001 | WHAT TO DO WHEN THE RULES CHANGE
Don’t just comply. Rethink how you compete.
What the NHS Drug Tariff Part IX Enhanced Assessment Framework can teach us about commercial strategy.
What the NHS Drug Tariff Part IX Enhanced Assessment Framework can teach us about commercial strategy.
What the NHS Drug Tariff Part IX Enhanced Assessment Framework can teach us about commercial strategy.
8 min read · Commercial strategy · 5 Aug 2026
8 min read · Commercial strategy · 5 Aug 2026
There are moments in every industry when regulations change.
The rational response is to understand the new rules, work out what’s now required, and then comply as efficiently as possible.
There are moments in every industry when regulations change.
The rational response is to understand the new rules, work out what’s now required, and then comply as efficiently as possible.
There are moments in every industry when regulations change.
The rational response is to understand the new rules, work out what’s now required, and then comply as efficiently as possible.
But this approach misses an important opportunity.
WHAT IS NHS DRUG TARIFF PART IX?
Part IX is a structured assessment of wound-care products available on reimbursement.
Quality | 50
Minimum requirement = 20
Up to three value-add areas (listed below) = 30
Effectiveness · Self-care · System savings · Inequalities
Evidence: clinical or real-world evidence, performance, patient and economic proof.
Social value | 10
Circular economy = 4
Sustainable packaging = 2
Supply-chain resilience = 4
Evidence: lifecycle, recyclability, packaging and continuity data.
Price | 40
Cluster benchmark = 40
−1.25 points per 1% above benchmark
More than 32% above = Fail
To be available for reimbursement, products must pass a threshold score of 55.
commoditisation is the symptom of unclear differentiation
Like all products, wound care is susceptible to commoditisation when meaningful differentiation is unclear.
Like all products, wound care is susceptible to commoditisation when meaningful differentiation is unclear.
Like all products, wound care is susceptible to commoditisation when meaningful differentiation is unclear.
With price a key criterion in this new framework, further commoditisation seems inevitable.
With price a key criterion in this new framework, further commoditisation seems inevitable.
With price a key criterion in this new framework, further commoditisation seems inevitable.
But stricter requirements for evidence present an opportunity.
CONSTRAINTS CAN BE A CATALYST
Defines the playing field.
Defines how you choose to compete on it.
Rules create the boundaries. They do not make the choices for you.
MANUFACTURERS FACE TWO CHOICES REGARDING EVIDENCE
Develop evidence to protect existing listings as efficiently as possible.
Clarify portfolio roles.
Decide how each product should compete.
Build evidence around those choices.
Either choice may lead to a successful submission.
Only one leaves the business more competitive.
FOR EACH PRODUCT, START WITH ONE COMMERCIAL QUESTION
Different functions naturally ask different commercial questions.
Different functions naturally ask different commercial questions.
Different functions naturally ask different commercial questions.
Clinical | What evidence should we generate?
Market Access | What does the submission require?
Marketing | What messages should we communicate?
Pricing | What price can we sustain?
Sales | What materials does the field need?
Part IX creates an opportunity to align around one question
How do we want this product to compete?
TAKE THE OPPORTUNITY TO REOPEN IMPORTANT CONVERSATIONS
What role is each product supposed to play?
Which are strategically important?
Which simply complete the portfolio?
Which deserve future investment?
Which should command a premium?
Which should compete aggressively on price?
Are we generating the evidence that supports each product’s role?
Which are strategically important?
Which simply complete the portfolio?
Which deserve future investment?
Which should command a premium?
Which should compete aggressively on price?
Are we generating the evidence that supports each product’s role?
Which are strategically important?
Which simply complete the portfolio?
Which deserve future investment?
Which should command a premium?
Which should compete aggressively on price?
Are we generating the evidence that supports each product’s role?
EVIDENCE FOLLOWS STRATEGY
The Commercial Evidence Chain
Role
What job should the product perform in the portfolio and market?
Decisions
Whose behaviour must change to achieve this?
Claims
What must they believe?
Evidence
What would prove it?
Returns
Where else can that proof create value?
Evidence gathering serves to activate the new strategy.
PROPERLY PLANNED EVIDENCE CAN HAVE MULTIPLE RETURNS
One commercial strategy.
One evidence strategy.
Multiple commercial returns.
Pricing discussions | Procurement conversations | Formulary reviews | Customer engagement | Future portfolio decisions
Pricing discussions | Procurement conversations | Formulary reviews | Customer engagement | Future portfolio decisions
Pricing discussions | Procurement conversations | Formulary reviews | Customer engagement | Future portfolio decisions
SUMMARY | START WITH ONE COMMERCIAL QUESTION
How do we want this product to compete?
The answer should determine everything that follows.
The answer should determine everything that follows.
The answer should determine everything that follows.
DAVID Insight 001 | WHAT to do when the rules change
