BIOQuébec’s Comments on the Patented Medicine Prices Review Board (PMPRB) Guidance Document for Consultations
BIOQUÉBEC
BIOQuébec is a non-profit association funded entirely by its members. It represents over 140 organizations in Quebec’s life sciences industry, particularly in the biopharmaceutical and biotechnology fields. Our members are involved in every stage of the healthcare innovation chain, including drug discovery, development, manufacturing, and marketing. BIOQuébec is the voice of the industry, promotes networking and economic development, and serves as a link between the private sector and stakeholders.
BACKGROUND
BIOQuébec has spoken out several times in recent years in favour of effective changes to the regulatory framework governing drug pricing in Canada. This is an extremely important issue for the development of the life sciences sector, in a context where medical advances are accelerating and taking on a global scope. Canadians cannot afford to see their economy left behind in this technological revolution as a result of misguided public policies that undermine the significant investments made by both the private and public sectors.
BIOQuébec is committed to a stable, predictable business environment that benefits patients, the public sector, and innovative companies. This is why BIOQuébec strives for coherence between the numerous public policies that affect our sector.
To this end, BIOQuébec promotes ongoing dialogue between the community, including academic research, the clinical field, patient groups and industry, and regulatory bodies. The Patented Medicine Prices Review Board (hereinafter referred to as the “Board” in the document) must be equipped with more frequent and ongoing consultation mechanisms, prior to the publication of interim guidelines. It needs to adopt the most holistic approach possible, to foster the greatest possible coherence.
We are very pleased that the Board has chosen to engage in a broader dialogue on its guidelines with civil society. BIOQuébec is grateful for this opportunity to make its views known.
BIOQUÉBEC’S COMMENTS ON THE GUIDELINES
PRINCIPLES
At the outset, BIOQuébec wishes to emphasize that the substance of this consultation is directed at stakeholders on subjects and issues that are generally very specific and precise, not to mention technical. BIOQuébec is not in a position to comment at this level of detail, and we hope that the other participating parties will be able to brief the Board according to its expectations.
On the other hand, BIOQuébec feels very comfortable commenting on the principles it would like to see reflected in the directions and guidelines laid out by the Board.