SHOULD COMPARATOR STRATEGY BECOME A DRUG-DEVELOPMENT DECISION, NOT AN HTA DECISION?
Author(s)
Kasem S. Akhras, PharmD, Emmanuel Lo, MSc., Sonja Nakasian, MSc..
VantEdge Access, LLC, Oak Brook, IL, USA.
VantEdge Access, LLC, Oak Brook, IL, USA.
OBJECTIVES: The European Union Joint Clinical Assessment (JCA), implemented in January 2025, requires a single assessment scope that incorporates comparator requirements across member states. This study evaluated comparator alignment between manufacturers and national HTA bodies, its association with HTA outcomes, and cross-country variability in preferred comparators.
METHODS: Using our proprietary AI-enabled analytics platform (OMNIA), we analyzed publicly available HTA assessments for innovative therapies in France (FR), Germany (DE), Italy (IT), and Spain (ES) (2020-2024). We assessed whether manufacturers' comparators matched HTA-preferred comparators, examined associations with HTA outcomes, and quantified the number of distinct preferred comparators across countries for each indication.
RESULTS: Of 2,326 reports (FR 1,042; DE 619; IT 222; ES 443), the manufacturer's comparator aligned with the body's preference in 64.9%, 95.5%, 68.0% and 56.9% in FR, DE, IT, ES respectively; Germany's near-universal alignment reflects G-BA's binding prospective comparator. Alignment predicted the outcome: the positive rate when aligned versus divergent was 49.0% vs 21.2% (FR), 57.8% vs 42.1% (DE), 68.2% vs 39.2% (IT), and 85.9% vs 67.1% (ES). Across 345 molecule-indications assessed in two or more countries, the pooled preferred-comparator set had a median of 6, rising to 9 in oncology.
CONCLUSIONS: Comparator heterogeneity remains a key challenge under EU JCA. These findings suggest that comparator strategy should be treated as a drug development decision, not solely an HTA consideration, to ensure evidence generation aligns with evolving European assessment and access requirements.
METHODS: Using our proprietary AI-enabled analytics platform (OMNIA), we analyzed publicly available HTA assessments for innovative therapies in France (FR), Germany (DE), Italy (IT), and Spain (ES) (2020-2024). We assessed whether manufacturers' comparators matched HTA-preferred comparators, examined associations with HTA outcomes, and quantified the number of distinct preferred comparators across countries for each indication.
RESULTS: Of 2,326 reports (FR 1,042; DE 619; IT 222; ES 443), the manufacturer's comparator aligned with the body's preference in 64.9%, 95.5%, 68.0% and 56.9% in FR, DE, IT, ES respectively; Germany's near-universal alignment reflects G-BA's binding prospective comparator. Alignment predicted the outcome: the positive rate when aligned versus divergent was 49.0% vs 21.2% (FR), 57.8% vs 42.1% (DE), 68.2% vs 39.2% (IT), and 85.9% vs 67.1% (ES). Across 345 molecule-indications assessed in two or more countries, the pooled preferred-comparator set had a median of 6, rising to 9 in oncology.
CONCLUSIONS: Comparator heterogeneity remains a key challenge under EU JCA. These findings suggest that comparator strategy should be treated as a drug development decision, not solely an HTA consideration, to ensure evidence generation aligns with evolving European assessment and access requirements.
Conference/Value in Health Info
2026-11, ISPOR Europe 2026, Vienna, Austria
Value in Health, Volume 29, Issue 12S
Code
HTA331
Topic
Economic Evaluation, Health Policy & Regulatory, Health Technology Assessment
Topic Subcategory
Decision & Deliberative Processes
Disease
Musculoskeletal Disorders (Arthritis, Bone Disorders, Osteoporosis, Other Musculoskeletal), Oncology, Rare & Orphan Diseases, Systemic Disorders/Conditions (Anesthesia, Auto-Immune Disorders (n.e.c.), Hematological Disorders (non-oncologic), Pain)