Brief submitted to:
House of Commons Standing Committee on Health
Bill C-64, An Act Respecting Pharmacare
Submitted by:
Ms. Connie Côté, CEO
Health Charities Coalition of Canada
Ottawa
May 23, 2024
Introduction
The Health Charities Coalition of Canada (HCCC) is pleased to make a submission to the Standing Committee on Health regarding Bill C-64, An Act respecting pharmacare. Health charities have a mission to improve the health of people affected by disease. We represent Canadians with a wide range of medical conditions, many of whom depend on prescription drugs to live longer, better and healthier lives. The aim of providing accessible, affordable and appropriate drug therapies to Canadians is laudable. Bill C-64, an Act respecting pharmacare, has been long awaited by our community and our intent is to provide input that will help to strengthen and advance the implementation of Canada’s first national pharmacare program.
Information contained herein is a summary of recent recommendations that were supported by various HCCC members as acknowledged in previous submissions from the Coalition on the topic of pharmacare. As there is diversity in how diseases are treated, the size of the patient population and the availability of treatments for various diseases, it is anticipated that many HCCC members will also provide a disease specific submission to the Committee.
Context
Access to medicines is an important issue for our members and to the Canadians that they serve. Prescription drugs can manage conditions, cure disease(s), improve quality of life, shorten or prevent time spent in hospitals and reduce the demand for health care services, potentially leading to positive health outcomes and decreased costs to the healthcare system. Unfortunately, there are many Canadians who remain either without prescription drug insurance and/or remain unenrolled in available programs.
The tabling of Bill C-64 proposes foundational principles for pharmacare and provides the Minister of Health with specific powers and obligations as it relates to the provision of certain prescription drugs and related products. This Bill also provides for a national formulary that will establish the scope of prescription drugs and related products to which Canadians should have access under national universal pharmacare, as well as establish a national bulk purchasing strategy. The introduction of Bill C-64 is a first step in meeting this important goal with an initial coverage for specific prescription drugs and related products intended for contraception or the treatment of diabetes.
As the Standing Committee on Health considers the Act respecting pharmacare, we wish to draw particular attention to the following areas of the Bill that may require further clarification to assist with its future implementation. Accordingly, HCCC makes the following recommendations to Bill C-64 vital to Canadian patients:
On addressing accessibility and affordability:
• A national pharmacare program needs to ensure patients are able to access all drugs approved by Health Canada – if not on the national formulary, then via private insurance plans or through separately adjudicated access programs that consider a patient’s specific circumstances. Reducing access that citizens currently have to prescription medicines is counterproductive and creates uncertainty for all people in Canada.
• The high cost of inflation and the rising cost of living have created additional barriers for many people who are living with disease who are required to pay out of pocket for all/portions of their prescription medications. 2 Every effort must be made to eliminate and/or reduce out-of-pocket drug expenses within a national pharmacare program.
On national formulary:
Individuals with lived and living experience are best suited to provide invaluable input on the impacts of therapies to a person living with disease and their expertise should be included in the development and implementation of a national formulary.
• That patient representatives and healthcare providers be involved in the planned committee of experts in the development of the national formulary as they are best placed to speak on behalf of patients needs and available treatment options in the context of pharmacare.
On patient representation/ Committee of Experts:
Throughout the Health Canada consultations on pharmacare, we have repeatedly recommended that the Government of Canada seek opportunities to meaningfully and continuously engage patient representatives in their decision making and regulatory processes. Meaningful engagement goes beyond holding briefings and calls for submissions. It is the conscious decision to include people with lived and living experience in identifying gaps and problems, setting priorities, and working together to identify and implement solutions. As we look to enacting Bill-64, we ask that consideration be given to ensuring that the legislation provides for patient partners and people with lived and living experience to provide their specific expertise and continuous input to strengthening the pharmacare program.
• While the development of a national pharmacare program holds great promise to improve the lives of patients in Canada, a program for patients must be designed with patients. To this end, itis imperative that the Committee of Experts include representation from people with lived andliving experience. It is recommended that section 11(1) include more specificity on the types of experts that are to be considered, and that “people with lived experience as a patient or person living with a disease” be included.
• In an effort to increase transparency, it is recommended that the work of the Committee be made available to Canadians. Therefore, is suggested that Section 11(2): be amended to read “The committee must, no later than the first anniversary of the day on which this Act receivesroyal assent, provide a written report to the Minister setting out its recommendations. The report must be made available to the public no later than 30 days after it has been submitted to the Minister”.
• Additionally, as part of its report, the Committee of Experts must also research and report on the anticipated and potential impacts of national universal pharmacare on access to medicines, applying case studies and other models to understand how beneficiaries are expected to behave in the context of new programs or enhancement of existing plans in terms of reduced financial barriers for specific medicines.
Conclusion
The Health Charities Coalition of Canada remains committed to working with the federal government to ensure that Canadians have access to high-quality therapies, devices and health strategies that are appropriate for patient needs, respect an individual’s choice and are delivered in a manner that is timely, safe and effective according to the most current evidence available. We welcome the opportunity to be a part of and/or provide recommendations to the Committee of Experts. We would be pleased to respond to any questions that the Committee may have.
Organizational Information
The Health Charities Coalition of Canada (HCCC) is a member-based organization comprised of national health charities which represent the voice of patients at all levels of the health continuum. The health charities that HCCC represents strengthen the voice of Canadians, patients and caregivers, and work with others to enhance health policy and increase investment in health research. HCCC strives to ensure that the federal government and policy makers look to the Coalition and its members for timely advice and leadership on major health issues of concern to Canadians; and that they recognize the expertise, commitment, and contributions of health charities in improving the health and well-being of Canadians.
1 Government of Canada. A Prescription for Canada: Achieving Pharmacare for All. June 2019. p.9
2 Law MR, Cheng L, Kolhatkar A, et al (2018) The consequences of patient charges for prescription drugs in Canada: a cross-sectional survey. CMAJOPEN E63-70