how changes to the pmprb could affect patients' access to drugs

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1 How Proposed Changes to the Patented Medicine Prices Review Board Could Affect Patients’ Access to Drugs September 28, 2017

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Page 1: How Changes to the PMPRB Could Affect Patients' Access to Drugs

1

How Proposed Changes to the Patented Medicine Prices Review Board Could Affect Patients’ Access to Drugs

September 28, 2017

Page 2: How Changes to the PMPRB Could Affect Patients' Access to Drugs

2

Today’s participants

Bill Dempster CEO – 3Sixty Public Affairs

Moderator

Panelist

Neil Palmer Founder & Principal Consultant –

PDCI Market Access

Panelist

Wayne Critchley Senior Associate –

Global Public Affairs

Panelist

John-Peter Bradford CEO – Life Saving Therapies Network

Page 3: How Changes to the PMPRB Could Affect Patients' Access to Drugs

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1. Introduction to PMPRB / proposed changes

2. Panellists’ perspectives

3. Discussion

What we’ll discuss

Page 4: How Changes to the PMPRB Could Affect Patients' Access to Drugs

What is the PMPRB?

• Quasi-judicial federal agency

• Reports to the federal health minister

• Twofold mandate:

regulates prices and reports on trends

• Regulates prices of patented drugs based on:

o independent assessment of treatment’s therapeutic value vs.

alternatives

o prices for same medications in other countries, which currently

include France, Germany, Italy, Sweden, Switzerland, the United

Kingdom and the United States (i.e., the basket of reference

countries or PMRB7)

4

Page 5: How Changes to the PMPRB Could Affect Patients' Access to Drugs

Proposed changes to the PMPRB

• Patented Medicines Regulations key

changes:

o Addition of economic factors for PMPRB

excessive price determinations:

- Pharmacoeconomic analysis

- Size of market

- Canadian GDP

o Updating the list of comparator countries

- Remove U.S. and Switzerland

- Add Australia, Belgium, Norway, Japan,

Netherlands, South Korea & Spain

o Requirements to report rebates to the

PMPRB

5

Source: PMPRB’s strategic plan

Page 6: How Changes to the PMPRB Could Affect Patients' Access to Drugs

Evolution and key dates

May 16, 2017

Consultation

document released

– opportunity to

provide written

input until

Jun. 28, 2017

Fall 2017

Draft regulations

will be published in

Canada Gazette I

along with

regulatory impact

analysis statement

(RIAS)

2018

Review of

comments/input on

draft regulations

and development of

final regulations to

be published in

Canada Gazette II

75-day

consultation period

End of 2018

Health Canada

aiming to conclude

the regulatory

amendment process

by this time

Strategic Plan

Dec. 2015

PMPRB

Guidelines

Jun. 2016

Nov-Dec 2017

GUIDELINES

discussions

and consultations

to occur at the

same time

NEW

Health

Minister

Ginette

Petitpas Taylor

6

Page 7: How Changes to the PMPRB Could Affect Patients' Access to Drugs

PMPRB REFORM:

IMPACT FOR PATIENTS?

September 28, 2017

Wayne Critchley

Page 8: How Changes to the PMPRB Could Affect Patients' Access to Drugs

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Minister of Health: Prime Minister’s Mandate Letter

“…Improve access to necessary prescription

medications”

• “joining with provincial and territorial

governments to buy drugs in bulk”

• “reducing the cost Canadian governments

pay for these drugs”

• “making them more affordable for

Canadians”

• “exploring the need for a national formulary”

Page 9: How Changes to the PMPRB Could Affect Patients' Access to Drugs

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Health minister vows to

save Canadians

'billions' on drug prices

January, 2017

… will bring prices in

“line to what we are

seeing in countries like

New Zealand”

Page 10: How Changes to the PMPRB Could Affect Patients' Access to Drugs

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PMPRB Reform –

Statements from Former Minister Philpott

PMRPB reform is a precursor to any potential

Pharmacare plan: we don’t want to “lock in extremely

high-price medications” – April 13, 2016

May 16, 2017 Speech:

• Announced proposed PMPRB reforms and

consultation process

• Canada has the 3rd highest drug prices & the 2nd

highest per capita pharmaceutical spending in the

OECD

• Proposed changes would lower prices in range of

25%

• Would bring annual savings of $3.5 billion

Other announcements in May 16 speech:

• Work with provinces on a “National Formulary”

• System alignment – Health Canada and CADTH

• Promised announcement on pCPA

Page 11: How Changes to the PMPRB Could Affect Patients' Access to Drugs

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Government's Regulatory Proposals –

Some Potential Impacts

• Duplication of HTA reviews

• 25% reduction in overall list prices

• Impact on pCPA and PLAs????

• Lower prices for private insurers

• Impact on government innovation policies and biopharmaceutical investment

• Delayed launch of innovative drugs in Canada

Page 12: How Changes to the PMPRB Could Affect Patients' Access to Drugs

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SOME KEY ISSUES

CONSULTATIONS

• No multi-stakeholder consultations

• Written submissions only

• Limited meetings

LIMITED LINK TO PUBLIC PAYERS

• PMPRB has no engagement in HC/CADTH/pCPA processes

• Potential for conflict between agencies

SPECIAL ISSUES FOR PATIENT

GROUPS

• Potential delays in access

• New barriers for drugs for rare diseases

• PMPRB has no patient input mechanisms

Page 13: How Changes to the PMPRB Could Affect Patients' Access to Drugs

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Contact:

Wayne Critchley

Senior Associate, HLS

Tel: 613-783-3449

[email protected]

Global Public Affairs: Contact Information

Ottawa

50 O’Connor Street, Suite 901

Ottawa, ON K1P 6L2

Telephone: 1 (613) 782-2336

Toronto

595 Bay Street, Suite 401

Toronto, ON M5G 2C2

Telephone: 1 (416) 597-3485

Edmonton

10060 Jasper Avenue, Suite

2020

Edmonton, AB T5J 3R8

Telephone: 1 (780) 665-4946

Calgary

633-6th Avenue SW, Suite

1000

Calgary, AB T2P 2Y5

Telephone: 1 (403) 264-3800

Vancouver

355 Burrard Street, Suite

570

Vancouver, BC V6C 2G8

Telephone: 1 (604) 362-2522

Page 14: How Changes to the PMPRB Could Affect Patients' Access to Drugs

14 September 2017

How Proposed Changes to PMPRB Could Affect Patient Access to Drugs

September 2017

Page 15: How Changes to the PMPRB Could Affect Patients' Access to Drugs

Mechanisms for Price Setting / Reimbursement

15 September 2017

Canada France Germany Italy Sweden Switz. UK USA

Additional benefit

(level of

improvement)

Clinical Effectiveness

Internal referencing

(cost comparisons to

similar drugs,

generics, biosimilars)

*

External referencing

(international price

comparisons) *

Cost effectiveness

(e.g., $/QALY)

Affordability

(budget impact) *

Risk Sharing

(product listing

agreements) * *

Regional decision

making *

Tiered Formularies

Page 16: How Changes to the PMPRB Could Affect Patients' Access to Drugs

PMPRB: Less Reliance on International Prices?

• PMPRB: “Given that it is standard industry practice worldwide to insist that public prices not reflect discounts and rebates, should the PMPRB generally place less weight on international public list prices when determining the non-excessive price ceiling for a drug?”

• International price referencing began in Canada in 1987 (PMPRB C-22 amendments to Patent Act)

• Listing agreements and patient access schemes make international price comparisons challenging

– but these exist because of international price referencing

– transparent pricing would result in a downward spiral of prices

– even if prices are identical at launch, prices will inevitably move apart because of exchange rates

16 September 2017

Page 17: How Changes to the PMPRB Could Affect Patients' Access to Drugs

Health Canada: Criteria for selecting proposed reference countries

Three main criteria have been used to select the countries:

1. Consumer protection: whether the country has national pricing containment measures in place to protect consumers from high drug prices;

2. Economic Standing: whether the country has a similar economic standing to Canada, as measured by GDP per capita; and

3. Pharmaceutical market characteristics: whether the country has similar market characteristics to Canada, such as population, consumption, revenues and market entry of new products.

17 September 2017

Proposed Countries

Source: Health Canada “Protecting Canadians from Excessive Drug Prices: Consulting on Proposed Amendments to the Patented Medicines Regulations”, Ottawa May 2017

Page 18: How Changes to the PMPRB Could Affect Patients' Access to Drugs

What is the impact of International Reference Pricing?

• Is there evidence that lower prices delay product introduction in “low price” countries?

18 September 2017

Page 19: How Changes to the PMPRB Could Affect Patients' Access to Drugs

Health Canada / PMPRB: Lower prices have no effect on Access to Medicines

19 September 2017

Page 20: How Changes to the PMPRB Could Affect Patients' Access to Drugs

But for New Medicines…

Foreign Prices are similar or higher than Canada

20 September 2017

New med prices the same or higher in most

other countries including Sweden & UK

Page 21: How Changes to the PMPRB Could Affect Patients' Access to Drugs

Launch Sequencing is well established…

21 September 2017

Page 22: How Changes to the PMPRB Could Affect Patients' Access to Drugs

Sample Launch Sequence Analysis

22 September 2017

Page 23: How Changes to the PMPRB Could Affect Patients' Access to Drugs

Reservation Prices – At what point will products not be available?

• Reservation (or reserve) price is a term referring to a limit on the price of a good or a service.

– On the demand side, it is the highest price that a buyer is willing to pay;

– On the supply side, it is the lowest price at which a seller is willing to sell a good or service.

23 September 2017

Page 24: How Changes to the PMPRB Could Affect Patients' Access to Drugs

International (External) Reference Pricing

24 September 2017

Pharmaceutical Reference Pricing in the U.S. Delusion or a soon-to-be Reality? April 2016 Ilkka Anhava Ling Chen Huiyan

Jin Emil Nedev David Spellberg.

Page 25: How Changes to the PMPRB Could Affect Patients' Access to Drugs

Biography

25 September 2017

W. Neil Palmer

President & Principal Consultant PDCI Market Access Inc

[email protected] www.pdci.ca

Neil Palmer President and Principal Consultant of PDCI Market Access Inc. (PDCI) a leading pricing and reimbursement consultancy founded in 1996. He leads a senior team of market access professionals with pricing & reimbursement engagements covering Canada, Europe, and the United States. Prior to PDCI, Neil worked with the Canadian Patented Medicine Prices Review Board (PMPRB) where his responsibilities included policy development, overseeing the price review of patented medicines and conducting economic research. Prior to the PMPRB, he worked with the Health Division of Statistics Canada where he was responsible for economic and statistical analysis of health care costs and utilization. Neil also worked with RTI Health Solutions (Research Triangle Park, North Carolina) where he served as global vice president for pricing and reimbursement. After completing his studies at the University of Western Ontario, Neil began his career in Montreal with the research group of the Kellogg Centre for Advanced Studies in Primary Care. He has written extensively on pharmaceutical pricing and reimbursement issues and is a frequent speaker at conferences in North America and Europe. In January 2015, Neil was appointed Adjunct Assistant Professor at the University of Southern California School of Pharmacy graduate program in Health Care Decision Analysis where he lectures on health technology assessment, pricing and market access from a global perspective.

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Discussion

CONSULTATIONS

• No multi-stakeholder consultations

• Written submissions only

• Limited meetings

LIMITED LINK TO PUBLIC PAYERS

• PMPRB has no engagement in HC/CADTH/pCPA processes

• Potential for conflict between agencies

SPECIAL ISSUES FOR PATIENT GROUPS

• Potential delays in access

• New barriers for drugs for rare diseases

• PMPRB has no patient input mechanisms

Page 27: How Changes to the PMPRB Could Affect Patients' Access to Drugs

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Canadian Cancer Survivor Network Contact Info

Canadian Cancer Survivor Network 1750 Courtwood Crescent, Suite 210 Ottawa, ON K2C 2B5

Telephone: 613-898-1871

E-mail [email protected] or [email protected]

Website www.survivornet.ca

Twitter: @survivornetca

Facebook: www.facebook.com/CanadianSurvivorNet

Pinterest: http://pinterest.com/survivornetwork/