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IfPA is concerned that ICER’s draft evidence report, dated October 2, 2017, undervalues the benefits that tardive dyskinesia (TD) patients can receive from VMAT2 inhibitors. This undervaluation arises because of the reasons described below.

1. The base model does not incorporate the benefit of TD patients’ improved adherence to their antipsychotic medicines.

2. The cost-effectiveness model is biased against VMAT 2 inhibitors.

3. There is an association between tardive dyskinesia and more severe psychopathology.

4. ICER’s assumption that there is no association between tardive dyskinesia and increased mortality is likely overstated.

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