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How do you submit an HTA dossier that carries the added benefit through G-BA, IQWiG, NICE or HAS?

We prepare complete HTA dossiers for AMNOG (G-BA and IQWiG), the NICE Single Technology Appraisal, HAS and SGB V §137h, and guide you through the written commenting phase up to the oral hearing. Added benefit is not decided during the writing phase but in the choice of the appropriate comparator: if the comparator is only settled at submission, the entire chain of evidence has been built against the wrong comparator regimen and can no longer be salvaged.

  • Pharma
  • Biotech
  • MedTech
  • IVD

Overview

What do HTA bodies require of a dossier?

Submissions for AMNOG (G-BA / IQWiG), NICE STA, HAS and SGB V §137h, senior-led and methodologically aligned with the IQWiG methods paper and AM-NutzenV

Last updated: 2026-06-13

An HTA dossier must demonstrate a product's added benefit against a prescribed comparator therapy in methodologically sound terms, not just efficacy versus placebo. The four points at which dossiers regularly fail:

  • The appropriate comparator therapy (zVT) in the AMNOG procedure under SGB V §35a is determined by the G-BA, not chosen by the manufacturer. If the pivotal trial provides no head-to-head comparison against this zVT, the basis for added benefit is missing, regardless of data quality.
  • Patient-relevant endpoints are what count. Under its methods paper, IQWiG primarily assesses mortality, morbidity and health-related quality of life; surrogate endpoints are accepted only if their validation is demonstrated.
  • The EU HTA Regulation (EU) 2021/2282 establishes the Joint Clinical Assessment at EU level; PICO questions are consolidated across several Member States, which increases the number of comparisons and subgroups that have to be addressed.
  • Medical devices do not go through AMNOG. Methods involving high-risk-class medical devices in the inpatient setting fall under SGB V §137h; the assessment logic, timelines and evidence requirements differ fundamentally from the medicinal-product benefit assessment.

Services

How we support you

Comparator & Endpoint Strategy

Early determination of the likely appropriate comparator therapy under SGB V §35a and of the patient-relevant endpoints per the IQWiG methods paper, documented as a strategy paper before the study-design lock.

AMNOG Dossier Preparation (G-BA / IQWiG)

Complete dossier in line with the AM-NutzenV and the G-BA Rules of Procedure including all modules, with a traceable derivation of the extent and probability of added benefit for each patient group.

NICE STA & HAS Submission

Preparation of the submission for the NICE Single Technology Appraisal and the HAS procedure, with evidence synthesis and comparison logic adapted to each body's methodology.

Learn more

SGB V §137h Assessment for Medical Devices

Preparation of the information documents under SGB V §137h for methods involving high-risk-class medical devices, structuring the evidence along the G-BA assessment criteria.

Mock Review & Written Comments

Simulated agency assessment (mock review) ahead of submission, plus preparation of the written comments on the IQWiG assessment report, with evidence-backed rebuttal of the points of criticism.

Oral Hearing

Preparation for and support during the oral hearing at the G-BA, including the line of argument, anticipation of follow-up questions and a coordinated allocation of roles during the appearance.

What it comes down to

An HTA dossier is not measured by its data quality but by its fit with the prescribed comparator therapy. In the AMNOG procedure under SGB V §35a, the G-BA sets the appropriate comparator therapy, and the added benefit must be demonstrated precisely against that regimen. This entails a strict sequence: first the likely zVT is established, then the choice of patient-relevant endpoints per the IQWiG methods paper, then the study design, and only after that the dossier. Reverse this chain and lock the study design first, and you may end up building the evidence against the wrong comparator. That is the most expensive mistake in the procedure, because it can no longer be corrected during the writing phase.

The second bottleneck lies in translating between the different assessment worlds. A NICE submission centers on cost-effectiveness, AMNOG on the extent and probability of added benefit per patient group, and under Regulation (EU) 2021/2282 the Joint Clinical Assessment consolidates the PICO questions across several Member States. For high-risk-class medical devices in the inpatient setting, AMNOG does not apply in any case; instead, SGB V §137h applies with its own logic. We build the evidence synthesis so that it supports the broadest comparison requirement, and adapt only the argumentation per body rather than starting over for each procedure. Ahead of submission, the mock review reveals where a reviewer will call the added benefit into question, while the answer still belongs in the dossier and not only in the oral hearing.

Our approach

Our approach

01

Comparator & Endpoint Strategy

Defined likely zVT and patient-relevant endpoints, reconciled with the existing study design before any data has been collected.

02

Evidence Assessment & Gap Analysis

Assessment of whether the available evidence addresses the zVT under SGB V §35a; identified gaps with options (indirect comparison, RWE, subgroups).

03

Dossier Preparation

Complete dossier in line with the AM-NutzenV, or submission per NICE / HAS methodology, with a consistently evidence-backed derivation of added benefit.

04

Mock Review

Simulated IQWiG / NICE assessment with a list of likely objections and revised dossier passages before submission.

05

Submission & Written Comments

Dossier submitted on time, written comments on the assessment report with the points of criticism rebutted.

06

Oral Hearing

Prepared hearing at the G-BA with a coordinated line of argument and documented answers to follow-up questions.

Common pitfalls

Where projects commonly fail

The appropriate comparator therapy is clarified too late.

If the zVT under SGB V §35a is only considered while the dossier is being written, the pivotal trial may have been run against placebo or a different comparator. A retrospective head-to-head comparison can then no longer be produced, and the added benefit is deemed unproven.

Surrogate endpoints are used without validation.

Under its methods paper, IQWiG primarily accepts mortality, morbidity and quality of life; progression-free survival or a laboratory value without demonstrated surrogate validation will not carry the benefit argument.

Patient groups are not cleanly delineated.

The G-BA assesses the extent and probability of added benefit per patient group; a grouping that is too coarse or inconsistent with the therapeutic indication causes individual subgroups to drop out without a recognized added benefit.

Medical devices are forced into the AMNOG framework.

Methods involving high-risk-class medical devices run through SGB V §137h with its own assessment logic and its own timelines; anyone who structures them like a medicinal-product benefit assessment addresses the wrong criteria.

The EU HTA requirements are conceived nationally.

Under Regulation (EU) 2021/2282, PICO questions are consolidated across several Member States; anyone who designs the evidence synthesis around a single national comparator therapy will have to supply additional comparisons and subgroups retrospectively for the Joint Clinical Assessment.

FAQ

Frequently asked questions

When a new active substance enters the market, the manufacturer submits a benefit dossier to the G-BA under SGB V §35a. IQWiG (or the G-BA itself) assesses it against the defined appropriate comparator therapy; written comments and an oral hearing follow before the G-BA decides on the added benefit. The reimbursement-amount negotiations follow on from that.

Sources
  • Sozialgesetzbuch Fünftes Buch (SGB V, German Social Code Book V), §35a (early benefit assessment) and §137h (methods involving high-risk-class medical devices), primary text
  • Arzneimittel-Nutzenbewertungsverordnung (AM-NutzenV, Medicinal Products Benefit Assessment Ordinance), primary text
  • Verfahrensordnung des Gemeinsamen Bundesausschusses (VerfO G-BA, G-BA Rules of Procedure)
  • IQWiG, Allgemeine Methoden (General Methods / methods paper)
  • Regulation (EU) 2021/2282 on health technology assessment (HTA Regulation), primary text
  • NICE, Health Technology Evaluations: the manual (Single Technology Appraisal)
  • https://theentourage.de/expertise/hta-dossier/ (existing page content, revised)

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Regulations & standards considered

  • SGB V §35a (Early benefit assessment of medicinal products, AMNOG)
  • SGB V §137h (Assessment of new diagnostic and treatment methods involving high-risk-class medical devices)
  • Arzneimittel-Nutzenbewertungsverordnung (AM-NutzenV) (Medicinal Products Benefit Assessment Ordinance)
  • Verfahrensordnung des Gemeinsamen Bundesausschusses (VerfO G-BA) (G-BA Rules of Procedure)
  • IQWiG Allgemeine Methoden (General Methods / methods paper)
  • Regulation (EU) 2021/2282 (HTA Regulation, EU-HTAR)
  • NICE Health Technology Evaluations: the manual (Single Technology Appraisal)

Have a concrete project?

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