One thing I should point out, and I did get into this a little bit in my presentation, is that when the regulatory amendments were published, they contained a cost-benefit analysis that projected about $8.9 billion in savings as a result of these changes, in net present value.
I did try to unpack the numbers a little bit for you on how we project the impact of the new regime with both the guidelines and regulations operating in tandem. It is quite a bit lower than that. It's more in the neighbourhood of $6.2 billion. That's probably an overestimate of the impact over the coming 10 years, because that looks at list prices and it doesn't take into account.... We look at list prices and we see how much they are going to come down as a result of these changes, and then we calculate how much less we are going to be spending on pharmaceuticals. However, the reality in the market is that list prices don't represent the true price in the market most of the time.
Let's say you have a drug with a list price of $100. As a result of these changes, the list price would come down 5%, to $95. If the true price in the market is $90—if the pCPA has negotiated a deal for $90—that won't have any real impact on pharmaceutical expenditures in Canada. That $6.2 billion is probably an overestimation of the impact by a considerable margin.
There is a significant gap between what we're projecting today versus what was projected in the cost-benefit analysis, the CBA, because of the impact of that Federal Court decision and our inability to apply new factors in a meaningful way.
To circle back to your original question, Dr. Levine mentioned this in his opening remarks. Canadian prices vacillate between third- and fourth-highest in the OECD, currently, for patented medicines.