DOES YOUR REGULATORY PATHWAY UNDERMINE YOUR JCA? SCENARIO PLANNING FOR EVIDENCE GENERATION

Author(s)

Florentin Köhnemann, PhD1, Lisette Nientker, MSc2, Grace E. Fox, PhD3.
1OPEN Health, Berlin, Germany, 2OPEN Health, Rotterdam, Netherlands, 3OPEN Health, New York, NY, USA.
OBJECTIVES: The European Union (EU) Joint Clinical Assessment (JCA), the centralized clinical component of Health Technology Assessment (HTA) in Europe, is closely linked to regulatory marketing authorization, such that the chosen regulatory pathway shapes JCA processes and timelines. Uncertainty surrounding accelerated and conditional approvals and "special therapy situations" (e.g., pediatric or tumor-agnostic treatments) complicates population, intervention, comparator, and outcome (PICO) scoping and evidence generation, yet practical guidance remains limited. This analysis mapped relevant regulatory scenarios to the JCA process to identify implications for JCA dossier preparation and local market access.
METHODS: We reviewed key regulatory pathways, namely accelerated approval, conditional approval, approval under exceptional circumstances, and Type II variations, together with recognized "special therapy situations," and mapped each to the JCA process, assessing the downstream consequences for local market access teams. Findings reflect current procedural guidance and early JCA and downstream local HTA experience.
RESULTS: Given timing is difficult to revisit once the JCA process started, accelerated applications carry the greatest risk. Pediatric line extensions, such as those following a Pediatric Investigation Plan, typically rest on a weak evidence base. Tumor-agnostic therapies fit poorly with PICO-based frameworks, leaving population definitions ambiguous. Conditional approvals and approvals under exceptional circumstances carry post-authorization evidence obligations and periodic reassessment that may trigger a JCA update. These frequently lack several evidence components, with patient‑reported outcomes (PROs) and utility data being part of the gap.
CONCLUSIONS: Regulatory scenarios have substantial, under-recognized, implications for JCA. Due to different objectives, full alignment of regulatory and HTA strategies is unlikely. Accordingly, accelerated pathways should be pursued only when progression is certain, evidence transfer should be considered for pediatric extensions, populations need to be defined clearly for tumor-agnostic products, and supportive real-world evidence can be incorporated if clinical evidence components such as PROs and utility data are absent.

Conference/Value in Health Info

2026-11, ISPOR Europe 2026, Vienna, Austria

Value in Health, Volume 29, Issue 12S

Code

HTA136

Topic

Clinical Outcomes, Health Policy & Regulatory, Health Technology Assessment

Topic Subcategory

Systems & Structure

Disease

No Additional Disease & Conditions/Specialized Treatment Areas

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