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BIOTECanada’s submission on Bill C64 An Act respecting pharmacare – BIOTECanada

BIOTECanada’s written submission to the Parliamentary Standing Committee on Health (HESA) meeting on Pharmacare Bill C-64 for consideration

May 25, 2024
Standing Committee on Health
Sixth Floor, 131 Queen Street
House of Commons
Ottawa ON K1A 0A6

Submission on Bill C64 An Act respecting pharmacare

BIOTECanada offers comments on the proposed legislation with a focus on ensuring the needs of patients, particularly those with current barriers of access to safe, effective medicines and ensure they have the benefit of timely treatments. The landscape of public policy issues currently facing the entire Canadian healthcare system is complex and generating extensive public concern regarding the ability of the system to meet patient needs.

As providers of today’s game changing, and in many cases now lifesaving medicines and
therapies, the biotechnology sector in Canada regards the needs of patient care paramount in all the sector’s representations made to governments at all levels. This is particularly relevant as the world of medicine is changing rapidly, with the system seized with delivering the new, complex therapies forthcoming from throughout the sector, including gene and cell therapies,
combination biologics and many others. Canada needs to address the long-standing issue of
delays in listing new medicines for physicians and their patients to actually access and seek to
match the performance of our global peers.

BIOTECanada is concerned Bill C-64, An Act Respecting Pharmacare is a piecemeal and
uncoordinated approach to addressing gaps in healthcare coverage which risks disrupting the
current balance of public and private programs for drugs. This disruption will have significant
implications for Canadian patients at a critical time when remarkable new drugs and drug
technologies are emerging from the biotech sector, including those being developed by
Canadian biotech companies.

There currently exists a series of processes and analysis applied to medicines entering the
Canadian spectrum of care, each of which addresses the value and cost of those medicines.
Adding another potentially limiting formulary process to address gaps which could in fact be
addressed by the existing processes already in place, may jeopardize the intent of the
government to fill the existing deficits of care. It is important for the system of care, already
complicated and lengthy, not endure any further constraints on its ability to adopt and benefit
from new solutions to improve care for Canadian patients.

The goal for regulators, payers, innovators and federal and provincial governments alike, should be a streamlined system of regulatory and health technology assessment aimed at delivering access to the best of new, life changing therapies, to meet the dynamic of scientific innovation in a safe, timely and effective manner. In this context, initiatives such as pharmacare must ensure Canada remains at the forefront of a regulatory system designed to meet patient needs, while adapting to the scientific discoveries imminent throughout the sector.


Recommendation 1: The Government of Canada should build on Canada’s extensive existing
coverage instead of replacing it with limited public formularies.

Ensuring Canadian patients have timely, efficient and fair access to the medicines they need is
imperative for all Canadians. The current framework of the pharmacare legislation suggests
creating yet another stream of decision making that will undoubtedly add further confusion,
potentially stress the system of care with administrative requirements outside of existing
processes, and ultimately have limited effect for those in need of care. Rather than creating a
separate new system, federal investment and intervention should in fact build on the existing
systems already in place, with the ambition of streamlining and simplifying methods of access to care.

Recommendation 2: The federal government needs to work to improve and accelerate access to new medicines and strengthen Canada’s life sciences environment to attract clinical trials and promote research and development. With hundreds of world leading technologies and products being developed in Canada, the future of health care outcomes brings much promise. The ecosystem supporting that work is comprised of academic, research hospitals, small and emerging companies and global commercial companies each contributing with research, expertise or investment. The global competition for this work has grown to unprecedented levels. Canada needs to ensure it does not create any potential negative impacts on the ecosystem.


BIOTECanada is the national industry association with 240 members representing the broader
Canadian biotech ecosystem including start up and emerging companies, research organizations, established commercial companies, academic and research organizations and investors, all dedicated to developing modern science-based solutions to improve human health, food security, and our environment. BIOTECanada continues to work to represent the opportunities for Canada to modernize its healthcare system using the best of new technologies and solutions emanating from throughout the Canadian ecosystem and global network of researchers, entrepreneurs and manufacturers building the solutions patients need today and in the future.