CORD’s Submission to PMPRB on the Revised Draft Guidelines & CORD CADTH Consultation Feedback–Aligned Process

August 4, 2020

VIA EMAIL AND SUBMISSION PORTAL: PMPRB.Consultations.CEPMB@pmprb-cepmb.gc.ca

Patented Medicine Prices Review Board (PMPRB)
333 Laurier Avenue West, Suite 1400
Ottawa, Ontario K1P 1C1

Dear Members of the PMPRB,

The Canadian Organization for Rare Disorders (CORD) is the national voice for the nearly 3 million Canadians affected by rare diseases. This response focuses on three fundamental questions:

1. Have the PMPRB revised guidelines for the implementation of changes to the Patented Medicines Regulations (released in June 2020) meaningfully addressed the concerns raised by CORD in our submitted feedback to the original draft guidelines released in December 2019?
2. Has the consultation process subsequent to the release of the revised guidelines promoted, first and foremost, clarification of the application of economic factors to provide certainty to patients and developers as to the impact of the guidelines on access to new therapies?
3. Has the PMPRB provided forums for open and meaningful dialogue to exchange perspectives, to address stakeholder concerns, and most importantly, to jointly explore and co-create mutually beneficial solutions?

Our very short answer to all of these questions is an emphatic “NO!” In fact, not even close.

Our very short answer to all of these questions is an emphatic “NO!” In fact, not even close.

CORD CADTH Consultation Feedback–Aligned Process