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Selection from Decision-Making Practice - 16

Pharmeca a.s. 25. 06. 2025

The conditions for reimbursement of off-label indications are governed by Section 39b(3) of the Act on Public Health Insurance. To establish reimbursement, it is necessary to demonstrate that the use of the assessed medicinal product in the given off-label indication is sufficiently justified by current scientific knowledge and that its use represents the only available treatment option.
If it is not the only treatment option, reimbursement can still be granted provided that the applicant demonstrates cost-effectiveness compared to existing therapies.
If the condition of sufficient scientific justification is not met during the procedure, the Institute does not assess compliance with the remaining conditions.

Sufficient scientific knowledge is evaluated based on the evidence related to the specific indication. Recently, the State Institute for Drug Control (SÚKL) reached different conclusions on this condition for two indications of the same product: the treatment of high-grade squamous intraepithelial lesions of the vulva (HSIL) and extramammary Paget’s disease of the vulva (EMPD). Both proposed indications, HSIL and EMPD, are off-label.
The Institute determined that, based on available evidence, the use of the product in the treatment of vulvar HSIL is sufficiently supported by current scientific knowledge. Additionally, the product was found to be cost-effective, and therefore the reimbursement conditions for this off-label indication can be established.
In contrast, for EMPD, the use of the product was deemed insufficiently justified. The studies provided exhibited several methodological limitations, such as small patient samples, lack of a control arm, and observational design. As a result, the Institute proposes not to grant reimbursement for the EMPD indication.


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Articles on decision-making practice are based on publicly available texts from the decisions of the Ministry of Health of the Czech Republic and the State Institute for Drug Control (SÚKL).

A continuously updated overview of decisions issued by SÚKL and the Ministry of Health in the field of pricing and reimbursement is available on the Pharmeca a.s. website.

The text was translated using ChatGPT 4o. 

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