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Challenges and innovations: patented
      drug pricing and coverage
       A Funder’s Perspective

            February 26, 2013

                 Diane McArthur
    Assistant Deputy Minister, Executive Officer
           Ontario Public Drug Program
Landscape
•   In Fiscal Year 2011/12, the Ontario Public Drug Program’s spending was
    $4.4 billion, or almost 9% of total healthcare spending in Ontario
•   Drug costs are on the rise, and are now nationally the second largest health-
    care expense (public and private) after hospitals (National Health
    Expenditure Trends 1975-2012, CIHI)
•   The cost of innovative therapies continue to increase year over year, leading
    to high costs to public and private insurers
•   Move towards personalized medicine, along with increasing numbers of
    biologics and targeted therapies being introduced to the market at higher
    costs and more frequently with other component costs (e.g. genetic testing)
•   Innovative treatments for rare diseases and chronic diseases often last for
    many years (depending on the patient and their response to therapy),
    therefore the costs can be long-term with limited/minimal outcome
    assessments.
Challenges for drug funding
•   While certain new innovative medications do offer significant improvement,
    many new drugs coming to market offer limited benefits over currently
    available treatments
•   Trials are generally of short duration and designed to meet regulatory
    requirements and often do not address what payors and practitioners want to
    know – what are the real world comparative benefits and harms compared to
    current therapies?
•   Many new products, particularly those for small patient populations, do not
    meet traditional benchmarks of cost-effectiveness. The studies performed are
    often limited in providing information on whether the drugs affect important
    outcomes for patients.
•   Sustainability of public drug funding in the context of overall health care
    spending is a concern for all public payers
•   As one way to address, over the last 7 years in Ontario, there has been a
    shift in the paradigm of funding of branded drugs with the introduction of
    product listing agreements (PLAs)
Product Listing Agreements (PLAs)
What are they?
•   A listing agreement refers to an agreement between a pharmaceutical manufacturer
    and the Ministry/funder
•   Used to support reimbursement of products on the Formulary, Exceptional Access
    Program (EAP), or Cancer Care Ontario’s (CCO’s) New Drug Funding Program
    (NDFP)

Objective of PLAs:
•   Improve patient outcomes by providing patients with improved access to drugs, under
    certain conditions which are informed by the recommendations of the Ministry’s
    expert advisory committee as well as the recommendations from the national review
    bodies (Common Drug Review and pan-Canadian Oncology Drug Review)
•   Improve accountability and risk sharing by supporting funding decisions through a
    negotiated process between the Ministry and brand manufacturers
•   Leverage significant purchasing power to obtain better value for money
Snapshot of Ontario’s product listing agreements between FY 2006/07* - FY 2011/12**

•                             97 New Drugs to Formulary
•                             18 EAP Drugs to Formulary
•                             6 LU Drugs to GB
•                             44 New Drugs to Non-Formulary (EAP, NDFP & FA)
•                             11 Non-Formulary Drugs with New Indications
    Number of Drug Products




                               40
                                                                                                                      34
                               35
                               30
                               25
                               20                                                                                          17
                                                  14                            17           13       14
                               15                              11
                                                                            7
                               10                                                                                               7
                                    7 7 3                  3        6                4            3            4
                                5            1         1                2                1
                                0
                                      FY06/07      FY07/08      FY08/09          FY09/10               FY10/11         FY11/12
                                    New to Formulary            EAP to Formulary                           LU to GB
                                    New to Non-Formulary        EAP to Non-Formulary



* FY 2006/07 = October 1, 2006 – March 31, 2007; ** April 2, 2011- March 20, 2012
- EAP – Exceptional Access Program; NDFP – New Drugs Funding Program; FA – Facilitated Access
What have we learned – successes and challenges
 •   Agreements have made a significant impact on improving access to therapies
 •   Estimating financial exposure of funding decisions has been more accurate
     and overall spending growth is being more tightly managed
 •   Improvement in the value of money spent for drugs reimbursed
 •   Negotiating and monitoring agreements is resource intensive
 •   Opportunities for innovative approaches need to be further explored
 •   Increasing non-transparent pricing makes future negotiations and public
     discussions more difficult
 •   Similar challenges exist across the country and globally


     How do we collaborate to balance innovation with responsible spending
     of taxpayers dollars on drugs in a publicly funded system?
Drug Funding Process                                                                       NOC= Notice of Compliance –
                                                                                           indicating drug is safe and effective
                                                                                           DIN= Drug Identification Number
                                              Manufacturer submits
                                                                                           CDR =Common Drug Review
                                                                                           CDEC = Canadian Drug Expert
     Up to 2 years                                                                         Committee
    Non-transparent                               Health Canada
                                                Issues NOC & DIN                           pCODR = pan-Canadian Oncology
                                                                                           Drug Review
                                                                                           PERC = pCODR Expert Review
                                              Manufacturer submits                         Committee
                                                                                           NCE =New Chemical Entity


  pCODR Products
  (NCE / new combination product /    Common Drug Review products                 Non-CDR products /
   new indication)                    (NCE / new combination product /            non-pCODR products              Up to 1 year
  pERC recommendation to               new indication)                                                            Transparent
  drug plans                          CDEC recommendation to drug plans
  specific to oncology drugs



                   Ontario’s CED reviews Health Canada status, CDR recommendation, pCODR
                              recommendation and conducts Ontario-specific review.                                Up to 2 mths
                                                                                                                  Transparent
                CED provides recommendation to Executive Officer to reimburse (or not) through
                                         publicly funded program


                                     Interim decision made by Executive Officer                                    ~ 1 month



                                                   Negotiations                                                   Open ended


                                      Final decision made by Executive Officer
Collaboration: Pan-Canadian Brand Drug Pricing Alliance

•   Announced by Premiers in August 2010 at a meeting of the Council of
    Federation (COF).
•   Purpose: to examine opportunities to conduct joint provincial / territorial (P/T)
    negotiations for brand name drug products.
•   Goals:
     • To increase access to drug treatment options
     • To improve the consistency of drug listing decisions across the country
     • To capitalize on combined buying power of jurisdictions
     • To achieve consistent pricing and lower drug costs
     • Reduce duplication of negotiations and improve utilization of resources
Pan-Canadian Drug Pricing Alliance: Progress

•   P/Ts agreed to conduct joint negotiations for select drug products to determine if the
    approach was feasible on a broader scale.

•   To date, P/Ts have completed joint negotiations for seven brand name drug products.

•   An additional 13 drug products are under active negotiations

•   Building on the success of the Alliance to date, participating jurisdictions agree that
    moving forward any drug product approved through the national drug review
    processes (e.g. Common Drug Review, pan-Canadian Oncology Drug Review)
    should be considered by the Pan-Canadian Drug Pricing Alliance for a harmonized
    decision on whether negotiations should occur.

•   As the direction for a more consistent approach to pan-Canadian negotiations has
    evolved, the jurisdictions agreed that the development of a permanent and formal
    operating structure should be considered.
Pan-Canadian Pricing Alliance: Challenges encountered

•   Differences in public drug plan structures:
    • Program recipients
    • Legislation, regulations
    • Public drug program policies, processes for payment rules (e.g. mark-
      up, distribution fees, etc.)
    • Formularies – drugs listed and overall structure
•   These differences can lead to different priorities/goals for negotiation
•   Lack of a formal process or governance structure
•   Participation on individual negotiations by Provinces/Territories is not mandatory
•   Resources for conducting multi-jurisdictional negotiations
Future vision

•   First step - the need to develop a more strategic, comprehensive and
    coordinated approach to pharmaceutical management in Canada, including
    both generic and brand name products.
•   Approach must address current pan-Canadian challenges
•   Recognition that we are participants in a global pharmaceutical market
    • international alignment/collaboration both from a regulatory as well as
       public reimbursement perspective
•   The need to balance true innovation with cost
    • For example, do we invest in small incremental improvements in a large
       therapeutic area vs. large improvements in smaller therapeutic areas

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Diane McArthur - Patented Drug Pricing and Coverage

  • 1. Challenges and innovations: patented drug pricing and coverage A Funder’s Perspective February 26, 2013 Diane McArthur Assistant Deputy Minister, Executive Officer Ontario Public Drug Program
  • 2. Landscape • In Fiscal Year 2011/12, the Ontario Public Drug Program’s spending was $4.4 billion, or almost 9% of total healthcare spending in Ontario • Drug costs are on the rise, and are now nationally the second largest health- care expense (public and private) after hospitals (National Health Expenditure Trends 1975-2012, CIHI) • The cost of innovative therapies continue to increase year over year, leading to high costs to public and private insurers • Move towards personalized medicine, along with increasing numbers of biologics and targeted therapies being introduced to the market at higher costs and more frequently with other component costs (e.g. genetic testing) • Innovative treatments for rare diseases and chronic diseases often last for many years (depending on the patient and their response to therapy), therefore the costs can be long-term with limited/minimal outcome assessments.
  • 3. Challenges for drug funding • While certain new innovative medications do offer significant improvement, many new drugs coming to market offer limited benefits over currently available treatments • Trials are generally of short duration and designed to meet regulatory requirements and often do not address what payors and practitioners want to know – what are the real world comparative benefits and harms compared to current therapies? • Many new products, particularly those for small patient populations, do not meet traditional benchmarks of cost-effectiveness. The studies performed are often limited in providing information on whether the drugs affect important outcomes for patients. • Sustainability of public drug funding in the context of overall health care spending is a concern for all public payers • As one way to address, over the last 7 years in Ontario, there has been a shift in the paradigm of funding of branded drugs with the introduction of product listing agreements (PLAs)
  • 4. Product Listing Agreements (PLAs) What are they? • A listing agreement refers to an agreement between a pharmaceutical manufacturer and the Ministry/funder • Used to support reimbursement of products on the Formulary, Exceptional Access Program (EAP), or Cancer Care Ontario’s (CCO’s) New Drug Funding Program (NDFP) Objective of PLAs: • Improve patient outcomes by providing patients with improved access to drugs, under certain conditions which are informed by the recommendations of the Ministry’s expert advisory committee as well as the recommendations from the national review bodies (Common Drug Review and pan-Canadian Oncology Drug Review) • Improve accountability and risk sharing by supporting funding decisions through a negotiated process between the Ministry and brand manufacturers • Leverage significant purchasing power to obtain better value for money
  • 5. Snapshot of Ontario’s product listing agreements between FY 2006/07* - FY 2011/12** • 97 New Drugs to Formulary • 18 EAP Drugs to Formulary • 6 LU Drugs to GB • 44 New Drugs to Non-Formulary (EAP, NDFP & FA) • 11 Non-Formulary Drugs with New Indications Number of Drug Products 40 34 35 30 25 20 17 14 17 13 14 15 11 7 10 7 7 7 3 3 6 4 3 4 5 1 1 2 1 0 FY06/07 FY07/08 FY08/09 FY09/10 FY10/11 FY11/12 New to Formulary EAP to Formulary LU to GB New to Non-Formulary EAP to Non-Formulary * FY 2006/07 = October 1, 2006 – March 31, 2007; ** April 2, 2011- March 20, 2012 - EAP – Exceptional Access Program; NDFP – New Drugs Funding Program; FA – Facilitated Access
  • 6. What have we learned – successes and challenges • Agreements have made a significant impact on improving access to therapies • Estimating financial exposure of funding decisions has been more accurate and overall spending growth is being more tightly managed • Improvement in the value of money spent for drugs reimbursed • Negotiating and monitoring agreements is resource intensive • Opportunities for innovative approaches need to be further explored • Increasing non-transparent pricing makes future negotiations and public discussions more difficult • Similar challenges exist across the country and globally How do we collaborate to balance innovation with responsible spending of taxpayers dollars on drugs in a publicly funded system?
  • 7. Drug Funding Process NOC= Notice of Compliance – indicating drug is safe and effective DIN= Drug Identification Number Manufacturer submits CDR =Common Drug Review CDEC = Canadian Drug Expert Up to 2 years Committee Non-transparent Health Canada Issues NOC & DIN pCODR = pan-Canadian Oncology Drug Review PERC = pCODR Expert Review Manufacturer submits Committee NCE =New Chemical Entity pCODR Products (NCE / new combination product / Common Drug Review products Non-CDR products / new indication) (NCE / new combination product / non-pCODR products Up to 1 year pERC recommendation to new indication) Transparent drug plans CDEC recommendation to drug plans specific to oncology drugs Ontario’s CED reviews Health Canada status, CDR recommendation, pCODR recommendation and conducts Ontario-specific review. Up to 2 mths Transparent CED provides recommendation to Executive Officer to reimburse (or not) through publicly funded program Interim decision made by Executive Officer ~ 1 month Negotiations Open ended Final decision made by Executive Officer
  • 8. Collaboration: Pan-Canadian Brand Drug Pricing Alliance • Announced by Premiers in August 2010 at a meeting of the Council of Federation (COF). • Purpose: to examine opportunities to conduct joint provincial / territorial (P/T) negotiations for brand name drug products. • Goals: • To increase access to drug treatment options • To improve the consistency of drug listing decisions across the country • To capitalize on combined buying power of jurisdictions • To achieve consistent pricing and lower drug costs • Reduce duplication of negotiations and improve utilization of resources
  • 9. Pan-Canadian Drug Pricing Alliance: Progress • P/Ts agreed to conduct joint negotiations for select drug products to determine if the approach was feasible on a broader scale. • To date, P/Ts have completed joint negotiations for seven brand name drug products. • An additional 13 drug products are under active negotiations • Building on the success of the Alliance to date, participating jurisdictions agree that moving forward any drug product approved through the national drug review processes (e.g. Common Drug Review, pan-Canadian Oncology Drug Review) should be considered by the Pan-Canadian Drug Pricing Alliance for a harmonized decision on whether negotiations should occur. • As the direction for a more consistent approach to pan-Canadian negotiations has evolved, the jurisdictions agreed that the development of a permanent and formal operating structure should be considered.
  • 10. Pan-Canadian Pricing Alliance: Challenges encountered • Differences in public drug plan structures: • Program recipients • Legislation, regulations • Public drug program policies, processes for payment rules (e.g. mark- up, distribution fees, etc.) • Formularies – drugs listed and overall structure • These differences can lead to different priorities/goals for negotiation • Lack of a formal process or governance structure • Participation on individual negotiations by Provinces/Territories is not mandatory • Resources for conducting multi-jurisdictional negotiations
  • 11. Future vision • First step - the need to develop a more strategic, comprehensive and coordinated approach to pharmaceutical management in Canada, including both generic and brand name products. • Approach must address current pan-Canadian challenges • Recognition that we are participants in a global pharmaceutical market • international alignment/collaboration both from a regulatory as well as public reimbursement perspective • The need to balance true innovation with cost • For example, do we invest in small incremental improvements in a large therapeutic area vs. large improvements in smaller therapeutic areas