered by
subcutaneous injection.
Proposed wording:
Semaglutide 2.4 mg (Brand Name TBC, Novo Nordisk) is a once-weekly
subcutaneous injection that binds to and activates the glucagon-like peptide-1
(GLP-1) receptor in order to increase insulin levels and suppress glucagon
secretion. This action leads to the slowing of glucose absorption and lower
post-meal blood glucose levels.
Thank you for your
comment. The scope
has been amended to
reflect that the brand
name is yet to be
confirmed. The
proposed appraisal will
only appraise
semaglutide within its
marketing authorisation
and within the remit of
the scope. It is therefore
not necessary to

National Institute for Health and Care Excellence

Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021

Page 4

Summary form

Section Consultee/
Commentator
Comments [sic] Action
Current wording:
Semaglutide has a marketing authorisation in the UK as an adjunct to diet
and exercise for treatment of adults with insufficiently controlled type 2
diabetes mellitus, either as monotherapy when metformin is considered
inappropriate due to intolerance, or in combination with other medicinal
products for the treatment of diabetes. Semaglutide is available as once-daily
oral tablet and once-weekly injectable preparations.
Proposed wording:
Semaglutide has a marketing authorization in the UK as an adjunct to diet
and exercise for treatment of adults with insufficiently controlled type 2
diabetes mellitus, either as monotherapy when metformin is considered
inappropriate due to intolerance, or in combination with other medicinal
products for the treatment of diabetes. Semaglutide is available as once-daily
oral tablet (Rybelsus®, 3 mg, 7 mg and 14 mg) and once-weekly injectable
preparations (Ozempic®, 0.5 mg and 1.0 mg dose).
Current wording:
Intervention(s) Semaglutide
Proposed wording:
Semaglutide 2.4 mg
distinguish between
doses from other
indications.
GlaxoSmithKline No additional comment. Comment noted.
British Obesity
Society
Yes. Comment noted.

National Institute for Health and Care Excellence

Page 4 of 18 Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021

Page 5

Summary form

Section Consultee/
Commentator
Comments [sic] Action
The UK Obesity
Organisation
Yes, I believe this is correct. Comment noted.
Population GlaxoSmithKline Yes, the population is defined appropriately. Comment noted.
British Obesity
Society
Appropriate population data. Comment noted.
The UK Obesity
Organisation
Yes the population is defined appropriately. I would stress that those with a
BMI above 40 require access sooner than others.
Thank you for your
comment. No change to
the scope required.
Comparators Novo Nordisk Novo Nordisk would like to propose the following amendments to the
Comparators section:
**Orlistat (prescription dose)**is not a relevant comparator for semaglutide
2.4 mg. In section 3.2 of the final appraisal determination for technology
appraisal 494, orlistat was not considered to be widely used by the clinical
experts in clinical practice due to undesirable side effects leading to poor
adherence and outcomes. These sentiments were again reflected in the
recent appraisal of liraglutide for managing overweight and obesity [TA664]
and were discussed at length during consultation. In section 3.4 of the final
appraisal determination, it is stated that many people decide not to have
orlistat or stop taking it because of undesirable, and socially unacceptable
side effects. Therefore, based on this rationale, and the clear determination
made in TA494 and TA664 orlistat should not be considered a relevant
comparator.
Bariatric surgeryis not a relevant comparator in the appraisal for
semaglutide 2.4 mg. Although bariatric surgery may be considered a last
Thank you for your
comment. Although
clinical expert
comments in TA494
indicated that orlistat is
not widely used, it is
listed as an available
treatment option in
CG189. For
completeness, it has
been kept in the scope
as a comparator.
It is acknowledged that
bariatric surgery is a
treatment option when
all appropriate non-
surgical measures have
been tried. Therefore,

National Institute for Health and Care Excellence

Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021

Page 6

Summary form

Section Consultee/
Commentator
Comments [sic] Action
resort treatment option for patients with obesity with a high BMI (a BMI of 40
kg/m2or more, or between 35 kg/m2and 40 kg/m2and other significant
disease), in UK clinical practice it is not realistic that all patients will be offered
bariatric surgery. In section 3.1 of the final appraisal determination for
technology appraisal 494, clinical experts stated that only 0.1% of patients
eligible for surgery actually have it. Again, this is reiterated in section 3.4 of
the final appraisal determination for TA664.
To account for bariatric surgery in the treatment pathway for obesity, this will
be included in the economic model as an event. The rate of surgery would be
based on the current incidence in the NHS and modifiable via sensitivity
analysis.
Consistent with the recommendation achieved through appraisal TA664
liraglutide 3.0mg is a relevant comparator in patients who:

Have a body mass index (BMI) of at least 35 kg per m2

Have pre-diabetes (non-diabetic hyperglycaemia (defined as a
haemoglobin A1c level of 42 to 47 mmol per mol [6.0 to 6.4%] or a
fasting plasma glucose level of 5.5 to 6.9 mmol per litre)

Have a high risk of cardiovascular disease based on risk factors such
as hypertension and dyslipidaemia

It is prescribed in secondary care by a specialist multidisciplinary tier 3
weight management service
The expected license recommends the use of semaglutide 2.4 mg as an
adjunct to diet and exercise and therefore diet and exercise will continue to
be a significant component for the ongoing management of obesity
bariatric surgery has
been removed as a
comparator.
The scope has been
updated to specify the
population for whom
liraglutide is an
appropriate comparator.
GlaxoSmithKline Yes, the comparators are appropriate for this appraisal. Comment noted.

National Institute for Health and Care Excellence

Page 6 of 18 Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021

Page 7

Summary form

Section Consultee/
Commentator
Comments [sic] Action
British Obesity
Society
Yes. Comment noted.
The UK Obesity
Organisation
I think the comparators are fair for this appraisal. Comment noted.
Outcomes Novo Nordisk The following outcomes were collected as part of the STEP-1 clinical trial:

Change from baseline at week 0 to week 68 in body weight (%)

Subjects who after 68 weeks achieve (yes/no):
oBody weight reduction ≥5% from baseline (week 0)

Subjects who after 68 weeks achieve (yes/no):
oBody weight reduction ≥10% from baseline (week 0)
oBody weight reduction ≥15% from baseline (week 0)
oBody weight reduction ≥20% from baseline (week 0)

Change from baseline at week 0 to week 68 in:
oBody weight (kg)
oBMI (kg/m2)

Cardiovascular risk factors
oChange from baseline at week 0 to week 68 in:

Systolic blood pressure (mmHg)

Diastolic blood pressure (mmHg)

Lipids (mmol/L and mg/dL)

Total cholesterol

HDL cholesterol

LDL cholesterol

VLDL cholesterol

Free fatty acids
Thank you for your
comment. We note that
the trial outcomes
broadly fall under the
outcome measures in
the scope and the
company’s intended
modelled outcomes are
consistent with the
scope. Please note that
work productivity is
currently outside the
remit of NHS and PSS
perspective. No change
to the scope required.

National Institute for Health and Care Excellence

Page 7 of 18 Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021

Page 8

Summary form

Section Consultee/
Commentator
Comments [sic] Action

Triglycerides
oCRP (mg/L)
oPAI-1 activity (AU/mL)

Clinical outcome assessments
oChange from baseline at week 0 to week 68 in:

Physical functioning score (SF-36)

Physical function domain (5-items) score (IWQOL-Lite-
CT)

SF-36

IWQOL-Lite-CT

Subjects who after 68 weeks achieve (yes/no):
oResponder definition value for SF-36 physical functioning
score
oResponder definition value for IWQOL-Lite-CT physical
oFunction domain (5-items) score

Glucose metabolism
oChange from baseline at week 0 to week 68 in:

HbA1c (% and mmol/mol)

FPG (mmol/L and mg/dL)

Fasting serum insulin (mIU/L)

Other body weight-related endpoints
oWaist circumference (cm)#
oSoluble leptin receptor (ng/mL)
oLeptin (ng/mL)
oBody composition (as assessed by DEXA in a subset of
osubjects):

Total fat mass (kg and %)

Lean body mass (kg and %)

Visceral fat mass (kg and %)

Body weight (kg and %) in the DEXA subset of subjects

Safetyendpoints

National Institute for Health and Care Excellence

Page 8 of 18 Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021

Page 9

Summary form

Section Consultee/
Commentator
Comments [sic] Action

Number of TEAEs from baseline at week 0 to week 75

Number of SAEs from baseline at week 0 to week 75

Change from baseline at week 0 to week 68 in:
oPulse (bpm)
oAmylase (U/L)
oLipase (U/L)
oCalcitonin (ng/L)

Glycaemic status
oChange from baseline at week 0 to week 68 in glycaemic
category (normo-glycaemia, pre-diabetes, T2D)

Use of medication for hypertension and dyslipidaemia
oChange from baseline at week 0 to week 68 in:

Antihypertensive medication (decrease, no change,
increase)

Lipid-lowering medication (decrease, no change,
increase)

Work productivity
oChange from baseline at week 0 to week 68 in the SPS-6, total
score

Treatment discontinuation
oSubjects who from randomisation at week 0 to week 68 have
permanently discontinued randomised trial product (yes/no)
oTime to permanent discontinuation of randomised trial product
o(weeks)

Liver indices
oChange from baseline at week 0 to week 68 in fatty liver index
score category (<30, ≥30 and <60, ≥60)

Urinary incontinence
oChange from baseline at week 0 to week 68 in ICIQ-UI-SF,
sum score (assessed in female subjects)

Diet and physical activity

National Institute for Health and Care Excellence

Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021

Page 10

Summary form

Section Consultee/
Commentator
Comments [sic] Action
oNumber of days per week with at least one entry in the food
diary from baseline at week 0 to week 68
oNumber of minutes per week of physical activity from baseline
at week 0 to week 68
Modelled outcomes include, life expectancy, health-related quality of life
measures, cardiovascular events, incidence of type 2 diabetes, weight
progression over time.
Proposed change
Percentage body fat should not be included as an outcome.
Glycaemic status should be included as an outcome.
Rationale:
Section 1.2.2 of NICE clinical guidelines 189, suggests using BMI as a
practical estimate of percentage body fat (adiposity) in adults. In section 1.2.6
it also does not advocate percentage body fat as a measurement of
overweight or obesity via bioimpedance. This is also supported in section
5.1.3 of the NICE Evidence Review for clinical guideline 43, which states
there is a weak association between BMI and percentage adiposity:
“Adiposity is defined as the amount of body fat expressed as either the
absolute fat mass (in kilograms) or as the percentage of total body mass.
Absolute adiposity is highly correlated with body mass, but percentage
adiposity is relatively uncorrelated with body mass”. Furthermore, percentage
body fat is not routinely collected in UK clinical practice, was not considered
relevant to the recent appraisal of liraglutide for managing overweight and
obesity [TA664].
Treatment with semaglutide 2.4 mg is associated with improvements in
glycaemic status, clinically meaningful weight loss and improvements in other
Comment noted.
Outcomes amended.

National Institute for Health and Care Excellence

Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021

Page 11

Summary form

Section Consultee/
Commentator
Comments [sic] Action
comorbidity markers for patients with obesity. It is anticipated that a
proportion of patients treated with semaglutide 2.4 mg will revert to a normal
glucose levels, greatly reducing the risk of diabetes onset. As such,
glycaemic status is a relevant outcome to be included within the appraisal.
GlaxoSmithKline Yes, we agree with the listed outcomes. Comment noted.
British Obesity
Society
Yes. Comment noted.
The UK Obesity
Organisation
Yes – I think these outcomes will capture the most important health related
benefits.
Comment noted.
Economic
analysis
Novo Nordisk The costs and benefits of semaglutide 2.4 mg vs the relevant comparators
will be modelled over a lifetime horizon with ability for sensitivity analyses at
different time horizons.
Thank you for your
comment. No change to
the scope required.
GlaxoSmithKline No additional comment. Comment noted.
British Obesity
Society
Given the data available, the economic analysis is appropriate. Comment noted.
The UK Obesity
Organisation
This looks appropriate to me. Comment noted.
Equality and
Diversity
Novo Nordisk Socioeconomic status has an influence on the incidence and the impact of
obesity.
The lack of effective treatment options available on the NHS for the medical
management of obesity and lack of well-established obesity services means
that there may be inequity in access to available treatment options.
Thank you for your
comment. These
equalities
considerations are
formally addressed in

National Institute for Health and Care Excellence

Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021

Page 12

Summary form

Section Consultee/
Commentator
Comments [sic] Action
Obesity services are not available universally across England, and only a
fraction of patients who are eligible for these Tiers are referred and seen.
There is also lack of awareness of the services available and their clinical
outcomes accompanied with a certain reluctance to seek help amongst the
patients with obesity.
For BMI an adjustment will be considered for the BMI threshold for treatment
in patients from non-European descent. This is in line with the wording used
in the background for the scope, which some ethnic groups may be at
increased risk of some ill health conditions at lower BMI than people of
European family origin, and therefore some adjustment may be appropriate.
This is similarly reflected in the recent approval of liraglutide for managing
overweight and obesity [TA664] in a population with a BMI of at least 35 kg
per m2(adjust accordingly using lower thresholds for members of minority
ethnic groups known to be at equivalent risk of the consequences of obesity
at a lower BMI than the white population).
the Equalities Impact
Assessment form.
GlaxoSmithKline No additional comment. Comment noted.
British Obesity
Society
Proposed remit does not need changing. Comment noted.
The UK Obesity
Organisation
Stigma is rife when it comes to obesity, I would like to think that the
complexity of obesity is fully understood when evaluating this proposal.
Working to 12-week timelines etc. are just not appropriate for people living
with obesity. We cannot treat chronic conditions with acute solutions. I hope
this will be taken into consideration.
Thank you for your
comment. No change to
the scope required.
Other
considerations
Novo Nordisk Based on clinical guidelines and the prior NICE technology appraisal of
liraglutide [TA664], Novo Nordisk believe there remains a substantial unmet
need amongst patients with BMI ≥27 with comorbidities. This group is of a
particular priority for treatment with semaglutide 2.4 mg, especially those with
Thank you for your
comment. No change to
the scope required.

National Institute for Health and Care Excellence

Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021

Page 13

Summary form

Section Consultee/
Commentator
Comments [sic] Action
comorbidities who may not be eligible for or be able to access liraglutide
3.0mg. If evidence permits, analyses will be explored specifically for sub
populations given the ongoing need for efficacious and well tolerated
treatment options for patients with overweight or obesity and additional
comorbidities.
GlaxoSmithKline No additional comment. Comment noted.
The UK Obesity
Organisation
The urgency that has been highlighted re COVID-19 and the lack of support
and treatment options for people living with obesity (PLWO) should be
considered here.
Thank you for your
comment. No change to
the scope required.
Innovation Novo Nordisk Although the recent approval of liraglutide for managing overweight and
obesity [TA664] is a welcome step change in providing access to a clinically
effective treatment, this approval still represents a relatively small subset of
the overall overweight and obese population. For patients with BMI ≥27 with
comorbidities, many will not be eligible for treatment with liraglutide 3.0 mg,
and therefore a strong clinical need remains for efficacious treatments with
tolerable adverse effects profiles.
Thank you for your
comment. The appraisal
committee will consider
whether there are any
innovative aspects of
semaglutide that are not
adequately captured by
the QALY estimate.
GlaxoSmithKline No additional comment. Comment noted.
British Obesity
Society
This innovation could make a significant impact on health-related benefits,
opening up effective treatment to those unable to tolerate alternative, daily
injected medication.
Thank you for your
comment. No change to
the scope required.
The UK Obesity
Organisation
Yes – Liraglutide has shown some great outcomes and safety data.
Semaglutide has shown even greater outcomes re health benefits and weight
loss. The fact that it is available in tablet and injectable form offers flexibility
for people.
Thank you for your
comment. No change to
the scope required.

National Institute for Health and Care Excellence

Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021

Page 14

Summary form

Section Consultee/
Commentator
Comments [sic] Action
Some of the weight loss data for Semaglutide is not far from what can be
achieved with bariatric surgery, obviously this would be a huge step forward if
people can achieve this with an oral drug or injectable, rather than the risks
and costs associated with surgery.
Questions for
consultation
Novo Nordisk Have all relevant comparators for semaglutide been included in the
scope?
Yes
Which treatments are considered to be established clinical practice in
the NHS for overweight and obesity?
Liraglutide 3.0 mg should be considered for patients with a BMI≥35 with
prediabetes and high CV risk according to TA664.
No pharmacotherapy plus diet and exercise should also be considered for
these patients and for those patients with obesity who fall outside of this
criteria.
How should ‘standard care without semaglutide’ be defined?
Please see responses as provided above. The relevant comparators for this
appraisal are liraglutide (for those who have a body mass index (BMI) of at
least 35 kg per m2, have non-diabetic hyperglycaemia and have a high risk of
cardiovascular disease) and standard of care is likely to involve general
counselling on lifestyle measures, which is defined as diet and physical
activity in section 1.3.6 of NICE clinical guideline 189.
Are the outcomes listed appropriate?
Thank you for your
comment. No further
change to the scope
required.
Thank you for your
comment. Liraglutide is
listed as a comparator.
Thank you for your
comment. These are
listed as comparators in
the scope.
Thank you for your
comment. Please see
response in the

National Institute for Health and Care Excellence

Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021

Page 15

Summary form

Section Consultee/
Commentator
Comments [sic] Action
As mentioned above, percentage body fat is not considered an appropriate
measure for BMI and should not be listed as an outcome. The other
outcomes listed are appropriate, however they are not exhaustive. Therefore
additional suggested outcomes not listed in the scope e.g. impact on
glycaemic status and prediabetes will be presented alongside those listed.
Are there any subgroups of people in whom semaglutide is expected to
be more clinically effective and cost effective or other groups that
should be examined separately?
As explained in the ‘Other considerations’ section above, based on clinical
guidelines and the prior NICE technology appraisal of liraglutide [TA664],
Novo Nordisk believe there is a substantial unmet need for patients with BMI
≥27 with comorbidities for whom there are limited treatment options.
Particularly those who are not eligible for treatment with liraglutide 3.0 mg.
This group is a particular priority for treatment with semaglutide 2.4 mg. If
evidence permits analyses will be explored specifically for this population
given the ongoing need for efficacious and well tolerated treatment options for
patients with obesity and additional comorbidities. If justified, further analyses
will be presented on subpopulations with specific comorbidities and various
BMI cut offs.
Where do you consider semaglutide will fit into the existing NICE
pathway, Obesity?
As mentioned above, there remains a substantial unmet need for patient with
obesity and various weight related comorbidities. If evidence permits,
semaglutide 2.4 mg may be best positioned as a treatment for patients with
BMI ≥27 with comorbidities in addition to diet and exercise.
NICE is committed to promoting equality of opportunity, eliminating
unlawful discrimination and fostering good relations between people
‘outcomes’ section
above.
Thank you for your
comment. Semaglutide
will be appraised within
its marketing
authorisation. No further
change to the scope
required.
Thank you for your
comment.

National Institute for Health and Care Excellence

Page 15 of 18 Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021

Page 16

Summary form

Section Consultee/
Commentator
Comments [sic] Action
with particular protected characteristics and others. Please let us know
if you think that the proposed remit and scope may need changing in
order to meet these aims. In particular, please tell us if the proposed
remit and scope:

could exclude from full consideration any people protected by the
equality legislation who fall within the patient population for which
semaglutide will be licensed;
Novo Nordisk does not believe the proposed remit and scope could exclude
any people protected by the equality legislation who fall within the patient
population eligible for semaglutide.

could lead to recommendations that have a different impact on
people protected by the equality legislation than on the wider
population, e.g. by making it more difficult in practice for a specific
group to access the technology;
Novo Nordisk does not believe the proposed remit and scope could lead to
recommendations that have a different impact on people protected by the
equality legislation than on the wider population.

could have any adverse impact on people with a particular disability
or disabilities.
Novo Nordisk does not believe the proposed remit and scope could have any
adverse impact on people with a particular disability or disabilities.
Please tell us what evidence should be obtained to enable the
Committee to identify and consider such impacts.
Thank you for your
comment.
Thank you for your
comment.
Thank you for your
comment.

National Institute for Health and Care Excellence

Page 16 of 18 Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021

Page 17

Summary form

Section Consultee/
Commentator
Comments [sic] Action
N/A
Do you consider semaglutide to be innovative in its potential to make a
significant and substantial impact on health-related benefits and how it
might improve the way that current need is met (is this a ‘step-change’
in the management of the condition)?
Yes. Semaglutide provides a clinically efficacious and tolerable once-weekly
treatment option for people with obesity.
Do you consider that the use of semaglutide can result in any potential
significant and substantial health-related benefits that are unlikely to be
included in the QALY calculation?
Obesity is a complex condition that impacts on a patient’s physical, social and
psychological wellbeing. Accounting for all of these aspects in an economic
model is also complex. Novo Nordisk has developed an obesity model which
takes into account conditions which have a strong relationship with obesity
according to the WHO and therefore may underestimate health-related
benefits associated with all conditions that may benefit from weight loss such
as the risk of hospitalisation and mortality from infectious diseases including
COVID-19. PHE’s evidence review of excess weight and Covid-19 found
people with obesity are at greater risk of hospitalisation, Intensive Care Unit
(ICU) admission and death from Covid-19, with risk growing substantially as
BMI increases.
Please identify the nature of the data which you understand to be
available to enable the Appraisal Committee to take account of these
benefits.
Thank you for your
comment.
Thank you for your
comment. Please see
response in the
‘innovation’ section
above.
Thank you for your
comment.

National Institute for Health and Care Excellence

Page 17 of 18 Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021

Page 18

Summary form

Section Consultee/
Commentator
Comments [sic] Action
Novo Nordisk will include a utility value per BMI increment, which can be
varied in a sensitivity analysis. A review of relevant epidemiology will be
presented to substantiate the association between BMI and longer-term
complications not directly measured in the model.
To help NICE prioritise topics for additional adoption support, do you
consider that there will be any barriers to adoption of this technology
into practice? If yes, please describe briefly.
Obesity is considered a chronic disease that requires holistic, long-term
management with appropriate interventions. Typically there has been
underinvestment in weight management services damaging the ability for
patients to routinely, and equitably access effective interventions. If approved
semaglutide 2.4 mg would be introduced as a welcome additional to the
current standard of care and increase opportunity for access to the patients
most in need.
Thank you for your
comment.
The UK Obesity
Organisation
I feel these have been answered above. Comment noted.

National Institute for Health and Care Excellence

Page 18 of 18 Consultation comments on the draft remit and draft scope for the technology appraisal of semaglutide for managing overweight and obesity [ID3850] Issue date: May 2021