OBJECTIVES : Confidential price agreements are becoming increasingly common for pharmaceuticals. As a result, when new treatments enter the market, the clinically relevant comparators may thus be drugs with confidential prices. This creates challenges when conducting health economic analyses. Reimbursement agencies have introduced procedures to handle these situations while maintaining the confidentiality of the comparators. The aim of this study was to explore and contrast the procedures used to handle situations with comparator pricing confidentiality in the Nordic markets excluding Iceland, especially with respect to transparency.

METHODS : Reimbursement agency guidelines were reviewed, and surveys were sent to the relevant agencies in the Denmark, Finland, Norway and Sweden. The agencies were asked to describe the procedures used in case of comparator pricing confidentiality. A targeted search of assessment reports provided recent examples to illustrate the procedure. Responses and examples were reviewed qualitatively.

RESULTS : In Denmark and Norway, the confidential price is in some cases applied in the health economic analysis by the reimbursement agency, and the outcome is masked to the applicant. In Sweden, a proxy comparator is often requested, and the cost effectiveness of the new drug relative to the clinically relevant comparator is assessed indirectly using the proxy comparator as an anchor. In Finland, the applicant is requested to provide multiple scenarios with hypothetical discounts for the comparator.

CONCLUSIONS : In the increasingly common situation with comparator pricing confidentiality, Nordic reimbursement agencies have adopted different approaches to handle the challenges in the health economic analyses. The most transparent approach is the one used in Sweden, with the request of a comparator that differs from the clinically relevant comparator. However, this is done at the expense of clinical relevance. The Danish and Norwegian processes are the least transparent, which may obstruct the predictability of the reimbursement decisions.