When international MedTech companies prepare their market access strategy in France, most discussions focus on clinical evidence, reimbursement pathways, pricing, and health technology assessment.
However, one critical factor is frequently overlooked: procedure coding in France.
In reality, this procedure can significantly influence hospital adoption, physician engagement, activity reporting, reimbursement discussions, and ultimately the commercial success of a technology.
Therefore, companies that ignore procedure coding in France may face unexpected barriers even when clinical value is well established.
A recent evolution that changes the landscape of procedure coding in France
A recent development has largely gone unnoticed by many MedTech companies.
Since February 2026, manufacturers can directly request the evaluation and creation of a procedure code (CCAM) through the Haute Autorité de Santé (HAS).
Previously, these requests were typically initiated by:
- academic societies
- clinical expert groups
- or HAS itself during reimbursement evaluations
Today, MedTech companies have a more direct opportunity to contribute to the evolution of procedure coding in France.
The HAS document entitled “Evaluation of Professional Procedures – Submission of an Application via the EVActe Platform” formally describes this process.
Consequently, procedure coding in France has become a strategic lever that companies can actively incorporate into their market access planning.
Source : HAS methodological guide – Submission of an Application for the Evaluation of a Professional Healthcare Procedure. Feb 02, 2026
https://www.has-sante.fr/jcms/c_1714581/fr/deposer-un-dossier-d-evaluation-d-acte-professionnel
Why procedure coding in France matters more than most companies think
This is not an administrative detail.
It is one of the mechanisms through which hospital activity becomes visible, measurable, and economically recognized.
Specifically, CCAM codes are used to:
- describe medical procedures performed in hospitals
- support PMSI activity reporting
- contribute to hospital funding through DRG tariffs (GHS)
- document the use of innovative techniques
Behind each procedure code lies an economic logic.
If a procedure is not coded correctly, several consequences may emerge:
- activity becomes less visible
- hospital funding may not reflect clinical reality
- physician remuneration may not reflect procedural complexity
- adoption becomes economically less attractive
As a result, a clinically valuable innovation may struggle to achieve widespread adoption.
This is one reason why procedure coding in France should be considered early in the commercialization strategy.
Source : Methodological guide by HAS: Procedure for the selection of Requests for the Assessment of Professional Healthcare Procedures
https://www.has-sante.fr/jcms/c_2816204/fr/procedure-de-selection-des-demandes-d-evaluation-d-actes-professionnels
Article
The hidden risk in France by assimilation
One recurring issue observed in real-life MedTech projects is coding by assimilation.
When no dedicated procedure code exists, hospitals frequently use existing codes that only partially reflect the actual procedure being performed.
At first glance, this may appear to be a practical solution.
However, several challenges often emerge:
- increased audit exposure for hospitals
- inconsistent activity reporting
- uncertainty among coding teams
- hesitation from administrators
- reluctance from physicians to adopt the technology
Ultimately, coding by assimilation can become a significant obstacle to market penetration.
Yet many MedTech companies discover this challenge only after commercialization has already begun.
This is why procedure coding in France should be assessed before market launch rather than after.
Strategic Perspective: this is part of market access
A common misconception is that procedure coding should be addressed after reimbursement.
In practice, the opposite is often true.
Procedure coding in France directly influences:
- hospital economics
- physician incentives
- budget impact assessments
- adoption dynamics
- future reimbursement discussions
Therefore, coding strategy should be considered an integral component of market access planning.
Just like reimbursement pathways, this procedure in France helps determine how a technology will be integrated into routine clinical practice.
Field Perspective: clinical value is not always enough
Many innovative technologies demonstrate clear clinical benefits.
However, adoption depends on more than efficacy.
In real hospital environments, decision makers also consider:
- coding clarity
- administrative simplicity
- financial sustainability
- organizational impact
For instance, hospitals may hesitate to expand the use of a technology if activity reporting remains uncertain or if procedural complexity is not adequately recognized.
This is where this procedure often becomes the bridge between clinical value and economic reality.
Executive Perspective: think beyond the device
For MedTech executives, the strategic question should not be limited to:
“How will the device be reimbursed?”
Instead, a broader question should be asked:
“How will the procedure be recognized, coded, funded, and adopted?”
This distinction is critical.
Because reimbursement may support access to the device.
But this procedure coding often determines whether routine use becomes economically sustainable.
Strategic Implications
Procedure coding in France should not be viewed as a technical administrative matter.
Instead, it should be viewed as a strategic adoption lever.
Companies that address procedure coding in France early are often better positioned to:
- accelerate hospital adoption
- reduce implementation barriers
- improve activity visibility
- support future reimbursement discussions
- strengthen long-term commercial success
Strategic Takeaway
In France, market access is not only about the device.
It is also about the procedure.
Understanding this procedure coding and how a procedure is recognized, coded, and valued can have a major influence on adoption dynamics and commercial outcomes.
For many international MedTech companies, understanding procedure coding in France may be just as important as understanding reimbursement itself.
This remains one of the most overlooked — yet most powerful — levers in a successful go-to-market strategy.
Related articles: https://www.caredis.fr/medtech-market-entry-in-france/; https://www.caredis.fr/medtech-reimbursement-in-france-right-pathway/, https://www.caredis.fr/medtech-reimbursement-in-france/
