When the NUB Pathway Becomes a Distraction Instead of a Strategy

The NUB Pathway Is Well-Known — and That Is Exactly the Risk

In German MedTech market access, the NUB pathway is one of the most frequently discussed reimbursement routes. It is familiar, established, and often quickly recommended whenever a new technology enters the German market.

And that is precisely where the problem begins.

Because the pathway is so well-known, it is often presented as the default option — sometimes without sufficient assessment of whether it is structurally suitable for the product in question. The result is that companies may invest significant time and resources into a process that was never designed for their technology in the first place.

The phrase “it doesn’t hurt to try” may sound pragmatic. In reality, it can lead to months or even years of strategic delay.

NUB Was Designed for Specific Use Cases

The NUB process was created to support the temporary reimbursement of innovative hospital methods within the inpatient setting in Germany.

That distinction matters.

Not every medical technology fits this framework. In particular, technologies with a predominantly outpatient use case — including many diagnostic tests and procedures — often lack a realistic route through NUB because the underlying structural requirements are not met.

In these situations, submitting a NUB application is not a harmless parallel exercise. It can divert attention away from the pathways that actually have a chance of success.

The Real Cost Is Strategic Delay

The problem is rarely the administrative burden of the NUB application itself.

The real damage is the delay in addressing the correct reimbursement strategy early enough.

Alternative pathways such as §137e or §137h are often significantly more complex. They require deeper methodological understanding, stronger evidence planning, and a more nuanced assessment of regulatory and reimbursement interdependencies.

They are also less familiar to many advisors.

That combination can create a dangerous dynamic: recommending the pathway that is easiest to explain rather than the one most likely to work.

Honest Guidance Matters More Than Comfortable Advice

Effective market access strategy is not about choosing the pathway that appears most straightforward on paper.

It is about understanding:

whether a pathway is structurally appropriate,
how evidence requirements will evolve over time,
how inpatient and outpatient settings interact,
and where reimbursement decisions are realistically made.

This often means having difficult conversations early.

At athagoras Medtech, we believe clients deserve clear and honest guidance — even when the recommended route is more demanding than initially expected.

We focus on what is likely to work in practice, not simply on what is easiest to recommend.

Understanding the Interaction Between NUB, §137e, and §137h

One of the most common strategic mistakes in German market access is viewing NUB, §137e, and §137h as isolated processes.

In reality, these pathways are closely interconnected. Decisions made early in evidence generation, clinical positioning, and care setting strategy can significantly influence later reimbursement options.

Understanding where these processes complement each other — and where they fundamentally do not — is critical for long-term success in Germany.

Join Our Webinar on German MedTech Market Access Pathways

If you would like to better understand:

where NUB fits,
where it does not,
how §137e and §137h interact with reimbursement strategy,
and what companies should assess before committing resources,

we invite you to join our webinar on German MedTech market access pathways, where we share practical insights from real-world project experience.

Webinar Registration

Register for the webinar here https://us06web.zoom.us/webinar/register/1417763358483/WN_Njs3RcadTcWWVZlHLiWAmg

Missed the webinar? Please feel free to contact athagoras Medtech directly to discuss your specific market access and reimbursement questions with our team.