A Review of Cost Comparisons Submitted to NICE Since the Introduction of the Proportional Approach to Technology Appraisal
Author(s)
Alasdair D. Henry, PhD1, Clare Willis, PhD1, Thomas Scassellati Sforzolini, MS2, Priti Jhingran, PhD2.
1Genesis Research Group, London, United Kingdom, 2Genesis Research Group, Hoboken, NJ, USA.
1Genesis Research Group, London, United Kingdom, 2Genesis Research Group, Hoboken, NJ, USA.
OBJECTIVES: The National Institute for Health and Care Excellence (NICE) introduced a proportionate approach to technology appraisal (TA) in February 2022, recognising that not all technologies need the same depth of evaluation. One method in the proportionate approach utilises cost comparisons rather than cost-utility analyses (CUA), suitable for technologies with similar or greater benefits at similar or lower costs than technologies already recommended for the same indication. The aim of this study was to investigate trends in the use of cost comparisons and requirements for successful reimbursement.
METHODS: A search of NICE TA guidance was conducted and TAs published between February 2022 and June 2025 were identified where the manufacturer submitted a cost comparison.
RESULTS: A total of 250 new TAs were identified, of which 42 (17%) included a cost comparison. This approach was considered acceptable for decision making and technologies were recommended in 86% (n=36/42) of TAs, with a narrower population than the marketing authorisation in 23/36 approvals. In instances where cost comparisons were not accepted, 5/6 were recommended after a CUA. An additional 5 submissions were developed with a CUA but later accepted with a cost comparison and 2 cost-minimisation analyses were not accepted. Head-to-head data against a comparator was included in 33% (n=14/42) of submissions, while an indirect treatment comparison was required in 86% (n=36/42) to support evidence of clinical equivalence. The most common disease areas were inflammatory diseases (n=10/42), solid tumours (n=9/42), and ophthalmological diseases (n=6/42). A simple costing approach was used in 48% (n=19/40; 2 unclear) of cost comparisons; the remainder modelled disease progression to estimate costs.
CONCLUSIONS: Cost comparisons have become a common route for successful reimbursement with over 1 in 6 new TAs utilising this approach. This demonstrates that manufacturers are using this opportunity for faster access, allowing NICE to divert resources to more complex decision problems.
METHODS: A search of NICE TA guidance was conducted and TAs published between February 2022 and June 2025 were identified where the manufacturer submitted a cost comparison.
RESULTS: A total of 250 new TAs were identified, of which 42 (17%) included a cost comparison. This approach was considered acceptable for decision making and technologies were recommended in 86% (n=36/42) of TAs, with a narrower population than the marketing authorisation in 23/36 approvals. In instances where cost comparisons were not accepted, 5/6 were recommended after a CUA. An additional 5 submissions were developed with a CUA but later accepted with a cost comparison and 2 cost-minimisation analyses were not accepted. Head-to-head data against a comparator was included in 33% (n=14/42) of submissions, while an indirect treatment comparison was required in 86% (n=36/42) to support evidence of clinical equivalence. The most common disease areas were inflammatory diseases (n=10/42), solid tumours (n=9/42), and ophthalmological diseases (n=6/42). A simple costing approach was used in 48% (n=19/40; 2 unclear) of cost comparisons; the remainder modelled disease progression to estimate costs.
CONCLUSIONS: Cost comparisons have become a common route for successful reimbursement with over 1 in 6 new TAs utilising this approach. This demonstrates that manufacturers are using this opportunity for faster access, allowing NICE to divert resources to more complex decision problems.
Conference/Value in Health Info
2025-11, ISPOR Europe 2025, Glasgow, Scotland
Value in Health, Volume 28, Issue S2
Code
HTA13
Topic
Health Technology Assessment
Topic Subcategory
Decision & Deliberative Processes, Systems & Structure
Disease
No Additional Disease & Conditions/Specialized Treatment Areas