Articles

From JCA convergence to national divergence: Diagnosing evidence gaps across Europe  

22/10/2026

JCA creates a common EU-level clinical assessment, but it does not harmonise all the evidence and assessments required to secure national access. Differences in national treatment pathways, the relevance of populations and comparators, approaches to determining clinical added value, and requirements for economic evidence and budget impact can therefore create gaps between the JCA evidence package and national HTA requirements  

JCA standardises the clinical assessment, not the national value question

The JCA is a streamlined process that involves a single EU-level submission of evidence, providing a common comparative assessment of clinical effectiveness and safety. 2 

During JCA scoping, Member State requirements are consolidated into an assessment scope covering relevant populations, comparators and outcomes. The resulting PICOs may therefore expose evidence gaps early, before manufacturers address the requirements of individual national pricing and reimbursement processes.3  

However, harmonisation stops at the clinical assessment. The JCA does not determine added clinical value, pricing or reimbursement, which remain the responsibility of individual EU Member States.2 Manufacturers must therefore continue to navigate distinct national value frameworks and access processes after the JCA is completed. This distinction is important because the time to patient availability can vary substantially across European markets.4  

Where the evidence gaps emerge 

National EU authorities assess the common clinical output from the JCA in accordance with their own HTA and reimbursement frameworks; however, due to differing reimbursement requirements, evidence gaps may emerge.5 The table below summarises key areas where this may occur and potential mitigating actions that manufacturers should consider: 

JCA Potential national implication Potential action
Comparator 
 
 
Considers several comparators and accepts indirect-treatment comparisonLocal standard of care may not be adequately addressed by JCA analysis due to the relevance of the selected comparator in local clinical practice, or due to diverging methodological criteriaValidate clinical pathway assumptions, and explore ITC methodology requirements and feasibility if direct comparative data is not available 
PopulationNational assessment may focus on the population covered in the regulatory label or trial population or specific subgroups, with implications for price benchmarks further down the line Understand the impact of target population on comparator expectations, making a clear distinction between clinical versus economic comparators; then explore evidence requirements to demonstrate payer-relevant incremental value and a strategy to avoid price anchoring to low-cost standard of care  
OutcomesBeyond efficacy and safety assessment, additional outcomes to support the case for adoption into local care pathways may also be needed  Understanding how different national HTA assessments will value specific endpoints, e.g., HR-QoL, caregiver impact, patient preferences, route of administration, shifting patients from one care setting or level of care to another, etc. 
Also, manufacturers need to consider the implications of orphan drug designation for evidence needs and potential methodological implications in each country 
Economic / valueCost-effectiveness, budget impact and affordability invariably require local narrative and compelling evidenceUnderstand where the therapy can demonstrate payer-relevant cost-offsets or drive healthcare efficiency beyond clinical outcomes, to justify inclusion in budget-constrained systems 

Conclusion:  

Once the JCA is complete, manufacturers are still required to translate the JCA evidence package into individual national-level value strategies adapted to the context of each healthcare system. This process can be split into three distinct phases:

  1. Diagnosis: mapping the JCA evidence package against local requirements in priority markets
  2. Prioritisation: determining which gaps are most likely to affect appraisal success, price potential or access, and which evidence requirements are just “nice-to-haves”
  3. Mitigation: deciding on how to resolve critical evidence gap, including additional analyses, indirect comparisons, economic modelling, local evidence generation – all supported by robust payer validation 

In sum, the real challenge is ensuring that the evidence generated for JCA can be translated into compelling national value propositions across priority markets. Manufacturers should therefore assess national evidence requirements early, identify where the JCA package may fall short and prioritise the gaps most likely to affect appraisal outcomes, pricing potential or access.

A structured approach spanning diagnosis, prioritisation and mitigation can help teams focus evidence generation where it matters most, reduce avoidable surprises during national HTA and strengthen the pathway from EU-level assessment to patient access.  

Remap is well-positioned to help market access teams plan for JCA and national access as a single connected evidence strategy, rather than as sequential exercises.

Questions market access teams should ask now:

  1. Which evidence gaps are likely to have the most significant implications for P&MA at national level assessments in priority markets?
  2. What gaps can be mitigated without significant additional evidence generation e.g. subgroup analysis, different data cuts, ITCs, SLRs, NMAs?
  3. If significant new evidence generation is needed, what are the launch strategy trade-offs?

Wondering how to turn JCA evidence gaps into a clear national action plan: speak to Remap to explore our approach for diagnosing, prioritising and mitigating national evidence gaps.   

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