No, if you read the orbis site, they do not have to file with every member.
For cost neutral, you are wrong on both counts. First cost neutral also takes into account improvement in care (it’s a measurement of how it effects MHRA funding dedication in relation to patient improvement), and on your second point, even if the cost impact was like for like, you are wrong, as there is no SOC for rGBM.
I think you know all this.