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hta-payer· 5 June 2026· 11 min read
Inside a NICE submission: what reviewers actually look for
A former ERG reviewer walks through the questions they were trained to ask before page 12 of any submission.
Author
Chief Innovation Officer
You can tell in the first ten minutes whether a submission has been written for the committee or for the company that paid for it. We are not subtle about flagging the difference.
How a NICE reviewer actually reads
Most reviewers triage in three passes: first the model structure, then the comparator and population, then the ICER drivers. The narrative is read last, and only to check it matches the numbers.
The six margin questions
Markov when it should be partitioned survival, three-state when four are clinically meaningful, no tunnel states for a tunnel-state disease. This is page one and it is usually wrong.
| What reviewers flag in week 1 | What they accept in week 1 |
|---|---|
| Single parametric fit, no AIC/BIC reported | Multiple fits with AIC/BIC + clinical plausibility statement |
| Utilities from a different disease area | Trial-collected EQ-5D with mapping rationale |
| Subsequent therapy ignored | Subsequent therapy modelled with sensitivity analysis |
The clarification letter trap
Every weak assumption you fail to defend in the submission becomes a clarification question, which becomes a delay, which becomes a worse committee mood. Defend up front.
Sources
- NICE Reference Case (TSD 2)· NICE DSU· 2022
- Methods for the development of NICE public health guidance· NICE· 2024
Reviewer-shaped NICE submissions
Knowledgeable reads like an ERG reviewer — flagging weak assumptions, missing comparators, and brittle extrapolations before the committee does.
See the NICE workspace