Vital Submission to the PMPRB's 2023 Interim Guidance Consultation

Published on August 21, 2023

This submission is made on behalf of the Canadian Association for Pharmacy Distribution Management (CAPDM) (now named Vital) in response to the 2023 Proposed Amendment to the Interim Guidance re: New Medicines (the Draft Guidance). Vital is supportive of the Committee’s decision to study the ongoing PMPRB reforms, including the specific aspects this consultation explores, and encourages holistic examination of drug pricing to ensure sustainable funding for Canada’s medication supply system. Without consideration of the costs of physical storage and delivery in contemplating drug pricing approaches, the current and considered reforms will further destabilize an already fragile drug supply system, making access to medications for Canadians, particularly those in rural and remote areas, more challenging.