Suggestions for improvement of the Danish Health Technology Council (DTHC)

In our previous post, we summarized the three key learnings from the first 1.5 year of the DHTC’s existence.

Based on these conclusions we consider it appropriate to provide our suggestions for how to optimize or solve some of the identified issues.

  1. Remove the requirement about cost neutrality: If the DHTC wishes to meet their own ambitions of 15-25 evaluations annually they must acknowledge that innovative therapies in many cases will be associated with higher costs than current Standard of Care (SoC). Consequently, it is crucial to remove the requirement of cost-neutrality. In other HTA bodies, including the Danish Medicines Council (DMC), it is expected that incremental benefits (e.g., QALYs) are associated with additional costs. The discussion in other HTA bodies always revolves around how much are willing to pay for the incremental benefit and not if they are willing to pay for the incremental benefit.


  1. Anchor DHTC decisions in regional implementation: Currently, it is not a requirement to apply to the DHTC to get market access in Denmark. Additionally, it is unclear how DHTC decisions will be implemented in the Danish Regions. This combination removes any incentives to invest in the resources required to develop an application to the DHTC. This needs to change if the DHTC wish to conduct 15-25 evaluations annually. There needs to be structural link between the decisions made by the DHTC and how the Danish Regions implement technologies. NHS compliance with positive recommendations from NICE MedTech program, has been the subject of some criticism and as a consequence NICE have initiated several initiatives to deal with this issue lasted the new strategy from 2021.
    To draw a parallel to the DMC; companies choose to submit to the DMC for a great majority of all new drugs, because market access is de facto very difficult without a DMC recommendation. It needs to be clear what the potential benefits are of submitting to the DHTC.