• EU HTAR: Shaping the Future of Health Technology Assessment in the European Union

    EU HTAR: Shaping the Future of Health Technology Assessment in the European Union
    EU HTAR: Shaping the Future of Health Technology Assessment in the European Union

    Health technology assessment (HTA) is pivotal in the intricate landscape of today’s contemporary healthcare system. By meticulously and transparently consolidating data regarding the application of innovative technologies, HTA contributes to safeguarding patient safety, enhancing effectiveness, and maximizing overall value of healthcare services. This evidence-driven methodology supports informed decision-making and the formulation of health policies, ultimately resulting in the best possible outcomes. The Health Technology Assessment Regulation (HTAR) established by the European Union (EU) represents a significant advancement by creating a cohesive HTA framework across the EU.[1]

    Enacted by the European Commission, this pioneer legislation will provide a single unified framework for the evaluation of medical novelties across the member states, which ensures their safety and accessibility in order to bring about breakthroughs in patient care. The EU HTAR became effective in December 2021 and shall fully come into function from January 2025. It is not just a mere update in the procedures of HTA, but a strategic shift towards an effective healthcare system in the EU. Conceived to unify fragmented HTAs, it streamlines processes to eliminate redundancies and expedite the delivery of cutting-edge health technologies to patients. By fostering innovation and ensuring faster access to treatments, the EU HTAR establishes a common framework for collaboration among national HTA bodies in the EU, enhancing market access for healthcare technologies across Europe.[2-4] The journey of the EU HTAR began in 2018, culminating in its adoption in December 2021. Among the key features of the EU HTAR are the Joint Clinical Assessments (JCA), Joint Scientific Consultations (JSC), horizon scanning activities, and voluntary cooperation in areas outside the scope of mandatory cooperation.[5]

    The JCA is a joint initiative of the European Medicines Agency (EMA) with national HTA agencies, aiming at assessing clinical benefit and evaluating the cost-effectiveness of drugs with a view to their pricing and reimbursement at the national level. The JSC, on the other hand, streamlines logistics to maximize gains by optimizing opportunities for mutual understanding between regulators and HTAs. This promotes optimal and robust evidence generation fit-for-purpose for both regulators and HTA bodies, ultimately resulting in benefits for public health by enabling access to medicines that are effective for European patients.[6-7]

    The long-awaited draft implementing act on procedural rules for JCA of medicinal products was published in March 2024 confirming the timelines and procedures previously laid out by the European Commission. The implementing regulation specifies that to allow sufficient time for a high-quality JCA, the clinical assessment should be initiated at the same time as the marketing authorization procedure, specifically upon the EMA’s confirmation of a valid submission of an application for marketing authorization. Additionally, the final JCA report shall also be endorsed by the HTA Coordination Group (HTACG) no later than 30 days after the date of adoption of the European Commission decision granting marketing authorization for the medicinal product under evaluation. If changes occur during the regulatory process, such as changes in the therapeutic indication compared to the initially submitted one or a variation to the terms of existing marketing authorization, timelines for the JCA may be significantly delayed, depending on the extent of the impact of such changes.[8]

    Implementing the EU HTAR presents challenges, such as harmonizing methodologies and ensuring the active participation of all stakeholders in the JCA and JSC processes. For pharmaceutical and medical device makers, the regulation implies a pivot towards a more centralized European procedure for clinical evidence evaluation, impacting how they approach data generation and submission for the HTA process. There could also be some important challenges brought to the pharmaceutical manufacturers by the virtue of the new EU legislation. One major concern is the potentially onerous data requirements, which include multiple PICOs criteria (Population, Intervention, Comparator, and Outcome) for off-label treatments. One of the most important challenges that should be expected is the management of timelines because the final PICOs will only be known about 90 days prior to the JCA submission deadline, which typically leaves very little time to complete the evidence-generation process through meticulous and resource-intensive procedures such as systematic literature reviews, indirect treatment comparisons, and cost-effectiveness analysis using complex pharmacoeconomic models. This means that early engagement with local affiliates and key external stakeholders (payers, healthcare providers, patient organizations) will be crucial to understanding differences in clinical practice between Member States that will impact the scope of work.[9]

    Concerns have been raised about the impact on smaller companies and the overall attractiveness of Europe for investment in healthcare innovation. The workload and limited engagement with industry during the development of the JCA process present a paradox: while the original goal was to reduce the overall workload, it might have the opposite effect, particularly as the process will be needed for all new oncology and Advanced therapy medicinal products (ATMPs).[8]

    In conclusion, the new EU HTAR signals a transformative era in EU regulatory oversight, driving towards a more integrated and efficient approach to the HTA process. Manufacturers must proactively address the procedural and evidence-generation challenges ahead. While the new framework presents initial hurdles, it promises streamlined evaluations, reduced redundancy, and accelerated access to innovative treatments across Europe. Successful navigation of EU HTAR implementation will require active engagement from all stakeholders, including regulatory bodies, healthcare providers, manufacturers, and patients.

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    References:

    1. Wild C, Stricka M, Patera N. Guidance for the development of a National HTA-strategy. Health Policy and Technology. 2017 Sep 1;6(3):339-47.
    2. European Commission. Regulation on Health Technology Assessment. Retrieved from Regulation on Health Technology Assessment – European Commission (europa.eu).
    3. European Commission. Questions and Answers: Adoption of Regulation on Health Technology Assessment. Retrieved from QANDA_21_6773_EN.pdf (europa.eu).
    4. Desmet T, Brijs M, Vanderdonck F, Tops S, Simoens S, Huys I. Implementing the EU HTA regulation: Insights from semi-structured interviews on patient expectations, Belgian and European institutional perspectives, and industry outlooks. Frontiers in Pharmacology. 2024 Apr 10;15:1369508.
    5. The European Parliament and the Council of the European Union. Regulation (EU) 2021/2282 of the European Parliament and of the Council of 15 December 2021 on Health Technology Assessment and amending Directive 2011/24/EU2021 22.12.2021. Available online: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32021R2282&from=EN.
    6. EU Joint Clinical Assessments: Theory vs Practice. Retrieved from PharmaBoardroom – EU Joint Clinical Assessments: Theory vs Practice. Accessed on 4 Jun, 2024.
    7. Klaar S. Joint Scientific Consultations – Advice for EU Health Technology Assessment. NDA Whitepaper. 2024
    8. European Commission. The EU regulation on health technology assessment: what’s in it and why it matters? https://health.ec.europa.eu/document/download/855247c3-cda9-4645-99f7-7098836f314c_en?filename=ev_20240409_co01_en.pdf.
    9. Open Health. European Health Technology Assessment Regulation: Implications for the industry and the 5 key areas for successful implementation. EU HTAR – What are its implications for the industry + infographic (hubspotusercontent-na1.net).
  • The Role of PICOS Framework in EuNetHTA’s Joint Clinical Assessment

    The Role of PICOS Framework in EuNetHTA’s Joint Clinical Assessment
    The Role of PICOS Framework in EuNetHTA's Joint Clinical Assessment

    In Europe, the European Network for Health Technology Assessment (EuNetHTA), is the one tool, driving the conduct of health technology assessment (HTA) process. The Joint Clinical Assessment (JCA) is the central activity in this evaluation, that compares the relative clinical effectiveness and safety of emerging health technologies. As a way of arriving at a comprehensive and transparent assessment, the Population, Intervention, Comparison, Outcome, Study Design (PICOS) framework is widely employed. This, in turn, structured the approach so all critical aspects of the assessment are covered in a systematic way.[1]

    EuNetHTA is a network of collaboration between various HTA organizations spread across the EU member states. The principle objectives of EUNetHTA include streamlining and harmonizing the HTA process to ensure consistency, transparency, and efficiency in the health technology evaluation. It lists JCA as its core feature, providing robust evidence of safety and clinical efficacy for new health technologies compared with available alternatives. These are important assessments to be used at the national level to inform decision-making processes on the reimbursement and eventual adoption of these technologies by different healthcare systems. The JCA process is well organized, from formulating the research question all the way through to finalizing it with clarity and precision. This research question is fundamental to the entire assessment process and is directly informed by the PICOS framework.[2]

    The correlation between EuNetHTA and the PICOS framework is evident in the structured approach used to formulate the JCA research question. Each element of PICOS directly informs the corresponding aspects of the JCA. The JCA specifies the patient population for which the new technology is intended, aligning with the population component of PICOS. For instance, a JCA might focus on the effectiveness of a new drug for treating heart failure in patients with a specific genetic profile. The health technology being assessed is clearly defined in the JCA, reflecting the intervention component of PICOS. This could be, for instance, a novel surgical technique against some form of cancer or a new gene therapy for a type of genetic disorder. The JCA identifies the most appropriate comparator for the new technology, aligning with the comparison component of PICOS. This could be the current standard of care, a placebo control, or another alternative intervention. The JCA defines relevant clinical outcomes for assessing the impact of the new technology, corresponding to the outcome component of PICOS. Outcomes could include mortality rates, prevention of specific events, improvements in symptoms, disease progression, or cost-effectiveness measures. The JCA ensures that the assessment is based on rigorous and scientifically sound study designs, reflecting the study design component of PICOS.[2,3]

    The integration of the PICOS framework within the JCA process offers several significant benefits. PICOS ensures a clear and well-defined research question, promoting transparency and facilitating efficient communication among stakeholders involved in the JCA. PICOS provides a structured and systematic method for defining the scope of the assessment and identifying relevant evidence for evaluation. By establishing a standardized framework, PICOS allows for comparisons between different JCA reports across Europe, promoting consistency and harmonization. The structured nature of PICOS enhances the reproducibility of the JCA, allowing for easier replication of the assessment by other researchers or healthcare institutions.[2,3]

    Aligning with EuNetHTA’s PICOS is crucial for pharmaceutical companies developing new health technologies.  A well-defined PICOS framework during the HTA or SLR conducted by the company ensures a smooth transition to the JCA process.  By mirroring the PICOS elements used by EuNetHTA, companies can streamline the assessment process, anticipate potential information requests, and ultimately expedite regulatory approval.  Furthermore, considering the PICOS framework during the design of pivotal clinical trials allows companies to gather the most relevant data required for a successful JCA. This proactive approach minimizes the need for additional data collection during the JCA stage, saving time and resources for both companies and regulatory bodies.[3]

    Despite its advantages, implementing the PICOS framework within EuNetHTA presents several challenges. Disparities among nations regarding expected endpoints and comparators can result in a high number of PICO parameters. Harmonizing these parameters is essential but challenging, requiring collective efforts across diverse healthcare systems. Different countries may have different requirements and preferences for the exact same PICO question, complicating the scoping phase of EuNetHTA process. Reaching a consensus on these research questions is crucial for a holistic assessment approach. Pharmaceutical companies often face hurdles due to limited early engagement opportunities in the centralized HTA process. Early engagement is critical for aligning the assessment with industry expectations and ensuring comprehensive evaluations. The lack of a requirement for consolidated advice engagement can lead to inconsistencies in the assessment process. Consolidated advice is essential for maintaining a harmonized approach and ensuring all relevant aspects are considered. There is often a lack of consensus on appropriate methodologies, with existing guidelines sometimes viewed as insufficiently flexible for novel or pragmatic approaches. This can hinder the implementation of innovative assessment methods.[4]

    Multiple strategies can be utilized to tackle these like, ensuring the JCA process Involves early participation of all relevant stakeholders, including healthcare professionals, patient cohorts, and technology manufacturers, in order to guarantee a comprehensive understanding of healthcare needs. Extensive literature reviews and evidence synthesis, applying elements of the PICOS criterion represent a solid foundation for the assessment. Maintaining flexibility in the PICOS framework allows for adjustments based on new information or insights, enhancing the accuracy of the assessment. Developing standardized approaches and best practices for applying PICOS in JCAs contributes to consistency and facilitates knowledge sharing among EuNetHTA member states.[4]

    The EuNetHTA JCA is a very vital tool for efficient and harmonized health technology assessments across the European Union. The PICOS framework allows a structured approach, providing the investigation with greater clarity, transparency, and robustness. Despite the existing issues with implementing PICOS in the context of EuNetHTA, results from strategic directions to come up with a more effective and consistent JCA framework could be promising. Ultimately, this synergy between EuNetHTA and the PICOS framework will contribute to better-informed healthcare decisions and improved health outcomes for patients across Europe.

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    References

    1. Desmet T, Brijs M, Vanderdonck F, Tops S, Simoens S, Huys I. Implementing the EU HTA regulation: Insights from semi-structured interviews on patient expectations, Belgian and European institutional perspectives, and industry outlooks. Frontiers in Pharmacology. 2024 Apr 10;15:1369508.
    2. Konstanski M, Gehrman J, Martinez JS, Schmidt K, Wissinger E, Altmann H. HTA229 PICO Criteria Applied in Joint Action 3 Differ From National HTA Requirements: A Review of Oncology Drug Assessments in Denmark, France, Germany, and Sweden. Value in Health. 2023 Dec 1;26(12):S363-4.
    3. Chamoux C, Outteridge G, Berto P. PT29 Predicting PICOs for EU Joint Clinical Assessment: Lessons from PICOs in Relative Effectiveness Assessments (REA) from EUnetHTA Joint Action 3 Project. Value in Health. 2023 Dec 1;26(12):S392.
    4. Schuster V. EU HTA Regulation and Joint Clinical Assessment—Threat or Opportunity?. Journal of Market Access & Health Policy. 2024 May 13;12(2):100-4.