Letter to Senate Committee re off-label prescribingRelease Date: 03/04/2014 Staff Reference: Stephen Frank
March 4, 2014
The Honourable Kelvin K. Ogilvie
Chair, Senate Standing Committee
on Social Affairs, Science and Technology
The Senate of Canada
Ottawa, Ontario K1A 0A4
Dear Senator Ogilvie:
I am writing to indicate the Canadian life and health insurance industry's support for the recommendations outlined in Senate's recent report "Prescription Pharmaceuticals in Canada: Off-Label Use".
The CLHIA is a voluntary association whose member companies account for 99 per cent of Canada’s life and health insurance business. At the end of 2012, private insurance plans in Canada provided over 23 million people with supplementary health benefit coverage, including prescription drug benefits. During 2012, life and health insurers reimbursed about $10.1 billion in prescription drug costs to policyholders and beneficiaries in Canada under these plans.
As you may be aware, the CLHIA released the attached prescription drug policy paper in June of 2013. It makes a number of important recommendations to improve the prescription drug system in Canada. One of the key concerns we raised in our paper relates to off-label prescribing.
The paper notes that prescribing off-label can be a valuable tool for physicians and is generally accepted medical practice. However, it does pose risks from a patient safety perspective and can also drive up costs to the system. This is particularly true with rare, higher cost drugs whose original regulated price ceiling was established by the Patented Medicines Prices Review Board (PMPRB) based on a small estimated potential market. Over time, however, off label prescribing can result in a much larger volume of sales without any commensurate re-evaluation of the price ceiling by the PMPRB. This, over time, undermines the ongoing financial sustainability of Canada's prescription drug system. Canada's life and health insurance industry fully supports greater oversight into the practice of off-label prescribing – not only to ensure patient safety but also to help address rapidly escalating costs within the system.
We recognize that providing enhanced monitoring of off-label prescribing in Canada is a complex issue and commend the Senate for addressing it. As you continue your deliberations, if Canada's life and health insurance industry can be of any assistance, please to not hesitate to contact me.
Original signed by
c. Senator Art Eggleton, Deputy Chair