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Patented Medicine Prices Review Board
Let’s Talk Numbers Ottawa, December 6, 2012
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Content Price Review of Existing Medicines Exchange Rates
CPI-Adjustment Methodology Highest International Price Comparison Exchange Rates Verification of International Prices Calculating ex-factory prices Criteria for an Investigation Application Forms for the DIP Methodology
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CPI-Adjustment Methodology
Guidelines - Schedule 9 1.1 … the National Average Transaction Price and … of an existing patented drug product will be presumed to be excessive if they increase by more than that allowed under the Board’s CPI-Adjustment Methodology, as long as this price does not exceed the HIPC test.
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CPI-Adjustment Methodology
Constraint #1 1.2 - Adjusting the benchmark prices of the drug product for the cumulative change in the CPI from the benchmark year to the year under review (CPI-Adjusted Price); and
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CPI-Adjustment Methodology
Constraint #2 1.2 - Applying a cap on the maximum price increase in any one year, equal to 1.5 times the forecast change in the annual CPI. In periods of high inflation (over 10%), the limit will be five percentage point more than the forecast change in the CPI.
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Terminology Benchmark Year & Price Introductory vs Current
Benchmark Year is 3 years prior to the date of sale, unless date of first sale is less than 3 years Introductory Benchmark Price: Lower of the N-ATP and MAPP Current Benchmark Price: Lower of the N-ATP and N-NEAP
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CPI-Adjustment Methodology
CPI factor derived using Stats Can factors Cap factor is 1.5x the annual forecast CPI Factors Published in the PMPRB NEWSletter Actual: January NEWSletter Forecast: April NEWSletter
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Calculating the N-NEAP Example: 3 years
N-ATP N-NEAP Highest International Price 2009 (Benchmark) $ $ 2010 $ $ 2011 $ $ 2012 $ ? 2012 Forecast CPI Factor = 1.064 2012 Forecast Cap Factor = 1.032 CPI = x $ = $ Take the lower Cap = x $ = $ The forecast N-NEAP for 2012 = $
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Highest International Price
Calculating the N-NEAP Example: When Date of First Sale is less than 3 years prior Year N-ATP MAPP / N-NEAP Highest International Price 2010 (Benchmark) $ $ 2011 $ $ 2012 $ ? 2012 Forecast CPI Factor (2 year) = 1.046 2012 Forecast Cap Factor = 1.032 CPI = x $ = $ Take the lower Cap = x $ = $ The forecast N-NEAP for 2012 = $
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Calculating the N-NEAP Example: No yearly price increase
N-ATP MAPP / N-NEAP Highest International Price 2009 (Benchmark) $ $ 2010 $ 2011 $ 2012 $ ? 2012 Forecast CPI Factor = 1.064 2012 Forecast Cap Factor = 1.032 CPI = x $ = $ Take the lower Cap = x $ = $ The forecast N-NEAP for 2012 = $
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Highest International Price
Calculating the N-NEAP Example: How CPI & Cap differ in the second year of sales Date of first Sale - March 23, 2011 Benchmark Price: $ Year N-ATP MAPP / N-NEAP Highest International Price 2011 (Full Year) $9.0000 $ $ 2012 ? 2012 Forecast CPI Factor (1 year) = 1.021 2012 Forecast Cap Factor = 1.032 CPI = x $ = $ Take the lower Cap = x $ = $9.2880 The forecast N-NEAP for 2012 = $9.2880
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Highest International Price Comparison
Guidelines - Schedule 6 1.2 … the Average Transaction Price of a patented drug product at the national level…will be presumed to be excessive if it exceeds the highest price of the same strength and dosage for of the same patented drug product for each country listed in the Regulations (France, Germany, Italy, Sweden, Switzerland, the United Kingdom, and the United States).
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Highest International Price Comparison
Guidelines - Schedule 6 2.1 To calculate the HIPC test for a new patented drug product, the exchange rates used are the simple average of the thirty-six monthly average noon-spot exchange rates for each country (taken to eight decimal places) as published by the Bank of Canada for the thirty six months ending four months before the date of the first sale of the drug product.
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Highest International Price Comparison
Seven countries listed in the Regulations Reported Form 2 Block 5 Exchange rates (36-month average) Verification of International Prices
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Exchange Rates 36-Month Average Found on the website
April 2009 March 2012 April 2010 April 2011 Found on the website Are you a Patentee? Frequently Requested Items (
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International Price Verification
ABC 100 mg/tab (DIN ) International Price Verification January-June 2011 Country Company Submission Prices International Ex-Factory Prices Backed Out From Public Sources (Local Currency) (Canadian Currency) Publicly Available International Prices (30) (CDN$)(H) (CDN$) Canada (CDN$)(P) $2.6775 (CDN$)(W) (28) (€)(H) (€) (€)(P) Germany $2.1463 (€)(W) $2.1561 (US$)(H) (US$)(WAC) (US$)(P) (US$)(FSS) (US$)(W) (90) US $6.9589 N/A $6.3429 Median $4.5526 $4.2495
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Verification of International Prices
Country Source Hospital Pharmacy Wholesaler Other France Vidal X Germany Röte Liste Italy L’Informatore Farmaceutico Sweden TLV Website Switzerland BAG online United Kingdom Monthly Index of Medical Specialties (MIMS) United States Thompson PDR- Red Book Direct Price (DP) Wholesale Acquisition Cost (WAC) Federal Supply Schedule X(a) X 4-FSS (a) Report only one Wholesale price unless the DP and WAC prices are different.
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Example: Verification for Germany
Company Submission Pack Price Customer Size € Class Average Price / Unit in € Average Price/ Unit in CDN $ (28) (H) [(40.04/28) +( 42.10/28) + (40.04/28)] / 3 = € x = CDN $ (28) (P) (28) (W) Exchange rate for Germany: Company would be requested to provide evidence that € is the publicly available ex-factory price of ABC for hospitals in Germany.
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Calculating the Ex-Factory Price (Germany)
Formulary Price (FP) stated in euros in Röte Liste FP includes 19% Value Added Tax (VAT) No price comparable to ex-factory hospital price reported by patentee
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Calculating the Ex-Factory Price (Germany)
Step 1: Remove VAT: FP net (FPN) = FP / 1.19 Step 2: Calculate ex-factory pharmacy price (PP) PP = (FPN-8.10) / 1.03 Step 3: Derive ex-factory wholesale price (WP)
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Calculating the Ex-Factory Price (Germany)
Ex-factory wholesale price (WP) is derived as follows: If : < PP ≤ WP = PP / 1.15 3.46 < PP ≤ WP = PP 4.20 < PP ≤ WP = PP / 1.12 5.61 < PP ≤ WP = PP 7.27 < PP ≤ WP = PP / 1.09 9.82 < PP ≤ WP = PP < PP ≤ WP = PP / 1.07 < PP ≤ WP = PP < PP ≤ 1,272.00 WP = PP / 1.06 PP > 1,272.00 WP = PP – 72
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Example: Verification Germany (Drug ABC, March-June 2011)
Publicly Available Price(1) Pack Size Price Ex-Factory Price Pack Price Cust. Size € Class Average Price/ Unit in € Average Price/ Unit in CDN $ (28) (€) (28) (€)(P) [42.10/ /28 ]/2 = € x = CDN $ (28) (€)(W) (1) Price Source for Germany: Röte Liste Jan. 1, 2011 Exchange rate for Germany: Explanation of second column Prescription drug Step 1 remove VAT FPN = / = Step 2 PP = (FPN-8.10) / = (51.46 – 8.10) / = Step 3 WP = / =
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International Price Verification
ABC 100 mg/tab (DIN ) International Price Verification January-June 2011 Country Company Submission Prices International Ex-Factory Prices Backed Out From Public Sources (Local Currency) (Canadian Currency) Publicly Available International Prices (30) (CDN$)(H) (CDN$) Canada (CDN$)(P) $2.6775 (CDN$)(W) (28) (€)(H) (€) (€)(P) Germany $2.1463 (€)(W) $2.1561 (US$)(H) (US$)(WAC) (US$)(P) (US$)(FSS) (US$)(W) (90) US $6.9589 N/A $6.3429 Median $4.5526 $4.2495
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Criteria for Investigation
N-ATP exceeds the MAPP by 5% at intro Excessive Revenues greater than $50,000 PMPRB receives a complaint
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OTC and Veterinary Patentees still have to submit the Form 1 and Notification of Intent to Sell If there is a complaint, the PMPRB will request that the patentee file the complete Form 2s since date of first sale.
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DIP Methodology Simplified and Regular DIP
Introductory Benchmark Price (IBP) Two parts to the form (A & B) Part A (simplified & regular) reasons for the DIP Part B (regular only) Block 5 list price increases Must demonstrate loss of benefits
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Reference Material PMPRB Website - special section reserved for Patentees, look for the pill bottle along the side. ( Exchange Rates Verification of International Prices (Outreach Session) or (Formulas) DIP Methodology (Webinar, Forms and Reports)
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