AUTHORS: Joyce Atim, Rahul Vadehra
Rare diseases have a significant impact on people worldwide and have a high level of unmet needs. During the past 5 years, there has been a huge effort to develop new treatments for rare disease, with orphan drug medicines representing 45% of all approvals in Europe and 53% new active substance approvals in the US.1 Despite these initiatives, rare diseases present unique challenges to health technology assessment (HTA), impacting the reimbursement process for medications treating such conditions. Limited patient populations, limited data, the heterogeneous nature of rare diseases and the lack defined access routes across countries make it challenging to assess treatment value the traditional HTA methods.2 In this context, patient engagement is critical and can affect reimbursement by providing tailored messaging that addresses the unmet needs and burdens of rare diseases to improve access.
What are the key challenges impacting HTA in rare diseases?
Clinical value and evidence considerations
HTA for rare diseases is challenged by the clinical development process, where demonstrating efficacy and safety through traditional trials is difficult.3 Due to small patient populations, trials for rare disease often rely on single-arm designs and surrogate endpoints, increasing uncertainty for payers.4 This lack of comparative data makes it harder to prove meaningful clinical improvement, affecting reimbursement decisions and willingness to pay premium prices.
Economic value considerations
Challenges in clinical development impact the feasibility of economic modelling for rare diseases. The absence of comparator data, reliance on single-arm trial designs, heterogeneity within trial populations, and limited clinical outcomes contribute to uncertainty when evaluating mortality, efficacy, and treatment impacts in rare diseases.5,6 This often leads to reimbursement barriers. Patient engagement can help by providing insights into disease burden and societal impact, though not all HTA bodies consider these broader factors in decision-making.
Access challenges
Access to orphan drugs remains challenging, as few countries have specific pathways for rare diseases.7 England’s Highly Specialised Technologies (HST) program, the Netherlands’ orphan drug access protocol pilot, and Sweden’s staircase model for ultra-rare diseases offer more tailored solutions.8,9 Other countries, including Italy, France, Germany, and Spain, have adapted processes but still require strict economic evaluations, often disregarding surrogate measures. This highlights the need for stronger patient engagement to advocate for improved access.
Why is patient engagement important in HTA for Rare Diseases?
Patient engagement is essential in HTA for rare diseases, as traditional cost-effectiveness models often fail to capture the full impact of these conditions. Rare diseases by definition, have small patient populations, leading to limited clinical trial data. Therefore, patient insights are critical in demonstrating the true burden of disease, emphasising the urgency of treatment, and highlighting the impact beyond conventional clinical endpoints. Without patient input, HTA bodies may overlook key factors that determine whether a treatment is deemed valuable.10
A structured approach to patient engagement ensures that HTA frameworks assess treatments holistically. Standard cost-effectiveness models often disadvantage rare disease therapies due to high development costs. However, patient insights can be used to highlight broader benefits, such as improved quality of life, reduced caregiver burden and long-term societal gains. These factors are hard to measure with gold standard methods, but patient perspectives offer a more balanced assessment of a treatment’s value.11
Timely patient engagement is also crucial in accelerating access to innovative therapies. Many rare diseases are progressively debilitating, meaning that delays in treatment can lead to irreversible decline or even death. Countries that integrate patient perspectives early in the process are more likely to implement flexible access pathways, ensuring life changing treatments reach those who need them.11
Beyond access, patient engagement enhances equity in decision-making. If HTA bodies solely focus on cost-effectiveness, treatments for larger populations often take priority, while rare diseases therapies are deprioritised due to budget constraints. By embedding patient perspectives in the HTA process, healthcare systems can ensure that rare disease treatments receive fair considerations, preventing a situation where small patient populations are systematically disadvantaged.11
Without patient engagement in HTA for rare diseases, treatments may be undervalued, delayed, or not approved, adversely affecting patients’ quality of life and survival. The perspectives of patients are crucial in rare diseases to ensure access to essential, life-changing treatments.
What role is patient engagement playing in EU4 + UK HTA?
Most of the countries that were reviewed recognise the importance of patient engagement in HTA for rare disease treatments. However, approaches vary, as some countries have developed structured programmes, while others offer regional voting rights with no national framework in place (Table 1):
- Scotland (Scottish Medicines Consortium [SMC]): Patients can present experiences at committee meetings, and patient and clinician engagement (PACE) gives stronger decision-making influence for ultra-orphan/orphan drugs when standard criteria are unmet.
- England (National Institute for Health and Care Excellence [NICE]): Patient and Public Involvement Programme (PPIP) ensures continuous patient involvement in HTA, and HST allows greater flexibility for rare disease treatments with incremental cost-effectiveness ratio (ICERs) ≤£100,000 per quality-adjusted life year (QALY).
- France (Haute Autorité de Santé [HAS]): Patient representatives participate in all discussions and votes, but input is broadly sought for all medicines, with no rare disease-specific flexibility.
- Italy (Agenzia Italiana del Farmaco [AIFA]): Recent reforms introduced structured patient engagement via a national HTA stakeholder network, AIFA Ascolta help desk, and new legal mandates requiring patient input, particularly for rare diseases.
- Germany (Gemeinsamer Bundesausschuss [G-BA]/Institut für Qualität und Wirtschaftlichkeit im Gesundheitswesen [IQWiG]): Patients contribute via direct and indirect channels, with significantly higher involvement in advanced therapy medicinal product (ATMP) evaluations for rare diseases due to greater reliance on stakeholder input.
- Spain (Agencia Española de Medicamentos y Productos Sanitarios [AEMPS]/Regional HTAs): No national patient involvement, but Catalonia integrates patient representatives at all medicine appraisal stages, including voting rights
Country | Level of Patient Engagement | Specific to Rare Disease |
---|---|---|
Scotland (SMC) | Patients and representatives can attend NICE/SMC committee meetings to present their experiences PACE gives patient groups and clinicians a stronger voice in SMC decision making12 | PACE is triggered for ultra-orphan and orphan medicines when a drug is initially not recommended based on standard and economic criteria12 |
England (NICE) | Patients and representatives can attend NICE/SMC committee meetings to present their experiences | PPIP ensures patients are involved throughout assessment process13 HST provides more flexibility for rare diseases ICERs (≤£100,000 per QALY) partly due to strong patient advocacy14 |
France (HAS) | Representatives of patient organisations participate in all discussions and votes, providing advisory opinions on which HAS will base its decisions15 | Limited – patient input is sought for all medicines |
Italy (AIFA) | AGENAS has recently established a national HTA stakeholder network to include patient representatives in upcoming HTA activities16 The budget law (Legge di Bilancio 2025) requires that patient representatives be included in the decision-making processes of both MoH and AIFA16 AIFA Ascolta, a new help desk for patient associations, aims to enhance their role in pharmaceutical care17 AIFA leadership has committed to a “paradigm shift,” ensuring patients are active participants in therapeutic decisions, aligning Italy with best European practices18 | Previously nothing existed but going forward, when AIFA is evaluating a new therapy (especially for rare diseases), there should be a structured mechanism in place to consult the relevant patient association / representative and include their perspective in the HTA assessment |
Germany (G-BA/IQWiG) | Patients and relatives affected by the disease are included via: Indirect contact: Spokesperson of G-BA’s coordination committee for patient involvement can contact self-help groups and patient organisations19 Direct contact: IQWiG engages directly with patients to discuss the benefits and harms of medical examinations or treatments. These discussions help gather firsthand experiences and expectations.19 | Patient involvement in the assessment of ATMPs in rare diseases is significantly higher than for standard drugs, with patient representatives playing a key role in the process due to the lack of a clear “additional benefit” therefore requiring more reliance on stakeholder input during the evaluation phase20 |
Spain (AEMPS/Regional HTAs) | National level – no structured patient involvement Catalan Health Service not only allows patients to participate, but they also have voting rights. There is a high level of patient involvement as representatives are integrated at each step of the medicine appraisal21 | Limited – PHF conducted 96 appraisals for a total of 168 medicines and in all appraisals, patients were involved in the decision-making process21 |
Abbreviations: AIFA: Agenzia Italiana del Farmaco; AGENAS: Agenzia Nazionale per i Servizi Sanitari Regionali; ATMP: Advanced Therapy Medicinal Product; G-BA: Gemeinsamer Bundesausschuss; HAS: Haute Autorité de Santé; HST: Highly Specialised Technology; HTA: health Technology Assessment; ICER: Incremental Cost-Effectiveness Ratio; IQWiG: Institut für Qualität und Wirtschaftlichkeit im Gesundheitswesen; MoH: Ministry of Health; NICE: National Institute for Health and Care Excellence; PACE: Patient and Clinician Engagement; PHF: Programa d’Harmonització Farmacoterapèutica; PPIP: Patient and Public Involvement Programme; QALY: Quality-Adjusted Life Year; SMC: Scottish Medicines Consortium
Conclusion and Impact
Patient engagement is essential in addressing the challenges of HTA for rare diseases, where traditional cost-effectiveness models often fail to capture the full impact of treatments. Limited trial data, small patient populations, and high development costs make it difficult for rare disease treatments to meet conventional clinical and economic requirements, often leading to delays or rejection in reimbursement decisions. By integrating patient insights, HTA bodies can gain a more comprehensive understanding of disease burden, the urgency of treatment, and broader societal benefits such as improved quality of life and reduced caregiver strain. Countries that embed structured patient engagement early in the process can create more flexible access pathways, accelerating approvals and ensuring that life-changing treatments reach those who need them.
Without a strong patient voice in HTA, rare disease therapies risk being deprioritised, exacerbating health inequalities and leaving patients without viable treatment options. Moving forward, collaboration between HTA bodies, manufacturers, and policymakers is crucial to embedding patient perspectives in decision-making, ensuring a more equitable and inclusive approach to rare disease treatment access.
Citations and Reference List
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- Stafinski T, Glennie J, Young A, et al. HTA decision-making for drugs for rare diseases: comparison of processes across countries. Orphanet J Rare Dis. 2022;17(258). doi:10.1186/s13023-022-02397-4.
- Hollak C, Groothoff J. Fast but controlled access for orphan drugs. Amsterdam UMC News. Published November 7, 2022. Accessed February 28, 2025. https://www.amsterdamumc.org/en/research/institutes/amsterdam-gastroenterology-endocrinology-metabolism/news/fast-but-controlled-access-for-orphan-drugs.htm
- Dental and Pharmaceutical Benefits Agency (TLV). Strengthened Access to Medicines for Rare Diseases—At Long-Term Sustainable Costs. Published September 2023. Accessed February 28, 2025. https://www.tlv.se/download/18.56bb14ac18b37f17d083e082/1739352212105/strenghened_access_to_medicines_for_rare_disesases_2023-10-19.pdf
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- Scottish Medicines Consortium. Patient and Clinician Engagement (PACE) process. Accessed February 28, 2025. https://scottishmedicines.org.uk/how-we-decide/pace/
- National Institute for Health and Care Excellence (NICE). Patient and public involvement policy. Accessed February 28, 2025. https://www.nice.org.uk/about/nice-communities/nice-and-the-public/public-involvement/patient-and-public-involvement-policy
- National Institute for Health and Care Excellence (NICE). Interim Process and Methods of the Highly Specialised Technologies Programme. Published May 2017. Accessed February 28, 2025. https://www.nice.org.uk/media/default/about/what-we-do/nice-guidance/nice-highly-specialised-technologies-guidance/hst-interim-methods-process-guide-may-17.pdf
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