Should Environmental Considerations be Captured in HTAs?

Following on from similar discussions at ISPOR Europe 2024, incorporating environmental sustainability into value and access discussions was a hot topic at ISPOR Europe 2025.1–4

How Should Environmental Sustainability be Considered in HTA Decision-Making?

Incorporating environmental sustainability was often discussed in the context of ISPOR’s strategic focus on Whole Health in their 2030 Strategic Plan, which calls for a holistic approach to healthcare to incorporate physical, mental, social, environmental, and spiritual dimensions of wellbeing, moving beyond clinical efficacy and cost, to include wider determinants of health.5

While there have been some significant developments since ISPOR Europe 2024, including the launch of the ISPOR special interest group (SIG) for Environmental Assessment in Health Economics and Outcomes Research (HEOR), not much seems to have changed in terms of clarity on which decisions environmental sustainability should inform and how best to capture the environmental impact of new healthcare interventions in a robust way.

A few headline takeaways from the conference this year:

  • The newly formed ISPOR SIG for Environmental Assessment in HEOR have suggested formally including environmental sustainability on the ISPOR value flower to encourage consideration in Health Technology Assessment (HTA) decision making, but a clear framework on how to assess environmental sustainability is currently lacking
  • NICE are running a HTA Lab on comparing the environmental impacts of health technologies, which may go some way to addressing the current lack of guidance on incorporating environmental sustainability in HTA decision-making
  • Many stakeholders felt that incorporating environmental sustainability into procurement decisions rather than HTA may be more appropriate, to avoid delaying access to new treatments

Should Environmental Sustainability Be Included Alongside Traditional Value Criteria in HTAs?

Perspectives on whether it is possible to incorporate environmental factors into HTA decision making without diluting patient-focused outcomes differed. Some stakeholders were particularly concerned that trying to include environmental factors in HTA decision-making would unnecessarily delay patient access to new medicines given the complexity and uncertainty associated with quantifying the environmental impact of new interventions, particularly given that medicines are often manufactured in a different country to where they are ultimately used.

It was suggested that environmental considerations could instead be part of procurement decisions when comparing similar products – products with a more favourable environmental impact should be selected over a treatment with similar efficacy and safety, but poorer environmental outcomes. However, excluding environmental factors from HTA decision-making would mean that environmental benefits are not reflected in the willingness-to-pay threshold for a new intervention (i.e., a price premium), which might otherwise incentivise the development and launch of more environmentally sustainable interventions. An alternative approach may be to incorporate environmental considerations within HTA for only specific types of interventions, such as those being assessed via a cost-comparison approach (based on similar efficacy and safety outcomes) or those with a particularly high carbon footprint (such as asthma inhalers) given environmental considerations are likely to be more influential in these cases.6

The incorporation of environmental considerations into HTA decision-making certainly seems to be gaining traction in some markets; the Netherlands and Canada are looking into the inclusion of environmental considerations within HTA, and NICE are running a HTA Lab on comparing the environmental impacts of health technologies. Considering environmental factors in healthcare decisions sooner rather than later will be particularly important for countries with specific environmental targets, such as the ambitious NHS England targets of net zero carbon emissions by 2045 (for emissions the NHS can influence).7 However, developing robust and consistent frameworks to evaluate the environmental impact of new interventions will be essential to any further progress in this space.

How Can Environmental Sustainability Be Included Alongside Traditional Value Criteria?

Although several sessions at the conference discussed frameworks that could be used to assess the environmental impact of new healthcare interventions, including the results of a multistakeholder workshop held by the HTA international (HTAi) Environmental Sustainability in Health Technology Assessment (ESHTA) working group, we seem to be far from a consensus on how to accurately and efficiently assess the environmental impact of new interventions.8 Until such frameworks mature and alignment is reached across stakeholders on how to assess environmental impact within HTA,  environmental impact is likely to remain an informative input rather than a key decision driver, captured as a complementary input only.9 This will be a key area of focus for the ISPOR SIG for Environmental Assessment in HEOR, and there is likely to be substantial progress on this in the next few years as national and European stakeholders, and the general public, drive a continued focus on assessing environmental sustainability.

What Questions Remain Unanswered?

Overall, despite many research projects evaluating where and how to best capture the environmental impact of new healthcare interventions over the past few years,8–14 there are several important outstanding questions that must be addressed to define the place of environmental sustainability in HTA decision-making:

  • Should environmental sustainability be a formal criterion in the core HTA framework, or is it better captured in procurement decisions?
  • Should environmental sustainability be assessed routinely, or for specific technologies/in specific therapy areas with high environmental impact?
  • Should health budgets be used to meet carbon reduction targets?
  • Which environmental outcomes (emissions, resource use, waste, supply chain resilience) should be prioritised, and how should they be weighed against quality-adjusted life years and cost?

The HTAi ESHTA working group are planning a Delphi study to further explore stakeholder opinions on the incorporation of environment sustainability in HTA; the results of this research may help to answer some of these questions and drive further progress in this field.

References

  1. Value assessment from a whole health perspective: opportunities and challenges. ISPOR Europe 2025.
  2. Does environmental sustainability warrant a spot on ISPOR’s value flower? ISPOR Europe 2025.
  3. Can we have it “whole”? Barriers and opportunities for embracing a whole health perspective in HEOR. ISPOR Europe 2025.
  4. Adding nature’s petal to the value flower: Can inclusion of environmental impact in HTA aid the race to net zero? ISPOR Europe 2025.
  5. ISPOR. Whole Health. Access this article. Last accessed: December 2025.
  6. Smith A, Newby O, Sowman A, et al. Investigating the Quantitative Effect of Integrating Environmental Impacts into Economic Evaluations: To What Extent Could Environmental Sustainability Influence Decision Making in Health Technology Assessment? Presented at ISPOR Europe 2024.
  7. NHS England. Delivering a net zero NHS. 2024. Access this article. Last accessed: December 2025.
  8. Holtorf A-P, Pegg M, Mueller D, et al. Toward including environmental sustainability in Health Technology Assessment. International Journal of Technology Assessment in Health Care 2025;41:e70.
  9. Ardito V, Banks H, Tarricone R. Which Factors are Holding up the Integration of the Environmental Impact of Health Technologies in Health Technology Assessment? Insights from a Multi-Stakeholder Interview Study. Applied Health Economics and Health Policy 2025.
  10. Hensher M. Health technology assessment and healthcare environmental sustainability: Prioritizing effort and maximizing impact. International Journal of Technology Assessment in Health Care 2024;40:e25.
  11. Kindred M, Shabrina Z, Zakiyah N. Exploratory Approach to Incorporating Carbon Footprint in Health Technology Assessment (HTA) Modelling: Cost-Effectiveness Analysis of Health Interventions in the United Kingdom. Applied Health Economics and Health Policy 2024;22:49-60.
  12. Pinho-Gomes A-C, Yoo S-H, Allen A, et al. Incorporating environmental and sustainability considerations into health technology assessment and clinical and public health guidelines: a scoping review. International Journal of Technology Assessment in Health Care 2022;38:e84.
  13. Pizzi LT, Abbott RM, Onukwugha E. Taking Health Economics and Outcomes Research Forward: Expanding the Definition of Value to Include Whole Health. Value in Health 2025;28:702-704.
  14. Williams JTW, Bell KJL, Morton RL, et al. Methods to Include Environmental Impacts in Health Economic Evaluations and Health Technology Assessments: A Scoping Review. Value in Health 2024;27:794-804.

If you would like any further information on the summary presented above, please get in touch, or visit our Value & Access page. Alice Dean (Senior Analyst, Value & Access) and Helen Bewicke-Copley (Consultant, Value & Access) contributed to this article on behalf of Costello Medical. The views/opinions expressed are their own and do not necessarily reflect those of Costello Medical’s clients/affiliated partners.

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