MANAGED ENTRY AGREEMENTS FOR CELL AND GENE THERAPIES IN GERMANY: CURRENT LANDSCAPE AND POSSIBLE MITIGATION STRATEGY FOR MOST-FAVORED-NATION PRICING
Author(s)
Alexandra Meyer, M.Sc., Danny Bot, PhD, Janine Leismann, M.Sc..
Ecker + Ecker GmbH, Hamburg, Germany.
Ecker + Ecker GmbH, Hamburg, Germany.
OBJECTIVES: This study investigates (1) which MEAs currently exist for CGTs in Germany, (2) the rationale underlying these agreements, and (3) observable trends in the context of MFN pricing.
METHODS: Relevant MEAs were identified through systematic searches of G-BA and GKV-SV databases and official price database (Lauertaxe), complemented by hand searches of PubMed, press releases, and arbitration board decisions
RESULTS: As of June 2026, 16 EMA-approved CGTs are available in Germany, of which five have identifiable MEAs: Hemgenix®, Imlygic®, Kymriah®, Yescarta® and Zolgensma® Three are additionally subject to coverage with evidence development schemes. Risk-sharing arrangements were identified for three CGTs (Kymriah®, Yescarta®, Zolgensma®), while two others (Hemgenix®, Imlygic®) operate under performance-based agreements tied to treatment duration or re-intervention rates.
CONCLUSIONS: 31% of approved ATMPs in Germany are subject to MEAs, all performance-linked and concentrated among high-cost therapies. In the context of MFN pricing, MEAs can only serve as an effective mitigation strategy if the statutory reimbursement price remains nominally unchanged and the agreement incorporates a claw-back mechanism, ensuring confidential rebates do not trigger reference pricing obligations in other markets. Faster availability of claims data from statutory health insurers could further enhance the feasibility of such arrangements. Germany's existing MEA infrastructure may offer a replicable template — provided these structural prerequisites are met.
METHODS: Relevant MEAs were identified through systematic searches of G-BA and GKV-SV databases and official price database (Lauertaxe), complemented by hand searches of PubMed, press releases, and arbitration board decisions
RESULTS: As of June 2026, 16 EMA-approved CGTs are available in Germany, of which five have identifiable MEAs: Hemgenix®, Imlygic®, Kymriah®, Yescarta® and Zolgensma® Three are additionally subject to coverage with evidence development schemes. Risk-sharing arrangements were identified for three CGTs (Kymriah®, Yescarta®, Zolgensma®), while two others (Hemgenix®, Imlygic®) operate under performance-based agreements tied to treatment duration or re-intervention rates.
CONCLUSIONS: 31% of approved ATMPs in Germany are subject to MEAs, all performance-linked and concentrated among high-cost therapies. In the context of MFN pricing, MEAs can only serve as an effective mitigation strategy if the statutory reimbursement price remains nominally unchanged and the agreement incorporates a claw-back mechanism, ensuring confidential rebates do not trigger reference pricing obligations in other markets. Faster availability of claims data from statutory health insurers could further enhance the feasibility of such arrangements. Germany's existing MEA infrastructure may offer a replicable template — provided these structural prerequisites are met.
Conference/Value in Health Info
2026-11, ISPOR Europe 2026, Vienna, Austria
Value in Health, Volume 29, Issue 12S
Code
HPR80
Topic
Health Policy & Regulatory, Health Technology Assessment
Topic Subcategory
Insurance Systems & National Health Care, Pricing Policy & Schemes, Reimbursement & Access Policy, Risk-sharing Approaches
Disease
No Additional Disease & Conditions/Specialized Treatment Areas