China Introduces Pre-Communication Mechanism for Pharmacoeconomic Comparators

In February 2026, China’s National Healthcare Security Administration (NHSA) introduced the Measures for Pre-Communication on Reference Drugs (Interim). While technical in nature, the policy represents an interesting initiative within China’s evolving pharmacoeconomic framework and may have practical implications for companies preparing for reimbursement discussions.

At its core, the new mechanism allows pharmaceutical companies to communicate with the NHSA in advance to determine the reference drug (comparator) used in pharmacoeconomic evaluation.

Although this may appear to be a procedural change, the choice of comparator is one of the most influential assumptions in health economic evaluation. Different comparators can lead to very different conclusions about clinical value, incremental effectiveness, and ultimately the perceived economic value of a medicine. As such, the ability to discuss comparator selection with the payer before formal evaluation introduces a notable development in how pharmacoeconomic evidence may be prepared for China’s reimbursement system.

Why Comparator Selection Matters

In health economic analysis, comparator choice determines the baseline against which a new therapy is evaluated. If the comparator reflects the most relevant standard of care, the economic model is more likely to align with payer expectations. If the comparator differs from what the payer considers appropriate, disagreements can arise that may affect the overall assessment of value.

From this perspective, the new mechanism can bring greater predictability. Early communication with the NHSA may help companies align methodological assumptions before investing significant effort into pharmacoeconomic modelling. This could reduce the risk of major methodological disagreements during reimbursement assessment and help streamline discussions between industry and the payer.

For companies preparing submissions related to China’s National Reimbursement Drug List (NRDL), such alignment could prove particularly valuable.

Potential Challenges for International Companies

However, the mechanism also introduces new practical considerations.

For companies that are less familiar with China’s healthcare policy environment — or that do not yet have strong local market access capabilities — preparing for pre-communication with the payer may involve additional complexity and workload. Effective engagement requires more than technical pharmacoeconomic modelling. It also requires a strong understanding of China’s reimbursement logic, policy priorities, and the broader context in which economic evidence is evaluated.

In practice, this means that companies may need to carefully consider their evidence strategy earlier in the market access planning process, including how comparator selection aligns with clinical practice and policy expectations in China.

A Sign of China’s Evolving Pharmacoeconomic Framework

Pharmacoeconomic evaluation was originally introduced to China largely as a methodological framework developed in Western health technology assessment (HTA) systems. Over time, however, the discipline has increasingly been adapted to fit the institutional and policy context of China’s healthcare system.

Rather than simply replicating Western HTA approaches, China’s reimbursement framework continues to evolve in ways that reflect local healthcare priorities, policy structures, and decision-making processes. The introduction of a formal mechanism for comparator pre-communication is one example of how the system is gradually developing its own operational characteristics.

For international pharmaceutical companies, understanding this evolution is becoming increasingly important. Evidence generation strategies, economic modelling assumptions, and engagement with policymakers may all need to be planned with China-specific considerations in mind.

Looking Ahead

While the Measures for Pre-Communication on Reference Drugs (Interim) remain an early step, they provide insight into the direction of China’s pharmacoeconomic governance. The ability to discuss comparator selection with the payer before formal evaluation may offer valuable clarity for companies preparing reimbursement strategies.

At the same time, the policy reinforces the importance of local market access insight and early strategic planning when navigating China’s reimbursement landscape.

At MAAB Group, we continue to monitor developments in China’s healthcare policy and reimbursement environment and support international partners in navigating the country’s rapidly evolving market access landscape.

Source:

National Healthcare Security Administration (NHSA).Measures for Pre-Communication on Reference Drugs (Interim)

https://www.nhsa.gov.cn/art/2026/2/10/art_109_19642.html