OBJECTIVES: The implementation of health technologies is an essential step to guarantee patients’ timely access after an incorporation decision. The success of the incorporation requires health managers to consider implementation aspects alongside the assessment process as part of a technology life cycle. To understand which actions proceed with the incorporation, we compared the legislation on the implementation of health technologies in three countries.

METHODS: We conducted an exploratory comparative study based on the legislation, data from Health Technology Assessment (HTA) and governmental bodies from Brazil, Argentina and the United Kingdom (UK).

RESULTS: The health systems of the three countries are more or less fragmented and mixed, besides having diverse solutions for financing – for instance for antineoplastics, rare disease and high-cost drugs -, which leads to different HTA and implementation processes under a single location. Unlike Brazil's, the Argentinian system does not require every technology to go through an HTA process. There are different access pathways, through social security or union-related systems. In the UK, the health system negotiates the purchase and reallocates its budget, following the decision of National Institute for Health and Care Excellence (NICE). There is a general 90-day deadline for technologies to be available for patients, half the time settled in Brazil, where health managers from federal, state, and municipal level have shared responsibility for the implementation. While the implementation processes are country-specific, countries often have common issues.

CONCLUSIONS: Maintaining up-to-date, adaptable norms might help to keep pace with the rapid technological advancements in healthcare. The existence of clear regulations is crucial to ensure patients' access and the health system’s sustainability while fostering innovation. Even clear access deadlines might be difficult to comply with due to the health system’s challenges. The exchange of best practices can contribute to finding solutions to common implementation issues.