There is an assumption that NHS market access for medtech can be difficult because of regulatory and clinical requirements: obtaining CE or UKCA marking, generating evidence, and navigating NICE. In practice, products with full regulatory approval, positive clinical trial data and NICE guidance can spend years sitting largely unused in the NHS because the system has no mechanism to pay for them, no ring-fenced budget to draw on, and limited incentives for an individual commissioner to change an existing pathway on the basis of national guidance with no funding obligation.
The NHS 10-year plan acknowledged that the NHS had treated procurement as a commodity exercise with lowest price as the primary driver, and the launch of the National HealthTech Access Programme (NHAP) in February 2026 represents a structural response to that problem. But it solves it for a narrow slice of the market. For most medtech and digital health companies, the adoption gap is not at the assessment stage, but at the point where a recommendation meets a system with no clear way to act on it.
NICE has consolidated three separate assessment programmes: the Medical Technologies Evaluation Programme, the Diagnostics Assessment Programme and the Interventional Procedures Programme into a single unified HealthTech Programme. The new structure has three tracks corresponding to a product’s stage in the development lifecycle:
The shift from the old supply-led model, where companies notified NICE and hoped for selection, to a need-led prioritisation process is the other significant structural change. Topics are now selected against system need, not developer interest. For companies developing products in areas NICE has named as 2025-26 priorities (mental health, early cancer detection, diabetes, musculoskeletal conditions, women’s health, respiratory and neurology), that alignment matters commercially. For those developing outside those areas, the route to evaluation is narrower than it used to be.
The National HealthTech Access Programme (NHAP) is the most significant development in NHS medtech reimbursement. By expanding NICE’s Technology Appraisal programme to include health technologies, devices, diagnostics and digital tools, it creates, for the first time, a route by which a medtech product can carry the same legal funding obligation as an approved medicine. NHS commissioners will be legally required to fund technologies recommended through the NHAP, rather than making local commissioning decisions on an ad hoc basis.
The first two technologies entering the programme are capsule sponge tests for early detection of oesophageal cancer and AI-enabled tools for analysing prostate and breast cancer tissue samples. Both are high-impact, evidence-backed, and aligned with NHS cancer priorities.
But the design of the NHAP is explicit about its scope. It will evaluate only a small number of high-impact technologies; it does not represent a general reform of medtech access. The evidence requirements, implementation readiness criteria and scale of national adoption are calibrated for products that can genuinely transform pathways at NHS-wide scale. For most medtech companies, particularly SMEs, digital health developers, and those in early-stage evidence generation, the NHAP will not substantially change the route to market.
For technologies that don’t qualify for the NHAP, the reimbursement environment has improved at the margins but not fundamentally. The MedTech Funding Mandate (MTFM), in place since 2021, aims to address the adoption gap for NICE-approved technologies, but its eligibility criteria are tough. Products must demonstrate a net cost saving within three years and carry a budget impact of under £20 million. Since its launch, the MTFM has supported only a handful of technologies in any given year. In 2025/26, the sole supported technology is AposHealth, a device for knee osteoarthritis.
That narrow gate reflects an NHS under significant financial pressure, reluctant to mandate spending that is not self-evidently cost saving in the short term. Technologies that generate long-term value through better outcomes, reduced hospitalisation or improved quality of life, rather than direct in-year cost savings, sit outside the MTFM criteria. A positive NICE recommendation in the routine use pathway, without either NHAP status or MTFM coverage, still falls to ICBs and Trusts to fund adoption from existing allocations, with no obligation beyond conforming to the guidance.
The result is that a company can invest years and significant capital in generating the clinical and health-economic evidence NICE requires, receive a positive recommendation, and then spend further years negotiating Trust-by-Trust adoption with commissioners who have other spending pressures and no directive to prioritise their technology.
This is not a new problem, but the growing body of evidence quantifying it, and the explicit acknowledgement in the 10-year plan that something structural needs to change, are new. The plan commits to new value-based procurement guidance for devices and digital products and to a regulatory review of medical devices, including AI, with a new framework due in 2026. Whether those commitments close the adoption gap will determine whether the NHAP remains an outlier or the beginning of a broader shift.
For medtech developers
The engagement strategy needs to start well before the assessment process and extend further.
NICE’s Prioritisation Board now selects topics against defined system need, meaning companies need to build a credible evidence base that speaks to those priorities, not just to clinical outcomes in isolation. A technology that addresses a named priority area with strong real-world evidence, a clear service model and a defined implementation pathway is considerably better positioned for selection than one that arrives at the notification stage only optimised against clinical trial data.
The evidence generation plans that NICE publishes alongside early use assessments are practical tools. They set out specifically what data the committee will need to convert a conditional recommendation into final guidance. Companies that actively engage with those plans are better placed to complete the cycle to full guidance and, if eligible, to NHAP consideration.
Implementation readiness is now part of the market access question. Unlike medicines, which enter the system through a prescribing decision that can be made individually by any clinician, health technologies require active commissioning, inclusion in procurement frameworks, system integration, and staff training. Each is an independent point of failure. A technology can clear every regulatory and HTA hurdle and still stall at the question of how it fits with a Trust’s electronic patient record system, or whether any practice nurse has half an hour to be trained to use it. Demonstrating that these barriers are manageable is increasingly what NICE and commissioners want to see before recommending national adoption.
For NHS professionals
The procurement landscape is changing in ways that require new commercial literacy from NHS decision-makers at all levels. The 10-year plan’s shift toward neighbourhood health is bringing medicines budgets into primary care networks in some ICBs for the first time. The shift in NICE’s approach to existing use assessment and evaluating whether current spending and price variation is justified will affect categories of devices already embedded in procurement frameworks. And the explicit commitment to value-based procurement, away from the lowest-cost default, requires commissioners to engage with a more complex set of criteria than price alone can provide.
Industry partners who understand these structural changes and enter NHS relationships with a clear view of the problem the system is trying to solve, rather than the solution they are trying to sell,have a greater chance of success. As one NHS leader working in primary care transformation described the experience of engaging with industry: the questions that matter are not about the disease burden but about how the technology fits the workflow, how it integrates with existing systems, and how it can be paid for. Those are operational and commercial questions as much as clinical ones.
The NHAP is the right structural reform, even if its immediate reach is deliberately limited. Extending the Technology Appraisal mandate to health technologies addresses a fundamental inequity: a clinician can prescribe a NICE-approved medicine, knowing the funding is guaranteed, but can recommend a NICE-approved device or digital tool with no equivalent certainty that the patient will ever access it.
The challenge is that the NHAP addresses that inequity for only a small number of technologies selected based on high-impact criteria. For the rest, the existing system remains largely unchanged.
For medtech and digital health companies building market access strategy today, there are two questions to address: what pathway is available to your technology now, and what the NHAP might mean for the next generation of your product development. Getting the answers right gives the best chance of success now and in the future.
CHASE works with pharmaceutical, medtech and digital health companies on NHS market access, commercial strategy and NHS–industry partnerships. Our insights team can help you understand where your product sits in the new NICE landscape and what that means for your evidence generation and commercial approach.
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