When former health minister Greg Hunt announced a review of Australia’s Health Technology Assessment (HTA) system in September 2021, the claimed promise was to examine how new therapies are assessed for public subsidy and recommend improvements to ensure the institutional framework reflects contemporary realities.
To say the path from that announcement to today has been glacial and laboourious would be an obvious exercise in understatement.
The latest revelations about the next stage of work would be almost comedic if not for the serious implications, a new timeline into 2027 and an outrageous absence of transparency by design.
We now have a non-transparent closed study involving an unidentified group of 'targeted' stakeholders to support a guideline review as an outcome of an implementation review of the initial review. You literally could not make it up.
It is probably additional evidence of the official desire to extend this review beyond the upcoming 2026-27 Budget, essentially forcing it into the negotiation for new industry agreements, which cannot get underway until 1 July this year at the earliest.
If this is the way forward, a non-transparent and potentially rigged process, the review should be considered dead on arrival because officials are effectively forcing stakeholder endorsement of an outcome they would otherwise find unacceptable.
It is the policy equivalent of a gulag. Stakeholders are prisoners to a process over which they seem to have no agency or control.
If the process is not rigged, be transparent to prove the point.
It is yet another example in this system of a select group of stakeholders being granted privilege in a closed process. Can anyone say the system has benefited from this closed-shop approach to policymaking?
It is sad, set against the backdrop of the Government's clear intent to reform the National Disability Insurance Scheme and challenge the limits of Australia's Constitution when it comes to regulating specialist medical fees.
The HTA review timeline has been long and labourious.
In September 2021, Greg Hunt announced the HTA review. The review was not formally established until October 2022, more than a year later. During May 2022, Mr Hunt named Peter Boxall AO to chair the review on the day the federal election was called. Mr Boxall's appointment never proceeded after the change of Government.
Following Labor’s victory, new Health Minister Mark Butler appointed Deb Picone AO to chair the review's Reference Committee. The committee completed its review in May 2024. In October 2024, Mr Butler created an Implementation Advisory Group (IAG) to advise the Government on responding to the review, and in September 2025, he gave an initial response to the IAG’s report at Pharmaus.
At the recent AFR Healthcare Summit, Mr Butler announced that the health department had engaged consultants to support the next steps in the process.
This includes reviewing the definitions of high unmet medical need and high added therapeutic value. It also includes reviewing the Pharmaceutical Benefits Advisory Committee submission guidance on comparator selection and the discount rate.
It has now been revealed, but only to the chosen few, that those consultants are conducting Delphi studies. These are ethics‑approved, iterative consensus exercises. effectively consulting via controlled trials to shape wording and standards.
That activity will likely push final outcomes into 2027.
The review's timeline since the initial announcement will pass 2,000 days in early 2027.
First, why are Delphi forced consensus studies being launched now to address wording and definitions that were already identified as issues during the review, with proposed solutions?
If these items were known priorities from the outset, which they were, convening structured consensus work should have been part of the review’s original design, not a belated add‑on that delays implementation again.
Of course, maybe a consensus was reached, but certain officials and decision-makers do not like it. Time to create a new one, hence secretive and potentially rigged Dephi studies.
Why is this process being run in a manner that the public cannot scrutinise?
There are no published protocols, and there is no transparency about participant selection.
Delphi study methods can be powerful for forcing consensus, but their outcomes depend entirely on who is invited, how questions are framed, how iterations are run and how dissent is handled. Without a published protocol, open recruitment criteria and disclosure of participants’ affiliations, let alone their input, the process invites scepticism that the consensus is heavily influenced by particular interests.
It is totally inappropriate for a critical public health program.
The irony is that the invitation to stakeholders was signed by the official who recently publicly lamented that clinical trials are generally funded by those with a direct financial interest. Pot, kettle.
This process is being treated like a clinical trial, with stakeholder identities and input hidden as if the risk of disclosure were akin to that of deidentified patient data.
The fact that the process is being led by existing HTA contractors to the health department is an obvious conflict of interest.
Be under no illusion, this selective, non-transparent process could fundamentally reshape public health in this country. The methodology is unworthy of any public health program, and frankly, given the non-transparency by design, it invites all sorts of discussions about conduct.
We know that pharmaceutical and medical device companies have been invited to participate. We also know that some patient groups have been invited to participate. We know that some in 'government' will participate.
It can be revealed that this means health department officials. It means HTA advisory committees and individual members. It means HTA evaluation organisations contracted by the health department.
How will the input be weighted? Will the input of an industry association, based on member feedback, receive the same weighting as an individual member of an HTA advisory committee? This is why we need transparency.
For patients, it is yet another example of some organisations being given standing over others, for reasons that are entirely non-transparent. Patient organisations should be furious that their new HTA engagement framework, with love heart emojis at the centre, was published the same day 'targeted' stakeholders were invited to participate in these Delphi studies.
It seems that some patients are more at the centre of HTA than others.
We also know that, given the medical device sector's involvement, the outcome will be applied more broadly than medicines and vaccines.
The consequences are real.
Clinicians, patients, industry and payers need clear, transparent and predictable rules. Opaque methods and selective participation will undermine that confidence. Non‑transparent consensus exercises risk over‑weighting particular perspectives if participant selection is not robust, balanced and transparent.
If the government and department intend these Delphi studies to inform enduring changes to HTA definitions, they should immediately adopt minimum transparency and governance measures.
Publish full protocols before rounds begin, disclosing objectives, question design, iteration rules, consensus thresholds, analyses and how dissenting views will be recorded and treated. Disclose participant selection and manage conflicts by publishing criteria, invitations, participant lists, and the steps taken to achieve a representative balance.
Policy reforms succeed when their technical merits are matched by legitimacy in process. After almost five years from announcement to this point, the HTA review risks being remembered less for its recommendations than for procedural missteps that left key choices shrouded in uncertainty. Launching Delphi studies without published protocols or transparent participant disclosure not only slows progress but also undermines trust. It undermines trust in the outcomes and their legitimacy.
