NHSA Consults on 2025 Dual-List Adjustment Work Plan for NRDL and Commercial Drug List
On the afternoon of June 16, 2025, the National Healthcare Security Administration (NHSA) held a consultation meeting to gather feedback on the draft 2025 Work Plan for the Adjustment of the National Drug Catalogs—covering Basic Medical Insurance, Maternity Insurance, Work Injury Insurance, and the Commercial Health Insurance Innovative Drug List.
The meeting aimed to strengthen the role of industry associations in facilitating dialogue between government and enterprises and to pave the way for broader public consultation. Seven organizations—including the Chinese Medical Association and Chinese Pharmaceutical Association—were invited to participate.
This meeting followed the June 9 release of the Opinions on Further Safeguarding and Improving People's Livelihoods and Addressing the Public’s Most Pressing Needs, jointly issued by the General Office of the CPC Central Committee and the General Office of the State Council. The document called for enhancing the adjustment mechanism for the BMI drug list and introducing a dedicated catalog for innovative medicines under commercial health insurance to better meet the population’s diverse coverage needs.
It is worth noting that the 'dual-list' adjustment work plan is still in the public consultation stage. Subsequent consultations may focus on gathering input from the insurance industry.
Key Signals from the Meeting
1. Toward One National Commercial Health Insurance Innovative Drug List
Both the State Council's June 9 directive and NHSA’s consultation materials notably use the term "Commercial Health Insurance Innovative Drug List” in place of the previously proposed “Category C Drug List.”
The change in wording may not be coincidental.
Earlier in March, the Insurance Association of China (IAC)—a key self-regulatory body for commercial insurers—released a draft Commercial Health Insurance Drug Formulary – Tier A (“A-List”), ahead of the anticipated September release of the C-List. This move marked a parallel effort to create a unified drug framework for commercial products such as Huiminbao, Million Medical, and specialty drug plans.
The consistent use of "Commercial Health Insurance Innovative Drug List" across top-level policy documents and NHSA’s consultation suggests a possible pivot toward unifying the governance and formulation of the C-List and commercial drug lists—with NHSA assuming a central role.
As discussed in our Masterclass, I’ve raised the possibility that the C-List and commercial drug catalogs could eventually merge. This latest round of policy language and consultation signals suggests that such convergence may be happening sooner than expected.
2. Commercial List to Be Promoted as Reference, Not Requirement, Across Multi-Tiered Coverage Models
As discussed in our Masterclass, compared to the NRDL, the biggest risks for commercial pathways, such as the commercial innovative drug list, lie in financing and real-world uptake.
Unlike global analogs such as Singapore’s centrally managed Cancer Drug List (CDL)—where Integrated Shield Plans (including private top-ups) may only reimburse outpatient cancer treatments listed on the CDL—China’s proposed Commercial Innovative Drug List will serve as a reference, not a mandate. This was further clarified by the NHSA during the June 16 consultation.
Under this “reference use” model, the catalog’s impact will depend heavily on its ability to gain traction—through integration into commercial insurance products, adoption by mutual aid schemes, consumer willingness to pay, and hospital-level prescribing behavior.
Our Masterclass modules 1 and 2, along with the companion live Q&A, have taken a deep dive into these implementation challenges within the Chinese context—highlighting existing policy proposals as well as additional opportunities for targeted engagement to strengthen the commercial catalog’s traction.
This is also where China diverges significantly from most developed markets, where access strategies typically center on pricing and satisfying local HTA conditions. In contrast, China’s reimbursement and healthcare delivery infrastructure is still in flux—and evolving quickly. What further sets China apart is the government’s deliberate effort to coordinate reforms across the “three medicals” (medicine, medical insurance, and medical care), creating a highly dynamic policy environment.
Given this context, global firms must adopt a broader, more integrated view of market access when shaping commercial strategies for China. At NRDL+, we will continue tracking these developments through our Access360 program to help companies navigate and respond to these shifting dynamics more effectively.
Critical Questions for Manufacturers: Preparing for China’s Dual-List Adjustment Mechanism
The launch of the Dual-List Adjustment mechanism marks a pivotal shift in China’s healthcare system, signaling the formal integration of commercial health insurance with its social insurance program. This development is poised to reshape the access landscape and carries significant implications for patients, payers, providers—and manufacturers navigating pricing, product positioning, and policy alignment.
To help manufacturers navigate this shifting landscape, our upcoming Masterclass Live Panels will dive into critical questions shaping access strategy. A few we’ll explore during the live discussions include, but are not limited to:
- How can the access framework be redefined to unlock China’s revenue potential while maintaining global pricing discipline amid shifting reimbursement dynamics and evolving payer priorities?
- Near-term adjustments to mitigate the impact of potential Huiminbao delisting under the dual-list adjustment reform
- Longer-term implications of an integrated commercial and social insurance system for pricing and reimbursement strategy
- Lifecycle planning strategies to optimize product positioning across the NRDL and emerging commercial pathways
- How NHSA defines “innovation” and its role in commercial innovative drug list inclusion
- How value propositions and evidence generation should evolve for new access channels
- Global analogs that can inform China’s national commercial innovative drug list pilot and highlight opportunities for targeted policy engagement
- What are the key considerations commercial insurers weigh when deciding whether to incorporate the Commercial Innovative Drug List into their product design?
- The current state of payment innovation in China—and which models show real potential
- Pathways for collaboration between life sciences companies and commercial insurers
Join Our Masterclass Expert Panels
If the Dual-List Adjustment workplan is confirmed for 2025, we’ll move the Strategy Panel to the first live session—so manufacturers can get timely insights to guide their listing decisions.
Haven’t signed up yet? There’s still time. Enroll in the Masterclass now to join the Live Panels and enjoy a free trial of Access360—a program that fuses policy intelligence with executive learning to help you connect the dots across policy, strategy, and execution amid China’s shifting healthcare landscape.
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References:
1. 2025年医保目录迎颠覆性变革！哪些药物将入选首批商保目录？, MedTrend医趋势, 2025-6-19, https://www.phirda.com/artilce_39212.html?module=trackingCodeGenerator
- 中共中央办公厅 国务院办公厅关于进一步保障和改善民生 着力解决群众急难愁盼的意见 (The General Office of the Communist Party of China Central Committee and the General Office of the State Council: Opinions on Further Safeguarding and Improving People's Livelihoods and Addressing the Public’s Most Pressing Needs), Xinhua News Agency, 6-9-25, https://www.gov.cn/zhengce/202506/content_7027015.htm?ref=nrdlplus.com
