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HTA Submission Writing

HTA Submission Dossier

Pubrica prepares HTA submission dossiers for manufacturers preparing national reimbursement submissions, written to the requirements of each agency. Each agency sets its own requirements: NICE submissions follow a reference case, CDA-AMC conducts reimbursement reviews, the G-BA assesses dossiers against a comparator it sets, HAS transparency dossiers turn on SMR and ASMR, and PBAC applies its own guidelines. These submissions share a trial but differ in almost every other respect. Pubrica’s HTA submission writers prepare each dossier for the agency that will assess it, together with clarification responses and checks against the economic model.

  • Written for each agency: the reference case, comparator rule and accepted methods differ in every market
  • Current agency names and methods: CADTH has been Canada’s Drug Agency (CDA-AMC) since 1 May 2024, and our dossiers reflect the change
  • The appropriate comparator applied correctly, because in Germany a dossier assessed against the wrong comparator is judged to show no additional benefit
  • Model and dossier written together, so the numbers in the text are the numbers in the model
  • Clarification questions anticipated, because clarification rounds are where submission timelines are most often lost
HTA Dossier Support Included and excluded

Dossier built to the named agencyIncluded

Reference case and methods appliedIncluded

Clarification responses draftedIncluded

Consistency with the model checkedIncluded

A guaranteed recommendationNot something any provider can offer

Agency → reference case → evidence → dossier → clarification

Included in every HTA dossier
  • Built to the named agency
  • Current agency names and methods
  • Comparator rule applied correctly
  • Numbers consistent with the model
  • Clarification questions anticipated
Quoted per submissionOn agency, indication and evidence
Five agenciesNICE, CDA-AMC, G-BA, HAS, PBAC
NICE reference case3.5%, NHS and PSS, GBP 20,000–30,000 per QALY
ISO 9001:2015Quality management certified · cert. H3CR9TCU20251212INDQM10N

Deliverables

Four Components of Every HTA Submission Dossier

Each agency requires a different argument for the same product, so we prepare each dossier for the agency that will read it.

The reference case applied in full NICE sets a 3.5% annual discount on costs and health effects, an NHS and personal social services cost perspective, and results at GBP 20,000 and GBP 30,000 per QALY, with the severity modifier where it applies.

From the reference caseA model built to a different discount rate or a societal perspective does not meet the NICE reference case and must be rebuilt, which duplicates work.

The comparator set by the agency In Germany, the G-BA sets the appropriate comparator therapy and IQWiG assesses additional benefit against it. A dossier argued against a different comparator does not address the assessment question.

From the German fileThe comparator is settled in advance through consultation. Companies that engage in that process are better prepared than those that learn of the choice when they receive the assessment.

Current agency names and methods CADTH became Canada’s Drug Agency (CDA-AMC) on 1 May 2024. Documents that still refer to CADTH indicate to a reviewer that they have not been recently updated.

From the reviewThis detail affects how a submission is read. The same applies to a NICE submission that cites end-of-life criteria, which the severity modifier has replaced.

Clarification responses included Every agency raises clarification questions. We draft the answers against the model and the evidence, rather than leaving them to be assembled under deadline pressure.

From the processClarification rounds are where submission timelines are most often lost, and where any inconsistency between the dossier text and the model is raised in committee discussion.

The samples shown are illustrative and anonymised. Hover over a sample to replay it.

Compliance and Standards

HTA Submission Standards and Methods Guidance

Each agency publishes its own methods guide. The standards below apply across agencies.

PMG36

NICE evaluations manual (the reference case)

A 3.5% annual discount on costs and health effects, an NHS and personal social services cost perspective, results at GBP 20,000 and GBP 30,000 per QALY, and the severity modifier that replaced the end-of-life criteria.

CHEERS 2022 (reporting economic evaluations)

The consolidated health economic evaluation reporting standard. Twenty-eight items covering model structure, inputs, assumptions, uncertainty and conflicts — and the checklist reviewers and HTA bodies increasingly ask to see completed.

ISPOR–SMDM good practices (modelling)

The seven-report series on model conceptualisation, state-transition and discrete event structures, parameter estimation, and the validation and transparency expectations that decide whether an HTA committee trusts a model it did not build.

ISO9001:2015

Quality management (cert. H3CR9TCU20251212INDQM10N)

Our certified quality system governs how work is run, recorded and released.

Responsible Use of AI

Our Approach to AI Use in HTA Submission Dossiers

HTA reviewers examine every part of a submission, so each structural assumption, input and source must be attributable. NICE has published a position on AI use in submissions, and traceability, rather than speed, governs how we use AI tools.

How We Use AI ToolsWe use AI tools to help find and extract published inputs, check a model or dossier for internal consistency, and draft code that a health economist then reviews and runs.
Where We Do Not Use AIWe do not use AI tools for structural assumptions, utility, cost or comparator choices, the clinical argument, or any text entering a submission as drafted. An assessor expects a named analyst behind the model and a named author behind the dossier.
Your AI Use DeclarationYour declaration states the tool, the stage at which it was used and the human oversight applied. Journals, funders, regulators and the ICMJE January 2026 update now expect this, and an undeclared tool found later is treated as an integrity matter.

Why We Do Not Publish AI Accuracy Figures

Accuracy figures for AI tools are usually reported by the companies that sell them.

Pubrica therefore does not quote its own accuracy figures, as they would carry the same conflict of interest. Instead, we tell you which tool was used on your project, at which stage, and what a specialist changed afterwards.

Our Process

How Our HTA Dossier Development Process Works

We confirm the target agency first, because it determines the perspective, comparator, discount rate and outcome measures used throughout.

Step one

Agency and Reference Case

We confirm the target agency and establish its reference case, comparator rule and accepted methods before any analysis is run.

Step two

Evidence and Model Alignment

We check the systematic review, indirect comparisons and economic model against the methods this agency accepts, and rebuild any element developed for a different agency.

Step three

Dossier Drafting

We write the dossier to the agency template and terminology, with every figure traced to the model that produced it.

Step four

Submission and Clarification

After submission, we answer clarification questions using the same evidence base.

Our Experts

Your HTA Submission Dossier Team

A named team of subject specialists stays with your project from scoping to delivery. Your project coordinator introduces each team member by name before work begins.

Subject expertA subject matter expert matched to your topic

Determines what the work can claim on the basis of the evidence. The subject expert is matched to your topic and tells you clearly when the evidence does not support the intended conclusion.

Responsible forScope, judgement, interpretation
Reviews againstICMJE, COPE, the reporting guideline
FieldMatched to your topic
Mr. JohnM.Sc. in Statistics · statistician

Responsible for every decision that depends on the numbers. Confirms before analysis begins whether the data can answer the question, and hands over the code so the analysis can be re-run independently.

Responsible forAnalysis and certainty
Reviews againstGRADE, SWiM, ICH E9
ToolsR, Stata, SAS, RevMan
Dr. AntonyInformation specialist

Identifies the evidence on which the work is based and documents the search so that it can be reproduced. Writes the search strategy line by line for each platform and delivers it dated and reproducible.

Responsible forSearch and retrieval
Reviews againstPRISMA-S, PRESS
Second-checked byA second information specialist
Dr. DivyaPhD in Life Science · second reviewer

Reviews the work independently of the first pass and reconciles the two, because most errors in this work are transcription errors rather than errors of reasoning. All disagreements are logged and adjudicated.

Responsible forIndependent second review
Reviews againstThe applicable checklist
Adjudicated byA third reviewer

Packages

HTA Dossier Packages

Pricing depends on the agency, the indication and whether the evidence already exists in a form the agency accepts.

Single

One agency

For a single national submission

Quoted per projectOn agency and indication

Delivery By agency timetable

  • ✓Reference case and comparator rule applied
  • ✓Evidence checked against agency methods
  • ✓Dossier written to the template
  • ✓Numbers traced to the model
  • ✓Clarification responses drafted

Please tell us the target agency first, as it determines the perspective, the discount rate and sometimes the outcome measure.

Deliverables Request a quote
Sequence

Multi-market sequence

For launches across several HTA markets

Quoted per projectOn markets and sequencing

Delivery By market

  • ✓Shared evidence core built once
  • ✓Each dossier built to its own agency
  • ✓Sequencing advised against reference pricing
  • ✓Consistency maintained across markets
  • ✓Clarification handled per agency

The order of submission matters, because an early low price in a reference market affects pricing in later markets.

Deliverables Request a quote
Resubmission

Resubmission and appeal

For products with a negative or restricted recommendation

Quoted per projectOn the finding to be addressed

Delivery By scope

  • ✓Detailed review of the committee finding
  • ✓Answerable and unanswerable issues identified
  • ✓Evidence or analysis rebuilt where it can be
  • ✓Resubmission or appeal drafted
  • ✓Clear advice where a finding cannot be addressed

Some committee findings can be addressed with further analysis and some cannot. We tell you which is which before any resubmission work begins.

Deliverables Request a quote

Send us the agency and the indication, and we will check your evidence base against that agency’s reference case at no cost and tell you what would need to be rebuilt.

FAQs

HTA Submission Dossier FAQs

If your question is not answered here, please ask an expert. No quote is required.

A single evidence core can serve several agencies, but a single dossier cannot. The reference case, comparator rule and accepted methods differ enough that a document written for one agency does not meet the requirements of another.

The most economical approach is a global value dossier as the single evidence source, with each national submission built from it rather than adapted from another submission.

No. It removes the duplicated clinical assessment. Pricing and reimbursement remain national, and every Member State still runs its own process and asks its own questions.

Your national economic argument now builds on a clinical assessment you did not write alone, and it must remain consistent with it.

The dossier is assessed against the appropriate comparator therapy the G-BA set, not the one you argued against. Evidence against a different comparator generally cannot demonstrate additional benefit.

The comparator is settled in advance through consultation, and that is the stage at which to engage with it.

Ideally before the pivotal trial fixes its comparator and outcome measures, if these are still open. HTA requirements differ from regulatory requirements, and the gap between them cannot be closed afterwards.

Where the trial has already been completed, the earliest useful point is before the economic model is built, so that it follows the correct reference case from the start.

Request a Free Reference Case Check of Your HTA Evidence

You will receive a clear list of what transfers, what must be rebuilt, and what cannot be changed at this stage.

Get a free quote

Regulations

Check your project against this rule

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Material you send is held under signed confidentiality, with access limited to the assigned team and encrypted transfer. It is not used to train anything and is not passed to third-party tools. Ask for the agreement before you send anything you would rather cover first.