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Health Policy Analysis

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Journal homepage: www.elsevier.com/locate/jval

A Conceptual Framework for Life-Cycle Health Technology Assessment


Erin Kirwin, MA, Jeff Round, PhD, Ken Bond, MA, Christopher McCabe, PhD

A B S T R A C T

Objectives: Health technology assessment (HTA) uses evidence appraisal and synthesis with economic evaluation to inform
adoption decisions. Standard HTA processes sometimes struggle to (1) support decisions that involve significant uncertainty
and (2) encourage continued generation of and adaptation to new evidence. We propose the life-cycle (LC)-HTA framework,
addressing these challenges by providing additional tools to decision makers and improving outcomes for all stakeholders.
Methods: Under the LC-HTA framework, HTA processes align to LC management. LC-HTA introduces changes in HTA methods
to minimize analytic time while optimizing decision certainty. Where decision uncertainty exists, we recommend risk-based
pricing and research-oriented managed access (ROMA). Contractual procurement agreements define the terms of
reassessment and provide additional decision options to HTA agencies. LC-HTA extends value-of-information methods to
inform ROMA agreements, leveraging routine, administrative data, and registries to reduce uncertainty.
Results: LC-HTA enables the adoption of high-value high-risk innovations while improving health system sustainability
through risk-sharing and reducing uncertainty. Responsiveness to evolving evidence is improved through contractually
embedded decision rules to simplify reassessment. ROMA allows conditional adoption to obtain additional information,
with confidence that the net value of that adoption decision is positive.
Conclusions: The LC-HTA framework improves outcomes for patients, sponsors, and payers. Patients benefit through earlier
access to new technologies. Payers increase the value of the technologies they invest in and gain mechanisms to review
investments. Sponsors benefit through greater certainty in outcomes related to their investment, swifter access to
markets, and greater opportunities to demonstrate value.

Keywords: economic evaluation, health technology assessment, life-cycle, research oriented market access, value of
information.

VALUE HEALTH. 2022; 25(7):1116–1123

Introduction Evidence assessment usually involves the review of an evi-


dence dossier submitted by the technology sponsor, which in-
Public programs face increasing budgetary pressures and cludes published and unpublished information from clinical trials
require strong evidence for health technology funding decisions. and economic evaluations. The sponsor is often the company that
These decisions are supported by health technology assessment has developed and owns the technology, but patient and clinician
(HTA) agencies, making recommendations based on reviews of groups may also make submissions. The HTA agency may then
clinical evidence and results from cost-effectiveness analysis. HTA commission or conduct a systematic review of the clinical evi-
agency recommendations have implications for patients’ access to dence and a cost-effectiveness analysis, with or without inclusion
treatments, sponsors’ return on investment, public formularies, of materials beyond the sponsor evidence dossier.
and payers’ budgets. In the appraisal phase, the results of the evidence assessment
are reviewed and discussed by a panel or body tasked with
Standard HTA Processes making recommendations for payer adoption decisions. Issues
such as equity, acceptability, and input from key stakeholders are
HTA processes typically begin after or concurrently with reg- sometimes considered. The recommendations typically take the
ulatory approval and vary by jurisdiction in terms of governance, form of (1) recommend, (2) recommend with conditions/re-
remit (advisory vs decision), links to reimbursement, and au- strictions, or (3) do not recommend.3 Conditional recommenda-
thority to monitor and adjust postdecision. Despite interjurisdic- tions may specify price reductions to achieve an acceptable value
tional differences, all HTA processes include 2 phases: evidence or budget impact target and clinical conditions that restrict access
assessment and appraisal.1,2 to specific patient subgroups.

1098-3015/Copyright ª 2022, International Society for Pharmacoeconomics and Outcomes Research, Inc. Published by Elsevier Inc. This is an open access article
under the CC BY license (http://creativecommons.org/licenses/by/4.0/).
HEALTH POLICY ANALYSIS 1117

Challenges With Standard HTA Processes outcomes for all stakeholders. Our framework is built around on-
market evidence generation and risk-based pricing strate-
Standard HTA and methods leave several well-documented
gies.25,34,47 There is no current HTA agency guidance that includes
challenges and limitations unaddressed, which include the
value-of-information (VoI) methods to inform adoption de-
following4-10:
cisions.37,48,49 Existing frameworks with similar aims do not take a
LC perspective50 or are retrospective in nature and do not include
Health system sustainability: Deadoption and divestment decision rules.51,52 Many of the individual components
threshold values of the LC-HTA framework are well established and understood, but
The ever-increasing nature of health technology development the sequential implementation of these methods and the
places significant pressures on health system payer budgets. embedded decision rules are novel.
When decision rules require that technologies demonstrate value A key component of LC-HTA is research-oriented managed
at a cost-effectiveness threshold (CET), the implication is that in access (ROMA). ROMA provides contractual agreements for tech-
the absence of deadoption elsewhere budgets will continually nologies that meet regulatory approval requirements but for
expand.11-15 Typical HTA reviews do not include recommendations which there is substantial uncertainty regarding effectiveness
on deadoption, meaning that technologies that should be dead- and/or cost-effectiveness. These agreements are research oriented
opted to ensure sustainability may continue to be reimbursed or, in that the contract defines the exact research protocol that will be
worse, more valuable products are deadopted to pay for the new implemented, the duration of the research, and the specific data
technology, harming total population health. Inappropriate sources that will be used, leveraging sources of administrative, or
threshold values could cause new technologies to displace more routinely collected data to generate real-world evidence (RWE).
health than they create.16-21 Evidence generated through ROMA will be used to reassess the
technology and inform adoption decisions, while allowing
Evolving evidence managed market access to sponsors and access to promising
Evidence for new and existing technologies is continually technologies to patients.
emerging. Initial decisions may be invalidated by changes in the LC-HTA requires reframing of price targets, given that prices
evidence base for the technology (eg, new trials) or by changes in can be used to compensate for decision uncertainty. In standard
the clinical pathway (eg, new complementary or substitute tech- HTA, a theoretical maximum acceptable price for payers is iden-
nologies), which can affect a technology’s value. There are few tified when the incremental cost-effectiveness ratio is equal to the
standard processes to reevaluate technologies over the on-market CET, which can also be expressed as the incremental net monetary
life-cycle (LC) or to support value-based price renegotiation in benefit (NMB) being equal to zero. We refer to this price as the
response to these changes.10,22-33 Where conditional funding value-based price.
recommendations are made, there is the need to reevaluate An alternative to the abovementioned model is risk-based
technologies for which additional evidence was required at the pricing, which relies on a modified VoI output, the independent
recommendation stage, such as managed access agreements.7,34-36 expected value of perfect information (iEVPI).47 The iEVPI is
calculated in the same way as standard expected value of perfect
Uncertainty information (EVPI),53,54 but compares only the NMB distribution
Evidentiary uncertainty arises from several factors, including of a technology at a given price and an alternative with a constant
the characteristics of the technology, the care pathway and patient value of the expected NMB of the current treatment at value-
group, and future events (patent expiry, uptake, and competitor based pricing. “Payer risk tolerance” is the maximum per-patient
entry). In health economic modeling, uncertainty is often classi- risk of making wrong decisions that payers are willing to accept
fied as methodological, structural, and parameter.37 The cumula- in monetary terms. The risk-based price is the price at which, for
tive effect of all these sources of uncertainty is to create a any given value threshold, the iEVPI is equal to payer risk toler-
significant risk of incorrect decisions: the adoption of technologies ance. Finally, the critical price is defined as the lesser of the value-
that will not deliver the promised value and the rejection of based price and the risk-based price.
technologies that would.13,38-45 As a direct consequence, payers We present the framework LC-HTA in the chronological
accept a substantial risk, which in turn affects the health of the sequence of a technology’s LC (Fig. 1). After initial HTA, the process
populations served. This risk is particularly high when regulatory becomes a cycle where technologies transition between the
approval is given to technologies that do not meet conventional reassessment, adoption, and no adoption stages.
evidentiary standards for effectiveness (such as the 2021 Food and
Drug Administration approval of aducanumab).46 Nevertheless, The Preassessment Stage
there are few mechanisms within standard HTA to mitigate these
risks. Preassessment meetings and early scientific advice programs
offer opportunities for sponsors to ask questions of regulators and/
Aim or HTA body to better align evidence with requirements. Some
HTA agencies collaborate internationally to provide early feed-
We aim to address these challenges through our framework for back.55,56 Such programs improve the efficiency of LC-HTA and
LC-HTA, designed to improve outcomes for patients, payers, and should be developed and retained.
sponsors. We describe a sequence of processes and decision rules
that are suitable for implementation within diverse contexts, The Safety and Efficacy Assessment Stage
rather than aligning the framework to specific jurisdictional
procedures. In most countries, a regulatory body is responsible for de-
cisions regarding market authorization, with a focus on safety,
efficacy, and manufacturing quality.57,58 The regulatory approval
The LC-HTA Framework stage typically involves the review of an evidence dossier sub-
mitted by the technology sponsor. This normally occurs before
The LC-HTA framework builds upon standard HTA concepts HTA review, although there are examples of overlapping pro-
and methods and proposes adaptations that will lead to better cesses.59 Under LC-HTA, these conventions are retained.
1118 VALUE IN HEALTH JULY 2022

Figure 1. The LC-HTA framework. Dark shaded square boxes represent LC-HTA stages as introduced in the section The LC-HTA
Framework; lighter shaded rounded boxes represent outcomes. White rounded boxes represent statuses within stages and outcomes.

LC-HTA indicates Life-cycle health technology assessment; HTA, health technology assessment; ROMA, research-oriented managed access.

Additionally, regulatory and HTA agencies should share informa- The evidence review should include an analysis of existing care
tion and communicate expected timelines and outcomes of pro- pathways, to better understand the context in which the technology
cesses, to improve the efficiency of review processes. After could be implemented and to evaluate the generalizability of the
regulatory review, agencies make recommendations that fall into existing evidence base to the decision context. The evidence review
one of 3 general categories: should involve consultation with patient and clinician groups to
document and validate important disease outcomes and clinical
1. Grant market access as per requested clinical indications factors that may not be well represented within the existing evi-
2. Grant market access with conditions/ restrictions dence base.61 Finally, potential sources for RWE related to the
3. Deny market access technology and care pathway should be identified to assess the
feasibility of on-market evidence development through ROMA.

The HTA Stage De novo model development and VoI analysis

Technologies receiving full or conditional regulatory approval In standard HTA, a health economic model is submitted as a
proceed to the HTA stage. component of the sponsor evidence dossier, and this model is
reviewed by the HTA agency. In LC-HTA, a de novo model is
Formulating the decision problem developed instead of or in addition to the sponsor model. This de
On receipt of acceptable submissions, the HTA agency must novo model is used to inform the initial assessment and appraisal,
define the decision problem: the indications and populations for which data should be collected under ROMA, the design of the on-
which the technology could be recommended and comparator market evidence generation, and the reappraisal.
technologies that must be included in the review. Ill-defined de- The development of de novo models is recommended to
cision problems will lead to inconsistencies in the HTA process resolve structural uncertainty (uncertainty because of the rele-
and could inhibit future reassessments. vance of care pathways in varying decision contexts) and to ensure
HTA agencies must provide guidance on appropriate CET capability for advanced analytic steps later in the process. Often
values. Limited estimates of the supply-side threshold can lead to sponsor models are developed for global markets and may not
the use of inappropriate values, reducing population health ben- capture the local clinical pathway, with distorting impacts on
efits. Similarly, varying threshold values by target population can technology diffusion, and the design and value of on-market
reduce population and equity-weighted population health.16 research. De novo models can better align to the care pathway
Another concern is the overall budget impact for technologies identified in the evidence review.
that are cost-effective at the margins. One solution is to restrict The characterization of parameter uncertainty will be
prices below the point of nonmarginal budget impacts; alternative improved by identifying all potential sources in the evidence re-
approaches could consider varying threshold values as budget view. Methods to improve the quality of initial parameter inputs,
impact increases.21 such as meta-analysis, Bayesian updating, expert elicitation, and
bias adjustment exercises, should be implemented as appro-
Evidence review and synthesis priate.62-70 Models should be developed to facilitate direct
The HTA agency should complete a systematic evidence review parameter updating to reflect on-market evidence generation and
and synthesis, supplementing the submitted evidence dossier.60 from other studies.
HEALTH POLICY ANALYSIS 1119

The application of VoI methods is central to LC-HTA, by sup- Health system activities. Includes significant off-label
porting the development of efficient study designs. VoI methods usage or overutilization, unanticipated budget impacts, or
can be computationally intensive, particularly advanced outputs requests from the technology sponsor to revisit reimbursement
that are required by the later stages of LC-HTA. Appropriate se- and changes to the care pathways, including alternative
lection of model structure and software platforms can greatly treatment options, which are likely to affect the technology’s
improve efficiency.71,72 value.
Once the LC-HTA model has been developed, the following
outputs are required, using the HTA agency endorsed value
New evidence. Includes new RCTs, real-world evaluations
threshold:
and other sources of information which could affect the results
of the HTA analysis.
1. Expected NMB, with a probabilistic sensitivity analysis to
quantify uncertainty in NMB values45
HTA method changes. Includes changes to HTA and/or
2. EVPI53,54
economic evaluation guidelines observed by the HTA
3. Value- and risk-based prices
agency.37,48,49 Relevant changes could include recommended CETs,
4. The expected value of perfect parameter information (EVPPI)
discount rates, or similar.
for key model parameters
If reassessment criteria are met, the new evidence should be
reviewed and synthesized. This can then be used to update the
These outputs will provide a detailed understanding of the
health economic model to support reassessment of the technol-
sources of decision uncertainty, along with pricing inputs required
ogy. The reimbursement status of the product can then be revised,
for the design of potential ROMA protocols.73-77
with the same decision options as the initial assessment.
HTA outcomes under LC-HTA
Four recommendations are available to HTA agencies based on
Research-oriented market access adoption
the outputs of the LC-HTA analyses: Protocol development. For technologies that receive a
ROMA recommendation, candidate ROMA protocols should be
1. Adoption without conditions: the sponsor submitted price is developed based on the results of the EVPPI analysis. Under each
less than or equal to the critical price. protocol, different elements of RWE are collected and used to
2. When evidence indicates that adoption of the technology update inputs in the health economic model, with the aim of
should only be made for specific indications or patient groups reducing uncertainty. In principle, ROMA may incorporate only-in-
and/or when the sponsor submitted price is greater than the research or only-with-research designs. It is expected that only-
critical price and the value-based price is less than the risk- with-research designs will be the norm, because of a lack of
based price, HTA agencies should recommend adoption with justification for clinical equipoise and/or patient refusal to be
conditions/restrictions. randomized once a license has been granted.35,41,78-80
3. When the sponsor submitted price is greater than the critical Models are developed to simulate the evidence generation
price and the risk-based price is less than the value-based process, characterized by sampling designs that could be imple-
price, HTA agencies should recommend ROMA. Under ROMA, mented through a technology diffusion model (TDM). The TDM
research will be undertaken to reduce uncertainty. simulates the diffusion of the technology over time, which may
4. When the evidence indicates that the technology will not have vary by sampling design.39,81,82 The RWE generation model is used
a positive NMB at any price that is acceptable to the sponsor, to simulate the additional evidence that would be generated as
HTA agencies should not recommend adoption. the adoption and use of the technology increase. For each sam-
pling design, the outputs of the TDM and RWE generation model
This decision typology builds upon the work of Claxton et al35 are used together to update parameter information in the health
adding the role of critical and risk-based pricing. Varying levels of economic model.
uncertainty in subsets of the full licensed indication may justify a The expected net benefit of sampling (ENBS) is estimated as
mixture of recommendations by clinical indication. the difference between the expected value of sample information
(the difference in EVPI with and without the additional informa-
tion from sampling) and the expected total cost of sampling,
The Adoption Stage
which accounts for the cost of evidence generation and the op-
Technology adoption takes 2 forms: regular or through ROMA. portunity costs incurred, such as forgone health gains for patients
For any technology, these are not necessarily mutually exclusive outside of research. The maximum ENBS is estimated for each
and may differ by clinical indication. sampling design by selecting the protocol duration that maxi-
mizes the value between the expected value of sample informa-
Regular adoption tion and the expected total cost of sampling. Therefore, for each
Following HTA agency recommendations, payers make positive sampling design, the optimal duration is identified and the ENBS
adoption decisions outside of ROMA when the final negotiated is calculated to compare among protocols.72,78
price is lower than the critical price, and any conditions/re-
strictions are agreed upon. These adoption decisions are made Protocol implementation. If at least one candidate ROMA
through a contractual agreement describing the inputs, process, protocol has a positive ENBS, it should be considered for imple-
and the conditions that would trigger reassessment including mentation. The protocol with the highest ENBS is the most valu-
decision rules. The reassessment conditions in the procurement able evidence development strategy.
contracts should consider26: ROMA protocols are implemented after contractual negotiation
with the sponsor. The contracted price must be less than the
Regulatory changes. Includes entry of competitors, patent value-based price. If the contracted price diverges from the risk-
expiry, entry of generic forms of the technology on the market, or based price, the ENBS for the candidate protocols should be
changes in regulatory status (ie, regulatory conditions). recalculated to ensure the highest value protocol is implemented.
1120 VALUE IN HEALTH JULY 2022

The terms of the contract will specify read-out periods for the Evolving Evidence
evidence development and will define stopping conditions for
Through the decision rules embedded in LC-HTA, the frame-
ending the ROMA protocol term. At each read-out period, addi-
work is responsive to evolving evidence that can affect the deci-
tional data and model outputs will be analyzed to determine if the
sion criteria for the adoption and/or deadoption of health
stopping conditions have been met. Once one of the stopping
technologies.
conditions has been met, a final evaluation can be produced.
LC-HTA also contributes to the development of evidence
The contract is intended to remain in place for the duration of
through ROMA. Although it generates evidence for a specific
the ROMA period. The duration of the ROMA period is determined
jurisdiction, it adds to the global evidence base and hence im-
by updating the ENBS analysis after each read-out period and
proves decisions in other jurisdictions.83
continuing if it is . 0.
The outputs from the ROMA protocol will be evaluated and
synthesized with previous evidence. The parameters in the health Uncertainty
economic model will be updated using the synthesized evidence By expanding the scope of evidence that is included in the
base, and revised net benefit, VoI, and ENBS estimates will be evidence review and synthesis, including RWE and technology
produced. The reimbursement status of the product can then be diffusion, the value of technologies is better characterized,
revised, with the same decision options as the initial assessment. reducing payer decision uncertainty.
The development of a de novo model further reduces uncer-
The De-adoption Stage tainty by ensuring alignment to jurisdiction specific care path-
Adoption is not recommended under 2 circumstances: when ways. In addition, by designing models to enable efficient
the evidence does not support an expectation of a positive net updating of evolving evidence and VoI outputs, LC-HTA allows
benefit at any price or when the price required for a positive ex- decision makers to respond promptly and predictably to new
pected net benefit is not acceptable to the sponsor. evidence, including the launch of similar technologies, all of which
reduces uncertainty for patients, sponsors, and payers.
The Reassessment Stage Using VoI outputs within decision making and the ROMA
process reduces uncertainty efficiently. EVPPI identifies the pa-
For technologies under regular approval, reassessment is
rameters that contribute the most to decision uncertainty. The
initiated should any of the 4 contracted conditions (section Reg-
ROMA component of LC-HTA ensures that RWE prioritizes these
ular adoption) arise.
parameters. The use of ENBS to select the best value ROMA pro-
When evidence generated through ROMA adoption reports,
tocol optimizes the value of investments in RWE generation.
reassessment is initiated, and the new evidence is synthesized and
An important innovation under LC-HTA is the direct linkage of
used to update the original HTA analyses and recommendations
uncertainty to risk. When there is a high degree of uncertainty in
(section HTA outcomes under LC-HTA).
the evidence base, there is an increased risk to decision makers of
For technologies outside of ROMA (regular adoption and de-
making incorrect decisions. This is particularly important when
adoption), submissions for reevaluation can be made by any
regulatory agencies approve technologies below conventional
sponsor (manufacturers, clinician, or patient groups). Resubmis-
evidentiary standards. The LC-HTA framework includes decision
sion to HTA agencies must indicate the basis for reevaluation, such
rules that are responsive to risks associated with uncertain
as new evidence or revisions to the submitted price.
effectiveness evidence at regulatory approval and, through ROMA,
provides mechanisms to share this risk between payers and
Discussion sponsors, while reducing delays in access to technologies for pa-
tients compared with standard HTA.41,79
The LC-HTA framework introduced in this article has been
designed to address challenges and limitations of standard HTA Considerations for Implementation of LC-HTA
when assessing and appraising high-value high-risk technolo-
Contractual agreements for implementing ROMA could repre-
gies—sustainability, evolving evidence, and uncertainty.
sent a significant change in the relationship among patients,
payers, and providers. In particular, there are likely legal chal-
Sustainability: Deadoption and Threshold Values
lenges related to withdrawing access to treatments that are
LC-HTA seeks to improve health system sustainability in deadopted after reassessment. The solutions to such problems will
several ways. The estimation of the risk- and value-based prices be jurisdiction specific. Related to this is the need to determine
ensures fair prices for health system payers. Risk-based prices will how technologies approved before the implementation of the LC-
be lower than value-based prices when there is substantial deci- HTA framework should be evaluated, for example, if reassessment
sion uncertainty, compensating for additional risk. Payers are criteria should be applied retroactively or only for products eval-
protected against incorrect decisions, whereas sponsors gain uated after adoption of an LC-HTA based approach.
market access more rapidly and the opportunity to demonstrate The LC-HTA framework includes many opportunities for effi-
their technology’s value, which could inform adoption decisions in ciency gains, including information sharing among sponsors,
other markets and/or support price increases. By convention, HTA regulators, and HTA agencies and the development of de novo
agencies treat regulatory approval as evidence of safety and effi- models that can be recycled and repurposed throughout the LC of
cacy. Within LC-HTA, deadoption decisions based on safety and a health technology or adapted for additional technologies with
effectiveness alone are possible, realized either through a failure similar care pathways and/or outcomes. Nevertheless, the LC-HTA
to demonstrate effectiveness or through the (non)acceptability of framework requires additional evidence review and synthesis, and
the critical price to sponsors. resource requirements (particularly trained analysts) are some-
LC-HTA adoption rules protect health system sustainability by what larger than those required for conventional HTA. The deci-
ensuring adoption is conditional upon technologies not displacing sion rules and contractual clauses could lead to a larger volume of
more value than they produce. This is further supported through reevaluations being required, exacerbating resource challenges.
the use of appropriate threshold values. Although these resources may seem to have high costs compared
HEALTH POLICY ANALYSIS 1121

with standard HTA, the methods embedded in LC-HTA allow the Correspondence: Erin Kirwin, MA, Institute of Health Economics, #1200,
quantification of the return on the investment in LC-HTA given 10405 Jasper Ave, Edmonton, AB T5J 3N4, Canada. Email: ekirwin@ihe.ca
that they can be incorporated as part of the costs of research when Author Contributions: Concept and design: Kirwin, Round, Bond, McCabe
identifying the ENBS. Although the up-front costs related to LC- Drafting of the manuscript: Kirwin, Round, Bond, McCabe
HTA de novo model development are substantial, they are small Critical revision of the paper for important intellectual content: Kirwin, Round,
relative to the expected cost of the investment decision. Such Bond, McCabe
Supervision: Round, McCabe
models are expected to pay substantial dividends over the long-
term, and reassessments will likely require lower resources than Conflict of Interest Disclosures: All authors reported receiving grants
initial assessments. from the Government of Alberta during the conduct of the study. Dr
Implementation of the LC-HTA framework requires efficient McCabe reported receiving nonfinancial support from Health Canada, the
Government of British Columbia, the Government of Ontario, and the
collaboration among HTA agencies, patients, and payers, in
Canadian Agency for Drugs and Technologies in Health and reported
particular to facilitate timely model development. Early sponsor receiving grants from Merck Canada Inc, Novartis Pharmaceuticals Canada
and patient engagement through parallel regulatory and HTA re- Inc, AstraZeneca Canada Inc, Takeda Canada Inc, Boehringer Ingelheim
view can mitigate timeline concerns. (Canada) Ltd, GlaxoSmithKline Inc, and Hoffman-La Roche Ltd outside of
There are opportunities for collaboration among HTA agencies the submitted work. No other disclosures were reported.
internationally. Often, technology sponsors submit applications Funding/Support: Authors Kirwin, Round, Bond, and McCabe received
for review to multiple agencies, closely linked in time and content. financial contributions from the Government of Alberta, grants #005527,
Improved communication and collaboration between agencies #005841, #008491, and #013211.
should enable components of evidence review, synthesis, and
Role of the Funder/Sponsor: The funder had no role in the design and
possibly health economic models to be shared, easing the burden conduct of the study; collection, management, analysis, and interpretation
on individual HTA agencies. Open science partnerships could of the data; preparation, review, or approval of the manuscript; and de-
further enhance the efficiency of evidence production.84 cision to submit the manuscript for publication.
Any new process will undoubtedly have unintended impacts.
Deadoption decisions will be politically sensitive and HTA
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