A Comparative Analysis of Early Access Pathways in Italy and France: Law 64896 vs. the French AAP

Author(s)

Alessandro d'Audino, MSc1, Vishal Yadav, M.Pharm.2, Lucy Forrester, M.Sc2, Federico Tartarelli, MSc1, Lucrezia Della Loggia, M.Sc.2, Natalia Ra, MSc2, Dario Lidonnici, BEc, BSc, MSc3, Christel Jansen, MSc2, Valeria Viola, M.Sc1, Herve Lilliu, BSc, MSc2, Andrea Marcellusi, PhD4.
1Pharma Value s.r.l., Rome, Italy, 2Inbeeo, London, United Kingdom, 3More Than Access Srl SB, Milan, Italy, 4University of Milan, Milano, Italy.
OBJECTIVES: Italy’s Law 648-96 enables early access (EA) to medicines not yet authorised nationally but that are either approved abroad, under investigation in clinical trials, or used off-label based on supporting phase II clinical data. France’s Early Access Authorisation (AAP) programme similarly allows temporary access to products with or without a marketing authorisation (MA) for patients lacking therapeutic alternatives, until a reimbursement decision is made. This study compares the two frameworks to assess their effectiveness in delivering EA and implications for routine pricing and reimbursement.
METHODS: We analysed EA requests submitted between January 2023 and December 2024 in Italy (n=126) and between January 2023 and June 2024 in France (n=56), using AIFA and HAS databases, respectively. For each request, we assessed product types, access timing (pre- or post-MA), timelines, success rates, and the relationship between EA outcomes and routine reimbursement.
RESULTS: Out of 126 applications in Italy, 30 were on-label and 96 off-label, the latter not being comparable with the approach of AAP. Among on-label requests, 73% were for new active substances and 27% were for indication expansions in both countries. Orphan drugs represented 50% of requests in Italy and 41% in France. The majority of requests were submitted pre-MA (57% in Italy; 59% in France). Average application processing time was longer in Italy than France (163 vs 111 days). EA-rejection rate was higher in Italy than France (67% vs 54%). Products with EA-approved decision reached routine reimbursement more quickly in France compared to Italy (312 vs 498 days). Reimbursement followed for 60% versus 25% of EA-approved, and 67% versus 42% of EA-rejected requests, respectively in Italy and France.
CONCLUSIONS: Italy’s 648-96 framework shows higher rejection rates and longer timelines but more transitions to routine access compared to France’s AAP, highlighting key differences between the two EA programmes.

Conference/Value in Health Info

2025-11, ISPOR Europe 2025, Glasgow, Scotland

Value in Health, Volume 28, Issue S2

Code

HPR3

Topic

Health Policy & Regulatory

Topic Subcategory

Reimbursement & Access Policy

Disease

No Additional Disease & Conditions/Specialized Treatment Areas

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