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