IN THE WORKS
CAPDM focuses on a number of industry issues and works on behalf of its Members to improve the pharmacy supply chain industry as a whole.
Current CAPDM Initiatives
Strategic Sessions with the Board
CAPDM and the Board of Directors have begun its series of strategic sessions to examine public and Member perceptions of the Association and its work in the industry, its strengths and key deliverables. Consulting with The Advantage Group and Praxis PR, CAPDM has spoken to many industry stakeholders, including brand and generic manufacturers, wholesalers, pharmacy retailers, and industry associations. Various government representatives and senior policy advisors have also been consulted to further understand how CAPDM is perceived. Moving forward, the Board of Directors will define CAPDM's focus, identity, and how best to serve the membership and work with stakeholders.
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Federal Government Activities
CAPDM submitted to Health Canada our Official Complaint regarding the excessive fee increases proposed by government for Establishment License Fees. An appeal panel will be held this autumn in Ottawa to consider this issue, plus other elements objected to by Rx&D, MEDEC, NDMAC and others, at which CAPDM will make a presentation.
In addition, CAPDM will meet with federal government groups in October on steps that Ottawa is considering to toughen up anti-counterfeiting laws and regulations, as well as on issues surrounding catastrophic drug coverage.
Temperature Control Coalition Seminar Aids Progress Toward Industry Guidelines
The Temperature Control Coalition – composed of CAPDM, RX&D, CGPA, NDMAC and PPCLA member companies – held a successful seminar/workshop on July 16 in Toronto. Attended by more than 65 people, the seminar/workshop met two important goals:
1. Speakers presented updates on the past several months’ work of three Working Groups - Temperature Control/Classification, Stability Data/Excursion Levels, and Contracts and Information Sharing - in their progress to achieve Leading Practices guidelines in these areas. In addition, a report was given by the Government Relations Working Group on feedback from some wholesalers/distributors and manufacturers regarding on-site audits by the Health Products and Food Branch Inspectorate, as well as from the HPFBI on its key discoveries during these inspections. A revealing presentation was also given on typical transit times nationally, pick-up and delivery processes, and loss or damage claims.
2. Input was received from attendees that strengthened the content of the work by these four Working Groups, as they progress toward concluding their work before the end of 2007.
The guideline for contract contents between manufacturers/importers and wholesalers/distributors has been distributed for wider comment. The objective is to complete a Leading Practices guideline for temperature controls/classification, route profiling and qualified packaging for circulation by late this Fall, which will be helpful in the industry’s next meeting with the HPFBI, expected to take place before the end of 2007.
CAPDM Responding to Health Canada’s Proposed Increases in Establishment Licensing Fees
The federal Health Protection and Food Branch Inspectorate has proposed large increases of Establishment Licensing fees paid by wholesalers/distributors and fees for storing and selling private label medical devices and medications. CAPDM has made a submission to the government opposing the size and timing of these increases, as well as seeking greater transparency regarding the reasons for the proposed fee hikes. Further discussions have been requested, which will take place over the summer.
Benzodiazepines Now GST Exempt
At the end of June, federal Parliament passed Bill C-40 that, among other provisions, makes Benzodiazepines exempt from GST collection.
CAPDM Engages Health Canada on Cost Recovery Framework
CAPDM has engaged in discussion with Health Canada on the Cost Recovery Framework, as Health Canada considers increasing fees charged for services and licensing it provides in several categories of business. Pharmaceutical manufacturers, wholesalers, self-distributing pharmacy chains, as well as medical device manufacturers are all potentially affected. CAPDM will be submitting a business impact overview and meet with Health Canada throughout the summer months.
CAPDM Forms Government Relations Committee – Ontario
Recognizing the complexity of government-industry relations, CAPDM is forming member-populated government relations committees for the key areas across Canada. With the Western Committee up and running, CAPDM has now formed the Ontario Committee and will be following up with other key regions in the near future. Each committee will identify key strategies and actions for their regions and guide ongoing activities to maximize dialogue with the government and responsiveness to critical issues.
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Provincial Government Activities
Ontario
CAPDM is in discussions with the Emergency Management Unit of the Ontario Ministry of Health and Long-term Care with respect to meetings following the October provincial election. The objective is to agree on possible pandemic scenarios that could reasonably occur and how the supply chain, government and other stakeholders can work together for effective readiness in the event of these emergencies.
Earlier this month, CAPDM made a submission to the Ontario Government, on lead times regarding Formulary updates. CAPDM recommended that the allowable time gap between the announcement of Formulary new prices and the effective date for industry to comply be 30 calendar days; the government is considering a lead time of seven days, which CAPDM believes is too short to properly implement all the changes that flow from Formulary updates. A decision from the government is expected before year-end.
Bill 171 (Pandemic Planning) - In April, CAPDM submitted a Brief to the Ontario Government’s Standing Committee on Social Policy related to the government’s proposed powers of “procurement, acquisition and seizure of any medications and supplies” necessary to address an immediate widespread risk to Ontarians’ health, where regular procurement processes are deemed unable to meet this need. CAPDM made several recommendations to the government as it reviews Bill 171, which addresses government powers, should a pandemic health crisis ever be certified by Ontario’s Chief Medical Officer of Health. CAPDM wants to ensure understanding that while the health care supply chain runs smoothly, it is technically very complex and highly integrated with systems outside Ontario – it is important that this complexity be taken into account during emergency planning and be reflected in clear legislative and regulatory language.
Recommendations included the following:
- Vital joint planning between the government and private sector suppliers of medicines and supplies should begin as soon as possible if and when the Bill becomes law. It is also crucial to establish an ongoing process for CAPDM Members to provide their expertise. This will mean that well before any pandemic may strike, decisions will be in place regarding a mutually-agreed system for procuring, possessing, transporting, storing and compensating for these products, and that adequate stocks can be available in an emergency. Taking these complex realities into account must be done upfront as a unified initiative, not as elements addressed in isolation of each other.
- Assuring the protection of confidential business information shared by suppliers must be part of any planning.
- Issues related to fair compensation policies were also addressed.
In addition to the Brief, CAPDM also held meetings with Ontario government officials for updates on provincial planning status; to obtain clarification on aspects of Bill 171; and to outline where the expertise of CAPDM can assist.
Bill 102 - CAPDM, along with other stakeholders, will be meeting with the Ministry of Health on the reporting and monitoring of professional allowances of Bill 102.
Emergency Preparedness - CAPDM is working with the Emergency Management Unit of the Ministry of Health with regard to Bill 171 and emergency procurement, as well as with the statutory of warehousing, stockpiling and distribution of pharmaceutical products in the event of a pandemic crisis.
British Columbia
CAPDM continued its ongoing meeting with BC’s Pharmaceutical Services Division (PSD) to understand the BC Ministry of Health and Pharmacare’s direction and impact on the pharmacy supply chain. PDS is still undergoing significant structural changes but will have the final structure and strategies defined by June. CAPDM will be attending the June meeting presenting the PDS strategy and direction and will provide an update to the membership.
Quebec
Consultation has taken place between the Quebec Ministry of Health and Quebec distributors concerning a reduction in the current generic drug pricing methodology, maximum wholesaler upcharges, Quebec drug price increase acceptance, etc. Recommendations are pending. It is understood that any generic drug pricing rulings will not be implemented before January 2007.
Saskatchewan
CAPDM has meet with a representative for distributors performing business in Saskatchewan under the Social Contract (Kevin Wilson, Executive Director of the SK Drug Plan and Extended Benefits Branch of the Ministry of Health) regarding the renewal of the Social Contract, which officially expired at the end of June 2005. Other areas concerning distribution amd contemplated future drug plan revisions were discussed to ensure CAPDM involvement and representation.