Thank you, Mr. Chair and members of the committee. I am indeed pleased to be back before you to assist in your final deliberations.
Before I begin my formal remarks, I wish to advise the committee that, as I'm sure you can appreciate, Dr. Sanders and I are neither of us in a position to make any commitments here today to you. However, we are certainly happy to listen to your thoughts, your words of wisdom and suggestions and recommendations, and take them back to the Conference of Deputy Ministers for their deliberations.
Mr. Chair, you and other members of the committee should be in receipt of a letter I sent you dated June 6. I would like to take this opportunity to read that letter into the record as part of the formal presentation on behalf of the Conference of Deputy Ministers of Health.
Over the course of the seven hearings held by the Standing Committee on Health related to the common drug review, there have been a number of themes continuously repeated and reinforced by both the pharmaceutical industry and their patient advocacy partners. I believe these themes or messages, as portrayed, are inaccurate and misleading. I wish to correct these inaccuracies for the committee in five specific areas: ownership, accountability to Canadians, CDR transparency, duplication of process, and compliance with CDR recommendations.
I go to the first item: ownership.
The committee has been led to believe that CADTH and the CDR are not “owned” by anyone and as such, are not accountable. This is not appropriate.
The CDR is owned by the 13 provincial/territorial deputy ministers of health and the federal deputy minister of health that established it.
As stewards of their respective health care systems, these deputy ministers take this ownership and the work of CDR very seriously and they report back regularly to their elected ministers of health. Under this governance structure, CADTH and the CDR are very much accountable. I quote from the presentation I made to the Standing Committee, which states the federal/provincial/territorial position: “We want to assure you that CADTH, which is owned and governed by the Conference of Deputy Ministers of Health, is fully accountable to the CDM. In fact, in our opinion, CADTH is one of the most accountable national agencies existing in Canada today.”
The second item is accountability to Canadians.
The CDR is not failing Canadians. In fact, through the rigorous, objective, and independent information obtained by the CDR, governments are able to make decisions that protect the public from harm, ensure improved health outcomes, and contribute to the long-term sustainability of Canada's health care system.
The Canadian public, as patients and taxpayers, expect nothing less of their governments in determining which drugs should be made available through the publicly funded drug benefit system.
Canada has faced drug recalls that have harmed Canadians. Governments must do whatever it takes to manage such risks. The CDR contributes to this goal, it is working, it is helping Canadians, and it is here to stay.
The third item is CDR transparency.
Industry has consistently attacked what it views as a total lack of transparency in the CDR's processes. This is far from the truth. To my knowledge, the CDR is the only drug reimbursement committee in Canada to make the reasons for its recommendations publicly available. This is a significant improvement from what existed prior to the establishment of the CDR.
The CDR continues to set new transparency standards for drug reimbursement in Canada and abroad. Based on the 2005 evaluation of CDR, further steps have already been taken to improve transparency. Chief among these was the appointment of two public representatives as voting members on the Canadian Expert Drug Advisory Committee. In addition, with the CDM's new funding, CADTH is implementing plans this year to produce lay versions of CDR recommendations, the reviews upon which these recommendations are based, and to publish the minutes of the CEDAC meetings.
While the CDM wholly supports calls for greater transparency in the CDR process, the fact is that greater transparency should be a two-way street. For example, we would recommend that drug companies make their submissions to the CDR public. Greater industry transparency could be achieved by making the protocols of all studies available so that comparisons can be made with the final clinical results. We also suggest that the financial relationships between pharmaceutical companies, the disease-oriented groups they support, and those who develop clinical practice guidelines should be fully disclosed.
I go to the fourth item, duplication of process.
The committee has been told repeatedly that the provincial and territorial drug plans repeat the work of the CDR. This is a gross misrepresentation of the facts. I am aware the committee has received individual submissions from most provinces. In those submissions, the provinces clearly state that they do not duplicate the work of the CDR, rather they consider the CDR recommendations in light of their own jurisdictional priorities, needs, and resources. The rigorously derived clinical and cost-effective evidence the CDR provides, combined with the other considerations, is an essential step in the drug plan coverage decision-making process and will continue to take place.
Prior to the CDR, the pharmaceutical industry played the provinces against one another. They would attempt to have the drug approved for coverage in one province and then apply pressure politically in the other provinces. This was not in the best interest of Canadians. With the CDR providing the same high-quality evidence and advice to all drug plans, industry no longer has this option open to it. Instead, through intensive lobbying over the last year, they've decided it is in their best interest to make the CDR look as though it is not working. You have heard directly from the provinces--CDR is working and it is meeting the objectives set out for it. The CDM is steadfastly confident it will continue to do so.
With respect to the fifth and final element, compliance with CDR recommendations, the individual submissions made to the committee by the provincial drug plans clearly state that their decisions are in compliance with the CDR recommendations. A detailed table identifying all drugs reviewed by the CDR and the level of compliance by jurisdictions is attached to my letter. It shows there is a 90% compliance rate with the CDR recommendations across all jurisdictions, and the deviations relate to specific listing conditions rather than a complete reversal of the recommendation. Given that the funding of drugs under provincial drug plans is entirely the decision of each province, a compliance rate of 90% is very high. In fact, the CDR offers the opportunity to move toward even greater standardization in drug coverage across jurisdictions, which is a publicly stated objective of the Conference of Deputy Ministers of Health.
The message being conveyed by industry is that there is a lack of compliance with the CDR recommendations. Let the facts speak for themselves.
In closing, the Conference of Deputy Ministers of Health wants to thank the standing committee for giving it the opportunity to set the record straight. The CDM fully supports the CDR as an invaluable service to Canadians. As the owners of the CDR, the CDM will be interested in the observations brought forward by the standing committee.
Thank you, Mr. Chair.