Quite simply, on the first point, the people who are most suffering from drug prices are the patients who are paying out of pocket. That represents about 21% of the total spend on prescription drugs in Canada. They don't have an ability to negotiate a better deal.
The second group of people—and they're represented here most ably by Mr. Frank—are the private insurance carriers. When they choose to, they have an ability to negotiate price on behalf of their plan sponsors.
The third group is the government drug programs which, after 60 years, have done the right thing and are bargaining collectively with drug providers through an informal organization, the pan-Canadian pharmaceutical alliance, which all the governments of Canada are participating in. The government drug plans are looking after themselves and they're doing a good job of it.
The problem is the new factors. The simple truth of it is that there is no other jurisdiction in the world that is using those economic factors for the purpose of price controls on drugs.
Let me make the distinction between price controls by regulation versus price negotiations, where individual patients don't have that clout. That's why we are in favour of the proposal and the regulation to change the comparison among countries to countries that are of a similar capacity to pay—gross domestic product.
The economic factors.... Frankly, if the committee and its analysts could take the time to go back to the six case studies of six different kinds of drugs that the PMPRB staff put forward back in 2008—which have not been updated with the final version of the regulations or the guidelines—you will see the problems there. I would invite a deeper dive by the committee and its analysts. I would be happy to help and point to the right documents.
It would be wonderful if the PMPRB had enough confidence in the rest of us that they would actually open their kimono and show us the details of their spreadsheets, their assumptions and their analysis, so that we could be happy to verify or be happy to dispute. There has been a lack of disclosure by the PMPRB staff of what the assumptions are and what the actual details of their analyses are on those case studies.
With all due respect, colour me skeptical when there is a lack of disclosure. Those are the reasons we are concerned about the significant risk that the government and PMPRB are taking by proceeding with all of the changes at the same time.
For my last point, let me use an analogy of a patient and a doctor. No doctor worth his salt would knowingly start a patient on four new drugs at the same time, because if something works, you don't know what is working. More importantly, if something does not work, you don't know what is causing the problem. The problem with these regulations and guidelines is that they're trying to do four different things at the same time. If something goes wrong, what is actually the central cause of the problem?
We ask for them to pause and reflect. Proceed with the change of basket of comparison countries and let's take a deeper dive into the more likely impacts of each of the three additional new economic factors. This is an experiment in public policy that has not taken place anywhere else in the world.
