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Reframing NICE's Cost-Effectiveness Threshold: Technical Benchmark or Policy Signal? A Documentary Content Analysis
Hesam Ghiasvand1, Seyran Naghdi2
1Centre for Healthcare and Community Transformation, Coventry University, Coventry, England, UK.
Objectives:
This study aimed to examine how governmental, industry, academic, consultancy, journalistic, and international health technology assessment (HTA) stakeholders framed the cost-effectiveness threshold (CET) uplift announced for the National Institute for Health and Care Excellence (NICE) in December 2025 during the early phase of policy debate.
Methods:
A qualitative documentary content analysis was conducted following the READ framework (Ready your materials, Extract data, Analyse data, and Distil your findings) for systematic document analysis in health policy research. Twenty-seven publicly available documents published between October 2025 and March 2026 were purposively sampled across government, NICE, industry, academia, consultancy, journalism, civil society, and international HTA actors. Data were analyzed through iterative coding and thematic synthesis.
Results:
The 2025 to 2026 debate extended beyond technical discussions of cost-effectiveness and revealed 5 interrelated themes. First, government documents explicitly reframed the CET as an instrument of industrial policy, economic growth, and pharmaceutical competitiveness. Second, substantial disagreement emerged regarding HTA governance and ministerial involvement in threshold setting. Third, stakeholders advanced competing interpretations of the consequences of the reform, with government and industry emphasizing innovation access, whereas academic and public-interest sources highlighted opportunity costs, service displacement, and population-health impacts. Fourth, many documents situated the reform within broader geopolitical and pharmaceutical-policy dynamics, including trade negotiations, investment incentives, and potential international spillovers. Finally, stakeholders expressed contrasting views regarding transparency, consultation, and procedural legitimacy.
Conclusions:
The NICE threshold uplift was framed as a politically mediated reform with implications for industrial strategy, HTA governance, healthcare resource allocation, and public trust. The findings demonstrate how CETs can become sites of broader political, economic, and institutional contestation, extending beyond their conventional role within health-economic evaluation.
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