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How do you prepare for the Joint Clinical Assessment under the EU HTA Regulation when the assessment scope is fixed only shortly before the dossier deadline?

We prepare manufacturers for the Joint Clinical Assessment under Regulation (EU) 2021/2282: assessment scope (PICO), dossier and national follow-on procedures. The scope is fixed ten days after the CHMP list of questions, and the dossier is due 100 days after the request.

Overview

What does the EU HTA Regulation set out for the Joint Clinical Assessment?

Preparation for the joint clinical assessment · (EU) 2021/2282, Implementing Regulation (EU) 2024/1381, § 35a SGB V

Last updated: October 3, 2026

The Joint Clinical Assessment evaluates the clinical evidence once at EU level, in parallel with the centralized authorization. Added benefit, price and reimbursement remain decisions for each member state.

  • The cut-off dates are in Art. 7(2) of Regulation (EU) 2021/2282: since January 12, 2025 for new active substances for cancer and for advanced therapy medicinal products, from January 13, 2028 for orphan medicinal products, and from January 13, 2030 for all other medicinal products in the centralized procedure.
  • The assessment scope sets the patient population, intervention, comparators and health outcomes (Art. 8(6)). Under Art. 10(2) of Implementing Regulation (EU) 2024/1381, it is finalized no later than ten days after the CHMP adopts its list of questions.
  • The dossier is due 100 days after the Commission's first request, or 60 days in accelerated procedures (Art. 12(2) of the Implementing Regulation), and the deadline falls at least 45 days before the planned CHMP opinion (Art. 10(1) of the Regulation).
  • The report describes relative effects and their certainty and contains no value judgment on added benefit (Art. 9(1)). Member states give it due consideration and do not request again at national level any data already submitted at EU level (Art. 13(1)).
  • Class IIb and III medical devices and class D in vitro diagnostics only fall under the procedure if the Commission selects them, at least every two years, using criteria such as unmet medical need or being the first device in a new category (Art. 7(4)). The procedural rules for assessing selected devices are set out in Implementing Regulation (EU) 2025/2086; the selection itself is made by a separate implementing act.

Services

How we support you

Applicability and Timeline

Checking whether and from when a product falls under Art. 7 of Regulation (EU) 2021/2282, and working the JCA timeline back from the planned marketing authorization application: validation, CHMP list of questions, assessment scope, dossier deadline.

Joint Scientific Consultation

Preparing an application for a joint scientific consultation under Art. 16 and 17 while studies are still being planned, in parallel with EMA scientific advice if requested.

What it comes down to

The Joint Clinical Assessment runs in parallel with the centralized authorization, and that is what makes it tight. Under Implementing Regulation (EU) 2024/1381, the assessment scope is fixed no later than ten days after the CHMP list of questions. The dossier is due 100 days after the first request and, under Art. 10(1) of Regulation (EU) 2021/2282, must arrive at least 45 days before the planned CHMP opinion.

Whatever is not already set up by then is hard to add, above all analyses for several comparators and subpopulations.

The report itself describes relative effects and their certainty. It contains no judgment on added benefit; that stays with the member states, in Germany with the early benefit assessment under § 35a SGB V. Our article on JCA and AMNOG covers how the two procedures connect.

Preparation therefore starts before the authorization application: which PICO questions are likely, what evidence supports them, and is a Joint Scientific Consultation worthwhile while the studies can still be planned? The procedure also applies to selected high-risk devices, where it adds to the reimbursement routes for MedTech and IVD.

Our approach

Our approach

01

Clarify applicability

Established whether the product is covered by Art. 7 of Regulation (EU) 2021/2282, and from which cut-off date.

02

Hold evidence against likely PICOs

A gap overview for each likely population and comparator, set up before the authorization application while analyses can still be planned.

03

Take on the assessment scope

The assessment scope evaluated after the first request, with an explanatory meeting on request, held no later than 20 days after the scope is finalized.

04

Submit the dossier on time

The dossier on the Annex I template within 100 days, or 60 days in the accelerated procedure.

05

Draft report and national procedures

Notes on purely technical or factual inaccuracies in the draft, then the national dossier based on the published report.

Common pitfalls

Where projects commonly fail

The JCA is read as a replacement for the national benefit assessment.

Under Art. 9(1) of Regulation (EU) 2021/2282, the report contains no value judgment on added benefit; each member state still draws its own conclusion, in Germany under § 35a SGB V.

Analyses are planned only after the scope is set.

The scope is fixed ten days after the CHMP list of questions and the dossier is due 100 days after the request; analyses for several comparators can hardly be set up from scratch in that window.

The dossier is submitted incomplete in the expectation of adding to it later.

If a second request is not met, the Coordination Group discontinues the assessment (Art. 10(6)), and the statement is published on the IT platform.

Substantive objections to the draft report are prepared.

Under Art. 11(5), the developer only flags purely technical or factual inaccuracies and submits no comments on the results.

A Joint Scientific Consultation is requested too late.

Under Art. 16(2) only technologies whose studies are still in the planning phase are eligible. If admissible applications exceed the planned number, the Coordination Group selects at the end of the request period (Art. 17(3)).

Market Access, RWE & Reimbursement

Do any of these pitfalls apply to you?

In a first call we assess your situation and say what needs clarifying first in your case. Without obligation, reply usually within one working day.

FAQ

Frequently asked questions

Under Art. 7(2) of Regulation (EU) 2021/2282: since January 12, 2025, medicinal products with new active substances for the treatment of cancer and advanced therapy medicinal products; from January 13, 2028, orphan medicinal products; and from January 13, 2030, all other centrally authorized medicinal products. New indications of products that have already been assessed are also covered under Art. 7(1)(b).

Sources
  • Regulation (EU) 2021/2282 on health technology assessment, Art. 7 to 13 and 16 to 21: primary text via the EU Cellar (CELEX 32021R2282)
  • Implementing Regulation (EU) 2024/1381, Art. 10 to 13: primary text via the EU Cellar (CELEX 32024R1381)
  • Commission Implementing Regulation (EU) 2025/2086 of 17 October 2025 (joint clinical assessment of medical devices and IVDs): primary text via the EU Cellar (CELEX 32025R2086)
  • German Social Code Book V (SGB V), § 35a: primary text, gesetze-im-internet.de

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Regulations & standards considered

  • Regulation (EU) 2021/2282 (EU HTA Regulation), Art. 7 to 13 and 16 to 21
  • Implementing Regulation (EU) 2024/1381 (procedure for joint clinical assessments of medicinal products)
  • Implementing Regulation (EU) 2025/2086 (procedural rules of the joint clinical assessment for medical devices and IVDs)
  • Regulation (EC) No 726/2004 (centralized authorization procedure)
  • § 35a SGB V (early benefit assessment)

Have a concrete project?

Briefly outline your situation. We'll respond with an initial assessment, usually within one business day.

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info@theentourage.ch

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