From Reference Tool to Operating Model: A Roadmap for China’s C-List
By Kelly Ke, Ruiyun Wanyan, and Ken Wong
I. Background
The launch of the Commercial Innovative Drug List (C-List) has created a distinct payment pathway for high-value innovative therapies outside the National Reimbursement Drug List (NRDL), while at the institutional level further clarifying the respective roles of social medical insurance and commercial health insurance. More broadly, this move signals that China’s multi-tier healthcare security framework is shifting from policy experimentation toward the construction of operational mechanisms.
At the policy level, supporting measures have been put in place to establish the basic conditions for the clinical use of C-List drugs. By allowing direct listing on provincial procurement platforms and by granting physicians greater prescribing autonomy within the public hospital system, the C-List has established a practical foundation for implementation in real-world care settings. At the same time, its introduction has begun to steer commercial insurers toward a more systematic use of evidence-based criteria in drug selection, while providing an institutional anchor for earlier and more structured engagement between insurers and pharmaceutical companies.
The publication of a list, however, should not be conflated with the establishment of a payment system. In December 2025, the C-List and the updated NRDL were released simultaneously as a “dual-list” framework—an arrangement with clear institutional symbolism, but one that also brings a more practical question to the forefront: within commercial health insurance, particularly city-level customized products such as Huiminbao, how should the C-List be effectively taken up and sustained over time.
Although the inaugural C-List includes only a limited number of medicines, their characteristics are highly concentrated: high clinical value, high cost, and significant uncertainty. Such therapies have long struggled to gain coverage through social medical insurance, which is designed primarily to ensure basic protection. Yet if they are incorporated directly into commercial insurance without adequate actuarial discipline and institutional design, they risk amplifying claims volatility—placing tangible strain on Huiminbao schemes, whose mandate is inclusiveness and whose risk pools remain relatively constrained.
As commercial health insurance—and Huiminbao in particular—shifts from a phase of rapid expansion toward operational stabilization, the establishment of the C-List represents only a first step. Its real effectiveness will depend on whether it can be translated into executable product structures, credible risk-sharing arrangements, and coherent governance mechanisms. Absent these foundations, the C-List may remain a policy reference rather than evolve into a stable access pathway supported by commercial insurance.
Against this backdrop, this article draws on recent policy developments and international experience from the United States, Singapore, Canada, and the United Kingdom to examine, across four dimensions—benefit design, inter-departmental coordination, risk sharing, and negotiation mechanisms—the key pathways for achieving the sustainable integration of the C-List within China’s commercial insurance system.
