
IMC Response to PMPRB Interim Approach Consultation
IMC’s members continue to have significant concerns regarding changes to the PMPRB and future Guidelines that will implement the revised schedule of international reference countries.
We represent Canada’s innovative pharmaceutical industry.
Innovative Medicines Canada is committed to being a valued partner in Canada’s healthcare system. We partner with governments, insurance companies, healthcare professionals and other stakeholders to advance our country’s life sciences sector.
The strong alliances we form support policies that improve Canada’s regulatory environment, protect intellectual property and expand Canada’s access to the newest available pharmaceuticals. We conduct all our advocacy to improve the well-being of all Canadians and protect patient safety on behalf of our members.
Canada’s innovative pharmaceutical companies invest more than $2.2 billion a year to find new ways to treat and cure illnesses and diseases. The more than 500 new products currently in development – from vaccines to cancer and infectious disease treatments – support local economies, including 100,000 high-quality, well-paying jobs. This activity also provides Canadian doctors and hospitals with access to innovative new therapies that help Canadians live longer and healthier lives.
Our advocacy integrates the interests of federal and regional governments, ensuring all voices are represented at the policy table. The opinions we hold and the communication campaigns we use to reach healthcare stakeholders are backed by data and research conducted either by Innovative Medicines Canada or our trusted providers.
Meanwhile, Canada attracts roughly 1 percent of the world’s pharmaceutical research and development investment. We can do much better. IMC is working with industry and governments to create a regulatory environment on par with the rest of the world. Our aim is to attract substantially more foreign investment and clinical trials.
A globally competitive intellectual property environment is crucial for advancing innovation in any industry. Innovative Medicines Canada works diligently to protect the innovation of evidence-based pharmaceuticals by advancing the following:
In 2013, the Government of Canada took steps to improve intellectual property protection in Canada by finalizing the Comprehensive Economic and Trade Agreement (CETA). This historic agreement was an essential step in strengthening Canada’s position on the international life sciences stage.
CETA provided several key improvements for protecting intellectual property:
The renegotiation of NAFTA presented a valuable opportunity to improve Canada’s intellectual property regime. Original copies of CUSMA provided substantial improvements. However, the final text does not improve Canada’s intellectual property regime as much as it could. Originally, the agreement provided research-based pharmaceutical companies with 10 years of data protection on new biologics, but the ratified agreement removed this improvement.
Despite the lack of data protection on new biologics, CUSMA does provide an opportunity to improve Canada’s intellectual property regime in a meaningful way. Patent term adjustment (PTA) will provide additional data protection in the event that patentees experience unreasonable delays in the patent examination process. The Government of Canada has not yet amended its patent legislation to fulfill this obligation, although it must do so by January 1, 2025.
For more information on Canada’s intellectual property regime and how it compares to other jurisdictions, see the following resources:
Global Innovation Policy Centre’s 2021 International IP Index
U.S. Trade Representative 2021 Special 301 Report
Increasing access to innovative medicines, vaccines and treatments for Canadian patients is central to IMC’s work. We are committed to working collaboratively with governments, industry, health care professionals and other key stakeholders to improve the pricing and reimbursement process and ensure timely access to new medicines for Canadians.
Today, Canadians with public drug plan coverage wait an average 22 months from Health Canada approval to patient access. This is two times longer than most other Organisation for Economic Co-operation and Development (OECD) countries, with Canada ranking 19 out of 20 countries that have a similar economic status.
By streamlining the access pathway, we can give Canadians faster access to the best innovations the industry has to offer – and, in doing so, achieve better health outcomes for all.
IMC’s members continue to have significant concerns regarding changes to the PMPRB and future Guidelines that will implement the revised schedule of international reference countries.
This policy note characterizes Canada’s current testing infrastructure and its limitations, which include that it hinders current and future patient access to the best available treatments.
IMC opposes a January 15, 2021 proposal to redefine ‘gap’ medicines and change the timeline for compliance – which halves the transition period to six months.
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