Neighbourhood Pharmacy Association of Canada’s four key recommendations for new PMPRB guidelines

The Patented Medicine Prices Review Board (PMPRB) has taken a step back from its planned timeline for pricing changes. The guidelines were to be implemented on Jan. 1, 2024, but the date was pushed back.It also allowed stakeholders to participate in policy round tables early in December and invited written submissions in response to a scoping paper on its new guidelines. The Neighbourhood Pharmacy Association of Canada took the opportunity to send a six-page submission that covered four main recommendations around the new guidelines. It said the increased opportunity for feedback was a welcome change. “We applaud the Board for recognizing the need for more meaningful consultation with a broader range of stakeholders as an important theme for consideration in guideline development,” it reads. Read: New PMPRB guidelines delayed, yet againThe main change is switching the list of reference countries to Australia, Belgium, Japan, Netherlands, Norway, Spain, the U.K., Sweden, France and Italy. It drops the formerly included U.S. and Switzerland—the only countries with higher prices than Canada in the Organisation for Economic Co-operation and Development (OECD). An impact analysis from October by Neighbourhood Pharmacy estimated that those proposed changes would pull $113 million a year in markup funding from the pharmacy sector. The association is asking that new guidelines guarantee that in-market medications—the ones that exist or are reviewed before the final guidelines are published—are not reassessed against the new PMPRB11 basket of comparator countries. It also asked the PMPRB not to use the “lowest of” price tests for medications for rare diseases. That way, the specialized handling, administration and monitoring, additional clinical services, capital investment and carrying costs these medications require would be taken into account, as well as the complex, high-stakes needs of patients. “Pharmacies are using markups to fill significant gaps in care for complex and vulnerable patients, such as those taking drugs for rare diseases,” the statement says.Read: Director of PMPRB resigns same week as colleague steps downOverall, it says it is crucial that the PMPRB understands how pharmacies are funded and the impact pricing reforms would have on the pharmacy sector unless there are reinvestments from governments to offset their impacts.Funding for Canadian pharmacies comes almost entirely through dispensing fees and mark-ups that are tied to list prices, the association explains. Those dispensing fees and mark-up percentages are negotiated provincially. Federal changes to list prices would have “profound consequences on pharmacy’s ability to sustain the delivery of medications, care, and services,” the association said. Read: New medicines in Canada come with high treatment costs: PMPRB reportIt pointed to several changes that could add up here. In addition to the impacts of PMPRB changes, the latest pan-Canadian Pharmaceutical Alliance generic pricing framework is estimated to remove $23.4 million from the pharmacy sector over the next five years, transition policies around biosimilars are reducing pharmacy funding by approximately $68 million a year, and a single-payer national pharmacare system would remove another $1 billion.At the same time, operating costs have risen thanks to issues including inflation and increased labour costs. It encourages the PMPRB to use a “whole-of-government” approach, which considers how policies are interconnected and the unintended consequences that might come from decisions. “Our comments are intended to help the PMPRB minimize the negative downstream impacts that patented medicine pricing policy changes will have on Canadians’ access to medication and care through their community pharmacies,” Sandra Hanna, the association’s CEO, said in the submission. Read: Diabetes drugs’ market share almost doubled in the past decade: PMPRB

Neighbourhood Pharmacy Association of Canada’s four key recommendations for new PMPRB guidelines

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