EU MDR & HTA Cardiovascular Reimbursement Strategy · Eclevar MedTech
EU MDR · HTA · Cardiovascular Reimbursement Strategy

CE Mark evidence
that becomes your
reimbursement dossier.

Notified Bodies approve devices. HTA bodies decide whether they get paid for. Eclevar designs one protocol with co-primary endpoints that satisfies both — so you enter your first HTA submission with the evidence already built.

4
HTA agencies covered
14mo
CE Mark to HAS decision
€8M+
Annual revenue unlocked
🇫🇷
HAS / CNEDIMTS
France · Liste en sus
🇩🇪
G-BA / IQWiG
Germany · MALE composite
🇬🇧
NICE MTEP
UK · £20–30k / QALY
🇪🇺
EUnetHTA JCA — Mandatory from Jan 2025
Class III & IIb implantables · One common clinical dossier
London · Paris · Dublin · Tokyo
ISO 13485 Certified QMS
EUCROF Platinum Award 2026
clientcare@eclevar.com
The Reimbursement Gap

Most design for CE Mark.
Not for reimbursement.

Notified Bodies assess safety versus state of the art. HTA bodies assess comparative effectiveness versus standard of care — with health economic models, QALY quantification and national cost data. These are two entirely different evidentiary standards — and most PMCF programmes are built for only one.

🏥

What Notified Bodies assess

Safety and performance versus state of the art. 12-month patency. Freedom from device-related adverse events. Annex XIV evidence hierarchy. Clinical evaluation methodology.

💶

What HTA bodies require

Comparative effectiveness versus standard of care. QALY quantification. ICER thresholds per agency. 5-year budget impact model. National cost data and PRO instruments validated by country.

The Eclevar approach

One protocol. Co-primary endpoints. We design the clinical programme so your CE Mark evidence is simultaneously your HTA dossier — built once, reimbursed everywhere.

Reimbursement success rate within 24 months of CE Mark
🇫🇷 France — HAS / CNEDIMTS (Liste en sus)71%
🇬🇧 UK — NICE MTEP64%
🇩🇪 Germany — G-BA Methodenbewertung48%
🇮🇹 Italy — AGENAS (National)38%
Five HTA Agencies That Matter

Know what each agency actually needs.

Each HTA body has its own preferred endpoints, modelling standards and grading frameworks. A single submission strategy that ignores these differences costs you months and revenue.

🇫🇷

HAS / CNEDIMTS

France

Two-step process: ASA I–V grading then CEPS pricing negotiation. TLR preferred over patency. Markov model with French utility value set mandatory for Class III.

🇩🇪

G-BA / IQWiG

Germany

Europe's largest market. Demands MALE composite endpoints. CEC adjudication is mandatory. Monte Carlo PSA with 1,000 iterations minimum. Strong preference for RCT data.

🇬🇧

NICE MTEP

United Kingdom

Strict ICER threshold (£20–30k / QALY). Pragmatic: accepts observational data with strong bias control. EQ-5D-5L required for QALY. Budget impact for NHS commissioners.

Endpoint Architecture

The right endpoint satisfies your NB
and your HTA body simultaneously.

The endpoint that gets you through a Notified Body review is often not the same one that gets you reimbursed. We design the co-primary endpoint hierarchy before protocol lock — so both are served by a single clinical programme.

❤️

TAVI & Structural Heart

  • 1

    All-cause mortality (VARC-3)

    Globally standardised. Accepted by all HTA bodies and Notified Bodies as the primary safety endpoint.

    HASIQWiGNICE
  • 2

    Freedom from TLR

    Patient-centred outcome. Kaplan-Meier analysis at 12 and 24 months. Explicitly preferred by HAS over technical patency.

    HAS primaryBIA-relevant
  • 3

    PRO: EQ-5D-5L

    Non-negotiable for QALY calculation. Recalculated for French, German and UK national value sets from the same dataset.

    QALY FR/DE/UKJCA compliant
🩺

Peripheral PTA & AVF

  • 1

    Primary Patency + CD-TLR

    Both technical (duplex) and patient-outcome (clinically-driven TLR) endpoints required to satisfy NB and HAS simultaneously.

    Annex XIVHAS
  • 2

    BTK: Limb Salvage (AFS)

    Amputation-free survival. The MALE composite equivalent for IQWiG in below-the-knee indications. Critical for German reimbursement pathway.

    IQWiG MALEBTK specific
  • 3

    PRO: VascuQoL-6

    Validated disease-specific instrument for peripheral arterial disease. Essential for functional outcomes and health utility calculation in PAD programmes.

    VascuQoL validatedFunctional outcomes
Health Economics

Without a QALY, you cannot
negotiate pricing.

The ICER per QALY is the universal output that governs pricing negotiations with every HTA body in Europe. Eclevar builds the complete Markov model alongside your clinical programme — from the first protocol lock, not after the data is collected.

Model deliverables

📊

5-Year Budget Impact Analysis (BIA) — national cost data, admission rates, country-specific unit costs

🎲

Monte Carlo Simulations — minimum 1,000 iterations (HAS requirement), PSA with tornado diagrams

📈

Probabilistic Sensitivity Analysis (PSA) — cost-effectiveness plane, CEAC, threshold analysis per country

🗺️

Country value sets — EQ-5D utility recalculated for FR, DE, UK and EU JCA dossier in parallel

Markov Model State Engine
STATE 1  ·  Post-Procedural Recovery
↓ Transition probability from PMCF dataset
STATE 2  ·  Well / Functional  QALY GAIN
↓ P(TLR), P(Major event), P(Death)
STATE 3  ·  Event / TLR / Death

Transition probabilities derived directly from PMCF dataset. Model built in parallel with data collection — not retrospectively.

ICER = (Cost Device − Cost Comparator) ÷ (QALY Device − QALY Comparator)
Case Study

TAVI programme: reimbursement in 14 months.

A manufacturer had CE Mark but 18 months of failed HAS submissions. Their PMCF used primary patency but lacked the TLR data required for reimbursement. Illustrative programme structure — not specific client data.

France · HAS CNEDIMTS · Cardiovascular · Class III

Redesigning for France (HAS CNEDIMTS)

A Class III TAVI manufacturer had CE Mark but 18 months of failed HAS submissions. Their PMCF programme was built around primary patency — technically sound for the Notified Body, but inadequate for HAS which requires TLR data and a Markov model with the French utility value set.

Eclevar solution: Protocol redesigned mid-programme. TLR co-primary added with retrospective DCB comparator arm. Markov model built in parallel with French and German value sets. BIA constructed against the DRG reference tariff. ASA II grading achieved and CEPS pricing negotiation completed within 14 months of CE Mark.

14 mo CE Mark to HAS decision
ASA II HAS grading achieved
€8M+ Annual revenue unlocked
Client success review

Less Patients, More Data.
The RegenLab Experience.

AT
Mr. Antoine Turzi
CEO, RegenLab
Questions

HTA strategy, answered.

When should HTA strategy be integrated into the clinical programme?

At protocol design, before the first patient is enrolled. The endpoint hierarchy, PRO instruments, comparator arm and follow-up schedule all need to satisfy both the Notified Body and the HTA body. Retrofitting HTA evidence after data collection is expensive, slow and rarely fully effective — which is why 18-month delays are common when manufacturers treat reimbursement as a post-CE-Mark activity.

What is the EUnetHTA JCA and does it apply to my device?

The Joint Clinical Assessment (JCA) is mandatory from January 2025 for Class III and Class IIb implantable medical devices. It produces a single common clinical assessment at EU level — meaning one dossier reviewed by a multi-national committee. Early engagement is strongly recommended, as the JCA scope and evidence requirements are defined at the consultation stage, before protocol lock.

What is an ICER and how is it calculated for a cardiovascular device?

The Incremental Cost-Effectiveness Ratio (ICER) = (Cost of device strategy − Cost of comparator) ÷ (QALYs with device − QALYs with comparator). Each HTA body applies a threshold: NICE uses £20–30k/QALY, France uses a case-by-case assessment, Germany does not apply a fixed threshold but uses the ICER to inform price negotiations. The QALY is calculated from EQ-5D utility scores collected in the clinical study and weighted by national value sets.

Can Eclevar redesign an existing PMCF programme for HTA?

Yes — and this is one of our most common engagements. We start with a gap analysis: what the existing data covers, what is missing, and what can be obtained retrospectively versus prospectively. In many cases a TLR co-primary, PRO instrument and Markov model can be added without restarting the programme — as in the TAVI case study above. The earlier in the programme this is done, the less costly the remediation.

Your CE Mark evidence
should be your reimbursement dossier.

We review your current PMCF programme against HAS, G-BA and NICE requirements to identify exactly what needs to change to make your evidence reimbursement-ready — free, 30 minutes, no obligation.

Reforming Clinical Evaluation of Medical Devices in Europe