CLHIA commends PMPRB on proposed changes to the price review process for new drugs (Section C.11)

Date de parution : 01/11/2016
Personne(s)-ressource(s) : Joan Weir

January 11, 2016

Guillaume Couillard
Director, Board Secretariat, Communications and Strategic Planning
Patented Medicine Prices Review Board
Ottawa ON

Re: PMPRB Initiative #2 - List Price Relative to MAPP Verification

Dear Mr. Couillard,

On behalf of the Canadian life and health insurance industry, I am providing our comments regarding your proposed changes to section C11 that will require patentees to ensure their domestic list prices for new drugs are below the Maximum Average Potential Price.

The CLHIA is a voluntary trade association with member companies that account for 99 percent of Canada's life and health insurance business. In Canada, at the end of 2014, the life and health insurance industry provided approximately 22 million Canadians with prescription drug benefit coverage and made payments of about $10.2 billion for prescription drugs.

As you are aware, in most cases, private payers reimburse list price for prescription drug claims. The recent increasing ratio of domestic Block 5 prices to N-ATP from 1.059 to 1.079 since 2010 is a concern to private payers and ultimately results in higher costs for those Canadians covered by private insurance or paying out of pocket. As such we fully support the PMPRB's proposal to require patentees to ensure that domestic list prices for new drugs are below the MAPP on a go forward basis. We also applaud the PMPRB for taking proactive steps to adjust your guidelines in response to changing market practices.

Thank you for bringing forward this important initiative. We would be pleased to discuss this at your convenience or provide any other information that you would find helpful. Please contact Joan Weir, Director- Health and Dental at (416)-359-2003 or


Original signed by

Stephen Frank
Vice President, Policy Development and Health