CLHIA Submission on Reducing Regulatory Burden for Private Label ProductsRelease Date: 11/28/2018 Staff Reference: Joan Weir
November 27, 2018
Drugs and Devices Division
Ministry of Health and Long-Term Care
80 Grosvenor Street, 9th Floor
Hepburn Block, Queen’s Park
Re: Reducing Regulatory Burden for Private Label Products, Proposal Number: 18-HLTC027
On behalf of the Canadian life and health insurance industry, I would like to thank you for the opportunity to provide input from the private drug plan perspective which accounts for 40% of the spending on prescription drugs in Ontario in 2017.
The CLHIA is a voluntary trade association with member companies that account for 99 percent of Canada's life and health insurance business. In Ontario, at the end of 2017, the life and health insurance industry provided more than 9.8 million Ontarians with private supplementary drug insurance and made payments of about $5 billion on prescription drugs.
As we understand it, the proposed regulatory amendments would repeal legislation made under the Ontario Drug Benefit Act as well as legislation in the Drug Interchangeability and Dispensing Fee Act, allowing private label products to be listed on the Ontario Drug Benefit Program and designated as interchangeable with other products. These are significant and complex changes and a concern for private payers (insurers) if this unintentionally increases costs, which is unclear at this time.
Given the complexity of the issue, we recommend proceeding on a trial basis to ensure there are not any unintended consequences. The suggestion of applying a limit to the percentage of private label products that a wholesaler and/or pharmacy affiliated with the private label company can purchase and sell is one way to do this. at least at the outset. This would allow time to assess the impact as well as to manage the potential disruption in the marketplace, including the possibility of price fluctuation and manipulation.
Thank you for your attention to this important issue. We would be pleased to discuss this with your officials at their convenience or provide any other information that you would find helpful. Please contact me directly at (416)-359-2003 or firstname.lastname@example.org.
Original signed by:
Director, Health and Disability Policy