Other
PMPRB Services
PDCI Market Access can assist you in preparing new medicine submissions using
our expertise on the PMPRB’s Guidelines, Procedures and Policies.
Expertise gained through extensive experience navigating new drugs through
the Board’s price review process.
A new medicine
submission should speak to the Board in its own terms, following the
process used by the staff of the Board to review new medicines. The
staff’s review is a methodical application of the scientific review
procedures, excessive price guidelines and, as needed, provisions of the
compliance and enforcement policies.
The
scientific review process involves, among other things, categorization of
the new medicine and the selection of comparable medicines and dosage
regimens. The process involves the Board's own scientific staff, drug
information centres and independent drug advisory panels. The latter are
responsible for making official recommendations to the Board on scientific
issues.
From the scientific
review, flows the price review. A staff compliance officer reviews the
price of each new drug product with reference to the Guidelines as they
apply to the category assigned by the scientific staff. On this basis, one
or more price comparisons will be conducted. In all cases, the price is
reviewed against the range of international prices. Ideally, this process
can be conducted before the new medicine is launched (and thereby avoid
enforcement actions).

Submissions for new
medicines are not required by the PMPRB. However, without a submission,
the staff of the Board will not have an opportunity to consider the
company’s position nor important information that may be relevant to the
scientific and price reviews.
Some companies wait
until the Board staff has conducted its review and formed an opinion
regarding scientific and pricing questions. This "wait and see"
approach can be a mistake. It is far less difficult to convince the Board
of the company’s position in the first instance than it is to alter an
opinion once it has been formed. For many of these issues (e.g., primary
indication and dosage regimens) there may be more than one appropriate
interpretation or a range of acceptable values. However, application of
the Guidelines requires precise answers and values. The staff of the Board
often seek recommendations from independent sources. Without a submission,
these sources are not in a position to see the issues from the company’s
perspective.
For further information on PDCI Market Access's consulting services for PMPRB
new medicine submissions please contact
Janice
D’Angelo or Neil Palmer.