Convergence, Divergence and Hybridity: A Regulatory Governance Perspective on Health Technology Assessment in England and Germany

Countries adopt different methods and processes to evaluate the benefits and costs of health technologies. It is important to identify and analyse the factors that influence the uptake and use of these methods and processes across countries. In this article, we introduce a regulatory governance approach to the analysis of convergence, divergence and hybridity in Health Technology Assessment (HTA) methods, discussing and critically analysing national processes for HTA in two major EU member states: England and Germany. We argue that any reasonably sophisticated account of national approaches to HTA must recognise that globalisation and the emergence of advanced industrial society involves the potential for widely varying processes, methods and evidential requirements. We suggest that this potential also confronts health policy analysts with the challenge of constructing analytical frameworks capable of identifying the diverse institutional, domestic and other factors that shape national approaches to HTA. A regulatory governance perspective can also potentially suggest some means by which their operations can be improved.