Why AMNOG is won or lost in the first 90 days
The dossier teams who win Zusatznutzen don't out-write everyone else. They out-sequence them.
Day 1–30: lock the evidence skeleton
Most teams open with the comparator debate. That is already too late. Day 1 is for the evidence skeleton: the exact PICO, the studies that will carry Module 4, and a one-page map of every claim you intend to make and the citation that defends it. If a claim does not have a source by day 30, it does not go in the dossier.
| The old way | The Knowledgeable way |
|---|---|
| Comparator workshop in week 6 | Comparator hypothesis in week 1, stress-tested against G-BA precedent in week 2 |
| Evidence review handed to an external SR vendor | Living evidence map with every claim source-linked, refreshed nightly |
| Module 4 draft starts week 14 | Module 4 skeleton populated from day 1; only the narrative is written late |
Day 31–60: defend the comparator
Your comparator choice is the single highest-leverage decision in the entire submission. Defend it in writing before week 9 — including a memo of the comparators the G-BA has accepted and rejected in adjacent indications over the last 36 months.
Day 61–90: write the reviewer-anticipation memo
The reviewer-anticipation memo is the artefact most teams skip — and it is the one that converts a beträchtlich into a defensible erheblich. Walk through every weak link in your evidence chain, anticipate the G-BA question, and write the answer before they ask it.
- Verfahrensordnung des G-BA (Kap. 5)· G-BA· 2024
- AMNOG-Report 2024· DAK / IGES· 2024
- Lauer-Taxe price trajectory after Zusatznutzen rulings· WIdO· 2023
Run your next AMNOG submission as a sprint
Knowledgeable compresses the 90-day sequence into a single workspace — evidence skeleton, comparator memo, and Module 4 skeleton, all source-linked.
See the AMNOG workspace