CLHIA-ACCAP

CLHIA Report on Prescription Drug Policy

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14 The Canadian life and health insurance industry believes that it is important that a mechanism be developed to review therapeutic price levels on a periodic basis to ensure that the price ceilings reflect the current market reality. There are two situations, in particular, where we believe that it would be appropriate to reduce the therapeutic class price. The first situation is where the indications, or off-label use, for a particular drug have expanded to the point where the market they serve is significantly greater than for what the drug's price was calibrated to originally. The second situation is where there have been many new "me-too" type competitors in a therapeutic class. The industry believes that in these situations, it is reasonable that the therapeutic class price cap be re-evaluated and lowered. THEREFORE, THE CLHIA RECOMMENDS THAT: • THERAPEUTIC CLASS PRICE LEVELS BE REVIEWED PERIODICALLY (E.G., EVERY 5 YEARS) OR IF INCREASED INDICATIONS RESULT IN A MATERIAL CHANGE IN VOLUME (E.G., A 100 PER CENT INCREASE) TO ENSURE THEY REFLECT ANY MATERIAL CHANGES IN THE MARKET SINCE THE PRIOR REVIEW. b.1.4 Introducing a Formal Institutional Role for Private Insurers The PMPRB Board of Directors currently consists of not more than five members who are appointed by the Governor-in-Council. The current make-up of the PMPRB consists of individuals with backgrounds in medicine, public policy, pharmacy, law and education (e.g., university professors). As we outlined above, the PMPRB pricing is particularly relevant for private payers in Canada, but not as much for public payers. We believe that there is a clear benefit to ensuring a meaningful private payer representation on the PMPRB Board going forward. This would help ensure that the Board's decisions and the PMPRB's overall strategy are clearly informed by the consumers whose interests they are mandated to protect.

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