Current documents on the EU-HTA process and opportunity to provide feedback

The draft proposes a considerable change compared to the approach discussed by the EUnetHTA21 project in regard to the assessment scope. Expectations were, that EU member states would submit their PICO questions which – after consolidation to avoid duplications – would all become part of a set of PICO questions to be answered by the pharmaceutical company. PICO exercises conducted on this basis for three pharmaceuticals led to 5, 6 and 9 PICOs with only 8 respectively 10 member states participating in the excercises. This fueled concerns that full participation of Member States could lead to even more PICOS.

The draft implementing act addresses this challenge by a modified approach. It suggests that assessor and co-assessor shall prepare an assessment scope proposal based on information submitted by the pharmaceutical company to the HTA secretariat at the same time they submit their marketing authorization. The information requested is the draft SMPC and the clinical overview section.

The assessors shall then share their assessment scope proposal with members of the JCA subgroup and – based on the input received from Member States - shall prepare a consolidated assessment scope reflecting Member States´ needs whose rights to submit PICO questions are not restricted. This modified approach may open a route to reduce the anticipated large number of PICO questions by following a kind of moderated development of the assessment scope based on a proposal by the assessors as a basis for the Member States.

The draft implementing act includes detailed procedural rules including the exchange of information with EMA, the – still short – time to prepare a dossier by pharmaceutical companies and even shorter deadlines (7 to 30 days) to submit additional data if requested.

This deadline also remains a huge challenge for companies as it also applies to the submission of updated dossiers after changes to the assessment scope following label changes during EMA´s marketing authorization procedure. Here the strict deadlines inscribed to the EU HTA regulation obviously prevent other timelines.

The draft also includes annexes, inter alia the draft dossier template.

As EU HTA stakeholder, the IGES Institute and companies of the IGES Group have been intensively involved in the discussions and consultations of EUnetHTA21 and have prepared for the application of the regulation.

The companies of the IGES Group, with their many years of experience in HTA procedures in EU countries, support pharmaceutical companies, manufacturers of medical devices and other stakeholders in the implementation of the EU HTA Regulation.