TA939/Scope Consultation Comments
Page 1

Summary form

National Institute for Health and Care Excellence

Single Technology Appraisal (STA)

Pembrolizumab in combination with platinum-based chemotherapy for treating recurrent, persistent or metastatic cervical cancer

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 MSD We suggest
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
Thank you for your
comment. The wording
of the draft remit is
written as per the
current NICE style to
ensure consistency
across all scopes and
appraisals. No changes
were made to the
scope.
British
Gynaecological
Cancer Society
Generally happy, please expand in particular to consider PDL1, TMB and MSI
status (see later on)
Thank you. No action
required.
Jo’s Cervical
Cancer Trust
Yes, we believe so [the wording of the remit is appropriate]. Thank you. No action
required.

National Institute for Health and Care Excellence

Pembrolizumab in combination with platinum-based chemotherapy for treating recurrent, persistent or metastatic cervical cancer Issue date: January 2022

Page 2

Summary form

Section Consultee/
Commentator
Comments [sic] Action
Timing Issues MSD We anticipate that the proposed appraisal should be scheduled to enable
NICE to issue final guidance soon after regulatory approval. Information
regarding anticipated regulatory timelines presented in UK PharmaScan
accurately reflect current expectations.
Thank you for your
comment. NICE aims to
publish guidance as
soon as possible after
the company receives
the marketing
authorisation and
introduces the
technology in the UK.
NICE has scheduled
this topic into its work
programme.
British
Gynaecological
Cancer Society
Routine [timing]. Thank you. No action
required.
Jo’s Cervical
Cancer Trust
There is currently a lack of choice / options for women with late stage cervical
cancer with just one life prolonging drug with limited results (e.g. 3-4 months),
therefore being able to offer increased options is important.
Current chemotherapy options have challenging side effects and therefore a
drug that can reduce these and improve quality of life is important.
Anecdotally we are hearing reports of an increase in women with advanced
stage cancers entering pathways due to later diagnosis as a result of the
COVID pandemic and we need to ensure that we are not failing this group.
Thank you for your
comment. NICE aims to
publish guidance as
soon as possible after
the company receives
the marketing
authorisation and
introduces the
technology in the UK.
NICE has scheduled
this topic into its work
programme.

National Institute for Health and Care Excellence

Pembrolizumab in combination with platinum-based chemotherapy for treating recurrent, persistent or metastatic cervical cancer Issue date: January 2022

Page 3

Summary form

Section Consultee/
Commentator
Comments [sic] Action
Additional
comments on the
draft remit
MSD No further comment. Noted. No action
required.
British
Gynaecological
Cancer Society
No additional comments. Noted. No action
required.
Jo’s Cervical
Cancer Trust
No additional comments. Noted. No action
required.

Comment 2: the draft scope

Section Consultee/
Commentator
Comments [sic] Action
Background
information
MSD We suggest a change to the wording used to define the stages for clarity.
Locally advanced cancer is defined as stage 1B2 to 4A (1) and metastatic is
defined as cervical cancer at stage IVB (2)
The word ‘metastatic’ should be removed from “there were 2,591 newly
diagnosed cases of metastatic cervical cancer”. The number referenced is the
total number of registrations in England during 2017 for cervical cancer.
Data from Public Health England (3) shows the percentage of people
diagnosed at each stage during 2018 was 46.4% for stage 1, 16.1% stage 2,
6.5% stage 3, 8.8% stage 4 and 22.1% had missing stage information. Using
these numbers would mean 228 patients diagnosed in 2017 with stage 4
(metastatic) cervical cancer.
Thank you for your
comment. The
background section of
the scope has been
updated to include the
definitions of the stages
and remove the word
‘metastatic’.
British
Gynaecological
Cancer Society
Please expand to:
1]include Gynaecologic Oncology Group prognostic model to predict treatment
response to cisplatin-based chemotherapy (Black race, Performance status,
Thank you for your
comment. The
background section of
the scope aims to

National Institute for Health and Care Excellence

Pembrolizumab in combination with platinum-based chemotherapy for treating recurrent, persistent or metastatic cervical cancer Issue date: January 2022

Page 4

Summary form

Section Consultee/
Commentator
Comments [sic] Action
pelvic disease, prior treatment with cisplatin, recurrence within 1 year of
diagnosis) (Moore Gynaecol Oncology 2010)
2]the additional benefit that bevacizumab offers when combined to platinum
paclitaxel backbone
3]effect of PDL1, TMB-tumour and MSI-H impact on response to
pembrolizumab
4]assessment of prior therapies, residual toxicities and performance status in
selecting appropriate second line therapy, options include pembrolizumab,
chemotherapy and palliative / Best supportive care
5]The published available data is beyond the first line setting. Does company
have data in the first line setting?
provide a brief summary
of the disease and how
it is managed, it is not
designed to be
exhaustive in its detail.
No changes were made
to the scope.
Jo’s Cervical
Cancer Trust
Yes [the background information is accurate and complete]. Thank you. No action
required.
The technology/
intervention
MSD Yes [the description of the technology is accurate]. Thank you. No action
required.
British
Gynaecological
Cancer Society
It [the technology description] needs updating to include particularly Tumour
Mutational Burden Data. Also to discuss Microsatellite instability / deficient
mismatch repair data
Thank you for your
comment. The
technology section is
intended only to briefly
outline the technology;
it is not designed to be
exhaustive in its detail.
No changes were
made.
Jo’s Cervical
Cancer Trust
We believe so [the description of the technology is accurate]. Thank you. No action
required.

National Institute for Health and Care Excellence

Pembrolizumab in combination with platinum-based chemotherapy for treating recurrent, persistent or metastatic cervical cancer Issue date: January 2022

Page 5

Summary form

Section Consultee/
Commentator
Comments [sic] Action
Population MSD We suggest “Adults (18 and over)” for clarity.
The primary endpoints will be assessed in combined positive score (CPS) ≥1
to <10, ≥10 and all-comers. Currently no data has been presented on
outcomes by these groups.
Thank you for your
comment. The wording
of the population is
written as per the
current NICE style to
ensure consistency
across all scopes and
appraisals. Ages are
only added for children
and adolescents. No
changes were made to
population wording. The
combined positive score
of PD-L1 expression
level has been added to
the ‘Other
considerations’ section
of the scope.
British
Gynaecological
Cancer Society
Possibly of Black ethnicity Thank you for your
comment. The
committee will consider
whether its
recommendations could
have a different impact
on people protected by
the equality legislation
than on the wider
population.

National Institute for Health and Care Excellence

Pembrolizumab in combination with platinum-based chemotherapy for treating recurrent, persistent or metastatic cervical cancer Issue date: January 2022

Page 6

Summary form

Section Consultee/
Commentator
Comments [sic] Action
Jo’s Cervical
Cancer Trust
Yes [the population is defined appropriately]. Thank you. No action
required.
Comparators MSD We suggest the removal of etoposide in combination with platinum therapy.
According to Royal Surrey guidelines (4) this is used in the treatment of small
cell cervical cancer (SCCC). SCCC accounts for 3% of all cervical cancers (5).
After reviewing publicly available cancer alliance guidelines, we also suggest
the removal of ‘paclitaxel alone’. Only one Cancer Alliance lists paclitaxel as an
option for palliative treatment but in the second line setting.
Bevacizumab in combination with paclitaxel and cisplatin or carboplatin, should
be included as per BGCS guidelines (6).

Platinum chemotherapy (cisplatin or carboplatin) alone or in combination
with paclitaxel or topotecan or etoposide

Paclitaxel alone.
Thank you for your
comment. At the
scoping stage of the
appraisal, identification
of comparators should
be inclusive. Because
etoposide is used in
cervical cancer, it has
been retained in the
scope. Any exclusion
from the decision
problem in the company
submission should be
fully justified and will be
considered during the
course of the appraisal.
Following the
discussions at the
scoping Zoom,
bevacizumab in
combination with
paclitaxel and
carboplatin has been
added to the scope for
people who receive it
via the Cancer Drugs
Fund. We acknowledge
paclitaxel alone is used

National Institute for Health and Care Excellence

Pembrolizumab in combination with platinum-based chemotherapy for treating recurrent, persistent or metastatic cervical cancer Issue date: January 2022

Page 7

Summary form

Section Consultee/
Commentator
Comments [sic] Action
in second line setting so
it has been removed.
British
Gynaecological
Cancer Society
First line systemic therapy in the UK is generally accepted to be platinum +
taxane +/- bevacizumab.
If you wish to look at the combination regimen of Pembro + other SACT in the
first line for cervical cancer, then your comparison groups should be:
1] platinum + taxane +bevacizumab (in the UK this is mainly carboplatin +
paclitaxel + bevacizumab)
2) platinum taxane without bevacizumab (in the UK this is mainly carboplatin
and paclitaxel).
Thank you for your
comment. Following the
discussions at the
scoping Zoom,
bevacizumab in
combination with
paclitaxel and
carboplatin has been
added to the scope for
people who receive it
via the Cancer Drugs
Fund.
Jo’s Cervical
Cancer Trust
Yes [these are the standard treatments currently used in the NHS with which
the technology should be compared].
Thank you. No action
required.
Outcomes MSD We suggest the inclusion of “duration of response” Thank you for your
comment. It is not
considered necessary
to specify ‘duration of
response’ as an
outcome in addition to
‘progression-free
survival’ that is already
included in the scope.
No changes were
made.

National Institute for Health and Care Excellence

Pembrolizumab in combination with platinum-based chemotherapy for treating recurrent, persistent or metastatic cervical cancer Issue date: January 2022

Page 8

Summary form

Section Consultee/
Commentator
Comments [sic] Action
British
Gynaecological
Cancer Society
Appropriate outcome data, please also seek any randomised data against
chemotherapy.
Thank you. No action
required.
Jo’s Cervical
Cancer Trust
Yes [these outcome measures capture the most important health related
benefits (and harms) of the technology].
Thank you. No action
required.
Economic
analysis
MSD None identified, no further comment. Noted. No action
required.
British
Gynaecological
Cancer Society
No comments. Noted. No action
required.
Jo’s Cervical
Cancer Trust
No comments. Noted. No action
required.
Equality and
Diversity
MSD None identified, no further comment. Noted. No action
required.
British
Gynaecological
Cancer Society
Ensure that patients of Black ethnicity are adequately assessed / represented Thank you for your
comment. The
population in the scope
is ‘Adults with untreated
recurrent, persistent or
metastatic cervical
cancer’. The appraisal
committee will assess
the technology using
the data presented to it
in the company

National Institute for Health and Care Excellence

Pembrolizumab in combination with platinum-based chemotherapy for treating recurrent, persistent or metastatic cervical cancer Issue date: January 2022

Page 9

Summary form

Section Consultee/
Commentator
Comments [sic] Action
submission documents.
No action required.
Jo’s Cervical
Cancer Trust
No comments. Noted. No action
required.
Other
considerations
MSD Patients with squamous cell carcinoma, adenosquamous carcinoma, or
adenocarcinoma of the cervix were eligible to be recruited to KEYNOTE-826.
Thank you for your
comment. Following
discussion at the
scoping Zoom,
adenosquamous
carcinoma and poorly
differentiated carcinoma
have been added to the
list of subgroups that
will be considered if the
evidence allows.
British
Gynaecological
Cancer Society
Pembrolizumab for second line cervical cancer systemic therapy is an
available option in NCCN guidelines.
Technology has the potential to improve outcomes in selected patients with
recurrent, persistent or metastatic cervical cancer, such subgroups that are
most likely to benefit should be explored as well as overall groups and groups
defined by histology (squamous vs adenocarcinomas).
1]include Gynaecologic Oncology Group prognostic model to predict treatment
response to cisplatin-based chemotherapy (Black race, Performance status,
pelvic disease, prior treatment with cisplatin, recurrence within 1 year of
diagnosis) (Moore Gynaecol Oncology 2010)
Thank you for your
comment. Following
discussions at the
scoping Zoom,
subgroups defined by
histology, pelvic
disease status,
programmed death-
ligand 1 (PD-L1)
expression and tumour
mutational burden were
included in the scope.

National Institute for Health and Care Excellence

Pembrolizumab in combination with platinum-based chemotherapy for treating recurrent, persistent or metastatic cervical cancer Issue date: January 2022

Page 10

Summary form

Section Consultee/
Commentator
Comments [sic] Action
2]effect of PDL1, TMB-tumour and MSI-H impact on response to
pembrolizumab
3]assessment of prior therapies, residual toxicities and performance status in
selecting appropriate second line therapy, options include pembrolizumab,
chemotherapy and palliative / Best supportive care
Subgroups specified
within Gynaecologic
Oncology Group
prognostic model
(except pelvic disease)
were not added to the
scope because they
included groups
protected by equality
legislation or were not
considered relevant to
the decision problem.
Subgroups defined by
microsatellite instability
(MSI) were not added
because MSI is rare
and not assessed in
clinical practice.
Jo’s Cervical
Cancer Trust
As touched on earlier there is a lack of life prolonging treatments for cervical
cancer patients. This treatment would give more equality to patients allowing
greater options in terms of advanced stage care that is long overdue.
Thank you. No action
required.
Innovation MSD MSD considers pembrolizumab to be innovative in its potential to make a
significant and substantial positive impact on health-related benefits.
Pembrolizumab in combination with chemotherapy has the potential to improve
outcomes for patients receiving treatment in adults with recurrent, persistent or
metastatic cervical cancer.
Thank you for your
comment. The
submissions can
expand on the potential
innovative nature of the
technology, in particular
its potential to make a
significant and
substantial impact on

National Institute for Health and Care Excellence

Pembrolizumab in combination with platinum-based chemotherapy for treating recurrent, persistent or metastatic cervical cancer Issue date: January 2022

Page 11

Summary form

Section Consultee/
Commentator
Comments [sic] Action
Pembrolizumab would be the first anti-PD-1 pathway targeting agent to be
approved for the first line treatment of adults with recurrent, persistent or
metastatic cervical cancer, and would represent a step-change in the
management of these patients.
health-related benefits
that are unlikely to be
included in the QALY
calculation during the
assessment. No action
required.
British
Gynaecological
Cancer Society
Technology has the potential to improve outcomes in selected patients with
recurrent, persistent or metastatic cervical cancer, such subgroups that are
most likely to benefit should be explored as well as overall groups. Please see
under Background information.
Thank you for your
comment. The
submissions can
expand on the potential
innovative nature of the
technology, in particular
its potential to make a
significant and
substantial impact on
health-related benefits
that are unlikely to be
included in the QALY
calculation during the
assessment. No action
required.
Jo’s Cervical
Cancer Trust
It would be considered innovative as it is using technology not currently used in
the treatment of cervical cancer.
Feedback we have received is that the health-related benefits are that it is well
tolerated by private patients in the UK as well as throughout Europe with fewer
side effects.
Thank you for your
comment. The
submissions can
expand on the potential
innovative nature of the
technology, in particular
its potential to make a
significant and

National Institute for Health and Care Excellence

Pembrolizumab in combination with platinum-based chemotherapy for treating recurrent, persistent or metastatic cervical cancer Issue date: January 2022

Page 12

Summary form

Section Consultee/
Commentator
Comments [sic] Action
substantial impact on
health-related benefits
that are unlikely to be
included in the QALY
calculation during the
assessment. No action
required.
Questions for
consultation
MSD Have all relevant comparators for pembrolizumab with chemotherapy
been included in the scope?

Which treatments are considered to be established clinical
practice in England for untreated recurrent, persistent or
metastatic cervical cancer?

What are the most commonly used chemotherapy regimens used
in clinical practice for untreated recurrent, persistent or metastatic
cervical cancer?
A: We expect the first line treatment used would be systemic chemotherapy
with cisplatin/paclitaxel or carboplatin/paclitaxel doublets with or without
bevacizumab depending on any patient risk factors as per the BGCS
guidelines.
Are the outcomes listed appropriate?
A: Yes; we do however ask that the “Duration of response” is also included in
the list of outcomes
Are the subgroups suggested in ‘Other considerations’ appropriate?
A: No further comment
Thank you for your
comment. No action
required.

National Institute for Health and Care Excellence

Pembrolizumab in combination with platinum-based chemotherapy for treating recurrent, persistent or metastatic cervical cancer Issue date: January 2022

Page 13

Summary form

Section Consultee/
Commentator
Comments [sic] Action
Are there any other subgroups of people in whom pembrolizumab is
expected to be more clinically effective and cost effective or other
groups that should be examined separately?
A: None at this time
Where do you considered pembrolizumab will fit into the existing NICE
pathway, Cervical cancer (2018).
A: We anticipate that the use of pembrolizumab in combination with
chemotherapy will be in the first line setting.
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
pembrolizumab will be licensed;

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 pembrolizumab;

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.
A: No impact
Do you consider pembrolizumab 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)?

National Institute for Health and Care Excellence

Pembrolizumab in combination with platinum-based chemotherapy for treating recurrent, persistent or metastatic cervical cancer Issue date: January 2022

Page 14

Summary form

Section Consultee/
Commentator
Comments [sic] Action
A: Yes
Do you consider that the use of pembrolizumab can result in any
potential significant and substantial health-related benefits that are
unlikely to be included in the QALY calculation?
A: We do not consider that there will be substantial health-related benefits that
are unlikely to be included in the QALY calculation.
Please identify the nature of the data which you understand to be
available to enable the Appraisal Committee to take account of these
benefits.
N/A
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.
A: None.
British
Gynaecological
Cancer Society
No comments. Noted. No action
required.
Jo’s Cervical
Cancer Trust
No comments. Noted. No action
required.
MSD No further comment. Noted. No action
required.

National Institute for Health and Care Excellence

Pembrolizumab in combination with platinum-based chemotherapy for treating recurrent, persistent or metastatic cervical cancer Issue date: January 2022

Page 15

Summary form

Section Consultee/
Commentator
Comments [sic] Action
Additional
comments on the
draft scope
British
Gynaecological
Cancer Society
No comments. Noted. No action
required.
Jo’s Cervical
Cancer Trust
No comments. Noted. No action
required.

The following consultees/commentators indicated that they had no comments on the draft remit and/or the draft scope Novartis Pharmaceutical UK Ltd

National Institute for Health and Care Excellence

Pembrolizumab in combination with platinum-based chemotherapy for treating recurrent, persistent or metastatic cervical cancer Issue date: January 2022