Rare Disease · United Kingdom · In-Market

UK PNH HTA Strategy Model

NICE has cleared four modern PNH anti-complement therapies (ravulizumab TA698, pegcetacoplan TA778, iptacopan TA1000 and crovalimab TA1019) through its standard £20,000-30,000 Technology Appraisal route, each contingent on a confidential commercial arrangement, never the Highly Specialised Technologies threshold. A new submission inherits an unbroken standard-STA precedent it must be built to clear from the first dossier decision.

9-sheet modelStandard-STA precedent analysisIn-MarketUpdated Q3 2026
Market United Kingdom Stage
The Landscape

Every modern PNH anti-complement therapy has cleared NICE's standard £20,000-30,000 Technology Appraisal route via a confidential commercial arrangement, and crovalimab's most recent approval turned on a cost comparison against the incumbents, so a new entrant's HTA strategy must be built for the standard threshold and an established class comparator set, not the Highly Specialised Technologies band.

NICE runs two appraisal tracks for ultra-rare conditions: the standard Technology Appraisal, which applies a £20,000 to £30,000 per QALY threshold, and the Highly Specialised Technologies route, reserved for the very rarest conditions and applying a far higher threshold. PNH sits close to the prevalence boundary, yet NICE has routed every modern anti-complement therapy through the standard track. Ravulizumab was recommended under TA698 in May 2021, pegcetacoplan under TA778 in March 2022 for residual anaemia after a C5 inhibitor, iptacopan under TA1000 in 2024 as NICE's 1,000th published appraisal, and crovalimab under TA1019 in November 2024. Each recommendation was contingent on a confidential commercial arrangement rather than a lower list price. Eculizumab, the original C5 inhibitor, predates these appraisals and was commissioned directly by NHS England as a highly specialised service, not through a numbered NICE technology appraisal.

That unbroken record is the strategic problem a new submission must solve. The bar is the ordinary £20,000 to £30,000 threshold, roughly a tenth as forgiving as the HST band, and four consecutive approvals have now cleared it through confidential discounting rather than modest list pricing. Crovalimab's TA1019 raised the difficulty further by winning on a cost comparison against ravulizumab and eculizumab, which signals that NICE will accept, and increasingly expect, a non-inferiority-plus-lower-cost case in this class. A new entrant therefore has to fix its PICO around the established anti-complement comparator set, decide early between a cost-comparison and a full cost-utility submission, and size the confidential discount needed to clear the standard threshold before the dossier is drafted. Our gap register scores each of those decisions against the four-appraisal precedent, not against an HST eligibility the class has never been granted.

£20K–30K
NICE standard Technology Appraisal QALY threshold every modern PNH anti-complement drug has cleared, none via the Highly Specialised Technologies band
4 of 4
modern PNH anti-complement therapies routed through the standard Technology Appraisal route (ravulizumab TA698, pegcetacoplan TA778, iptacopan TA1000, crovalimab TA1019)
TA698 · TA778 · TA1000 · TA1019
the four standard NICE appraisals that set the PNH HTA precedent, each contingent on a confidential commercial arrangement
9
sheets in the HTA Strategy Model: authority landscape, PICO framework, comparator defence, value-dossier self-assessment, HEOR gap register, economic model and submission timeline, client alignment questions
SUBMISSION PRECEDENT

UK PNH NICE appraisal precedent — four standard Technology Appraisals, no HST, each on a confidential arrangement

AgentNICE TAAppraisal Route & OutcomePrecedent for a New Entrant
Ravulizumab (Ultomiris)TA698Standard STA, recommended May 2021 with confidential PASStandard £20K-30K threshold; the entrenched anti-C5 comparator
Pegcetacoplan (Aspaveli)TA778Standard STA, recommended March 2022 for residual anaemia after a C5 inhibitorStandard threshold; sets the residual-anaemia comparator
Iptacopan (Fabhalta)TA1000Standard STA, recommended 2024 (NICE's 1,000th appraisal), confidential arrangementStandard threshold; the oral Factor B comparator
Crovalimab (Piasky)TA1019Standard STA, recommended Nov 2024 on a cost comparison vs eculizumab and ravulizumab, simple-discount PASSignals NICE will accept a cost-comparison case in this class
Eculizumab (Soliris)None (pre-appraisal)NHS England highly specialised commissioningOriginal C5 inhibitor; not a numbered NICE appraisal

Sources: NICE TA698 (ravulizumab, 2021); NICE TA778 (pegcetacoplan, 2022); NICE TA1000 (iptacopan, 2024); NICE TA1019 (crovalimab, November 2024); NHS England Highly Specialised Services specification for PNH.

Commercial Questions

What this model answers

Every section answers a named commercial question your team is asking, scoped to your asset.

01
NICE has appraised every modern PNH anti-complement drug through its standard Technology Appraisal route, never the Highly Specialised Technologies band. What threshold and comparator precedent does a new submission actually inherit?

Delivers

  • The prevalence and precedent logic behind four consecutive standard-STA recommendations (TA698, TA778, TA1000, TA1019)
  • why the £20,000-30,000 threshold, not the HST band, is the fixed bar
  • and the anti-complement comparator set a new PICO must be built around
02
Crovalimab's TA1019 was recommended on a cost comparison against the incumbent C5 inhibitors rather than a fresh cost-utility model. Should a new entrant submit a cost-comparison or a cost-utility case?

Delivers

  • The decision logic between a cost-comparison and a cost-utility submission in this class, tested against the TA1019 precedent and the value-dossier self-assessment, and what each route demands of the economic model
03
What confidential discount and pre-submission stakeholder sequence does a new PNH agent need to clear NICE's standard threshold on the MHRA approval timeline?

Delivers

  • PAS discount depth benchmarked to the incumbent confidential arrangements, the NICE pre-submission scoping and MHRA ILAP timing (roughly 24 months pre-approval), and the Leeds National PNH Registry real-world evidence that strengthens the dossier

Custom model delivered in 72 hours.

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Contents

What's inside

Rare Disease · 24–32 pp · In-Market · Analyst report + Excel model + PowerPoint readout

1 The Binding Constraint 2 pp
  • Why the unbroken standard Technology Appraisal precedent, not the HST band, is what a new submission must be built to clear first
  • Pressure-tested against the TA698, TA778, TA1000 and TA1019 record before the rest of the model is built out
2 HTA Authority Landscape 3 pp
  • NICE's standard Technology Appraisal process and why all four PNH anti-complement approvals used it rather than the Highly Specialised Technologies route
  • How NHS England Highly Specialised Services commissions the class, and what that adds to a numbered NICE appraisal
3 PICO Framework 3 pp
  • Population, Intervention, Comparator and Outcomes built around the established anti-complement comparator set
  • Framing the broad haemolytic-anaemia population against the 200-250 patient EVH-dominant residual-anaemia cohort from the Leeds National PNH Registry
4 Comparator Defence 3 pp
  • The 3-test comparator defence applied to a new C5 or Factor B entrant against ravulizumab and iptacopan
  • What crovalimab's TA1019 cost-comparison win signals about the comparator case NICE now expects in this class
5 Value Dossier Self-Assessment 3 pp
  • 5-module, 15-check self-assessment against submission readiness
  • Testing the dossier against the cost-comparison and confidential-PAS precedent the four incumbents have set
6 HEOR Gap Register 3 pp
  • Utility and quality-of-life, transfusion-offset and EVH-sizing evidence gaps scored by likelihood of challenge and impact
  • Submission-blocking versus manageable classification for each gap
7 Economic Model & Submission Timeline 4 pp
  • Choosing between a cost-comparison and a cost-utility model, and the PAS discount depth (roughly 30-40% off a UK price near £250,000 per year) needed to clear the standard threshold
  • Milestone timeline incorporating NICE pre-submission scoping and an MHRA ILAP filing roughly 24 months ahead of approval, with Leeds National PNH Registry real-world evidence
8 Client Alignment Questions 2 pp
  • The open HEOR and stakeholder-engagement questions your team must close before the dossier is finalised
Appendix and source ledger included · 45-minute analyst readout included with delivery
Formats

Included with every brief

PDF
PDF Brief
HTA Strategy Brief — Complete Edition
PDF methodology brief accompanying the 9-sheet HTA strategy model: authority landscape, PICO framework, comparator defence, and HEOR gap register for UK PNH.
XLS
Excel Model
HTA Strategy Model — Excel
9-sheet editable model: Cover, HTA Authority Landscape, PICO Framework, Comparator Defence, Value Dossier Self-Assessment, HEOR Gap Register, Economic Model & Submission Timeline, Client Alignment Questions, QC.
Methodology

How AXLRx builds this model

Prepared by MoatRx analysts.

Every AXLRx HTA strategy model is built from primary HTA-body sources: NICE technology appraisals and final guidance documents, not secondary summaries. Every comparator and threshold claim is pressure-tested against the live appraisal record before it is accepted.

UK PNH HTA sources: NICE TA698 (ravulizumab), TA778 (pegcetacoplan), TA1000 (iptacopan) and TA1019 (crovalimab), plus the NHS England Highly Specialised Services specification for PNH. Each appraisal was checked to confirm the standard Technology Appraisal route and the £20,000-30,000 threshold, not the Highly Specialised Technologies band.

  • Ravulizumab TA698, pegcetacoplan TA778, iptacopan TA1000 and crovalimab TA1019 each confirmed as standard single technology appraisals against live NICE guidance
  • Crovalimab's TA1019 cost-comparison basis and simple-discount patient access scheme verified against the live NICE recommendation
  • Population figures (roughly 1,500 diagnosed, roughly 600 on complement inhibition, 200-250 EVH-dominant) verified against AXLRx's UK PNH launch-readiness research and the Leeds National PNH Registry
FAQ

Frequently asked questions

Deliverables
What formats are included with every model?
Every commissioned HTA Strategy Model includes an editable 9-sheet Excel model (Cover, HTA Authority Landscape, PICO Framework, Comparator Defence, Value Dossier Self-Assessment, HEOR Gap Register, Economic Model & Submission Timeline, Client Alignment Questions, QC) and a PDF methodology brief. No PowerPoint deck, since an HTA strategy model is built to be worked in directly, not presented from. An optional 45-minute analyst readout call is included.
Sources
How is the HTA evidence verified?
AXLRx builds from primary sources only: NICE technology appraisals and final guidance documents, not secondary summaries. Every appraisal route, threshold and commercial-arrangement detail is independently verified before inclusion.
Customisation
Can I scope this to a specific comparator set or evidence-generation plan?
Yes. The intake form captures your indication, target HTA bodies, and comparator set. A scoping call confirms scope, including cost-comparison versus cost-utility framing and pre-submission stakeholder timing, before research starts. Commission via the intake form to start.
Get Started

Commission this model

AXLRx delivers rare-disease HTA strategy models built for market access and HEOR teams navigating NICE's standard Technology Appraisal precedent and confidential-arrangement dynamics. Custom model in 72 hours.

1
Submit your request

Specify your indication, HTA bodies, and comparator scope.

2
Scoping call

AXLRx analyst confirms comparator set, submission-route framing, and stakeholder-engagement timeline before building.

3
Delivery

Research-verified HTA strategy model in 72 hours with optional analyst readout.