Patented Medicine Prices Review Board Regulatory Affairs and Outreach Branch Outreach Sessions Montreal, November 22, 2012 Toronto, November 23, 2012 Overview Regulatory Filing – Latest Changes Form 1 Form 2 Block 1, 2, 3 Interim Maximum Average Potential Price (MAPP) DIP Methodology Simplified Regular PMPRB 101 2 Regulatory Filing Latest Changes in Form 1 and Form 2 Block 1, 2, 3 3 Changes in Form 1 FORM 1 MEDICINE IDENTIFICATION SHEET Pate n te d Me di ci n e Pri ce s Re vi e w Board Pri vi l e ge d s.87 Patent Act Use one form per DIN P lease Specify: or Original Filing - - Complet e all Blocks Amendment t o Original Filing - - Complet e all Blocks and specify which Block(s) is(are) amended __________ 1 NAME(S ) AND US E(S ) OF THE MEDICINE Brand Name: Generic Name: T herapeut ic use(s) of t he medicine approved by Healt h Canada: Hu man Pre scri pti on (The m e dic ine is fo r hum a n us e a nd c o nta ins a c o ntro lle d s ubs ta nc e a s de fine d in the C o ntro lle d Drugs and S ubs tanc e s A c t o r c o nta ins a s ubs ta nc e lis te d o r de s c ribe d in S c he dule s C o r D to the Fo o d and Drugs A c t o r in S c he dule F to the Fo o d and Drug R e gulatio ns ) OR Hu man O ve r-th e -C ou n te r OR Ve te ri n ary 4 (The m e dic ine is fo r hum a n us e a nd do e s no t c o nta in a c o ntro lle d s ubs ta nc e a s de fine d in the C o ntro lle d Drugs and S ubs tanc e s A c t o r do e s no t c o nta in a s ubs ta nc e lis te d o r de s c ribe d in S c he dule s C o r D to the Fo o d and Drugs A c t o r in S c he dule F to the Fo o d and Drug R e gulatio ns ) Changes in Form 1 2 PATENTEE Patentee Name Patentee Address Identity if the the patent holder patentee is: person entitled to the benefits of a patent or to exercise any rights in relation to a patent 3 NOTICE OF COMPLIANCE (N.O.C.) First N.O.C. Y M D Check if Special Access Programme applicable or Clinical T rial Application or Investigational New Drug 4 DRUG IDENTIFICATION NUMBER (DIN) Drug Identification Number 5 Dosage Form Strength/Unit Changes in Form 1 5 DATE OF FIRS T S ALE 6 PRODUCT MONOGRAPH (check only one box) Product Monograph OR Date of 1st Sale Y M D Information similar to that contained in a Product Monograph (Copy Included) (Copy Included) 7 PATENT NUMBER OF PATENTEE'S INVENTIONS PERTAINING TO THE MEDICINE Patent Number Numeric only 6 Date Granted Y M Expiration Date D Y M D Changes in Form 1 8 CERTIFIED BY: (in accordance with Section 7 of the Patented Medicines Regulations ) I hereby certify that the information presented is true and correct. Signature of duly authorized person for the reporting patentee. Name: T itle: Organization: Date: T el. Number: ( ) Fax Number : ( E-mail: Please send completed Form 1 to compliance@pmprb-cepmb.gc.ca 7 ) Changes in Form 2, Block 1, 2, 3 FORM 2 INFORMATION ON THE IDENTITY AND PRICES OF THE MEDICINE Patented Medicine Prices Review Board Privileged s.87 Patent Act Cover Sheet : Block 1, 2, 3 Please Specify or Original Filing Complete Block 1 and 3 Amendment to Original Filing Complete Block 2 and 3 BLOCK 1 : ORIGINAL FILING REPORTING PERIOD Period to which the information applies (only one reporting period per Form): NAMES OF THE MEDICINE Brand name of the medicine Generic name of the medicine 8 FROM Y TO M D Y M D Changes in Form 2, Block 1, 2, 3 BLOCK 2 : AMENDMENT TO AN ORIGINAL FILING REPORTING PERIOD Period to which the information applies (only one reporting period per Form): FROM Y TO M D Y M BLOCK(s) and DIN(s) or ASSIGNED NUMBER(s)THAT ARE AMENDED Check Block(s) that is(are) amended : Block 4 Block 5 9 For each Block, list DIN(S) or Assigned Number(s) that is (are) amended. Write one DIN per cell. D Changes in Form 2, Block 1, 2, 3 BLOCK 3 : PATENTEE * AND CERTIFYING SIGNATURE Patentee Name Patentee Address *Please see section 79(1) of the Patent Act for the definition of a "patentee". Note that a patentee is any person entitled to the benefits of a patent or to exercise any rights in relation to a patent. This includes patent holders, licensees or others. in accordance with Section 7 of the Patented Medicines Regulations I hereby certify that the information presented is true and correct. Signature of duly authorized person for the reporting patentee Name: T itle: Organization: Date: T el. Number: ( ) Fax Number : ( E-mail: Please send completed Form 2 including the cover sheet, Block 4 and Block 5 to: compliance@pmprb-cepmb.gc.ca 10 ) Interim Maximum Average Potential Price (MAPP) 11 Interim MAPP Compendium of Policies, Guidelines and Procedures, Schedule 5, Section 1.3 1.3 When the new patented drug product is sold in fewer than five countries at the time it is first sold in Canada, the median international price will be calculated on an interim basis. At the end of three years or when the same patented drug product with the same strength and dosage form is sold in at least five countries, whichever occurs first, Board Staff will re-determine the median international price. Whenever this occurs, the drug product’s Non-Excessive Average Price will be the lower of: (a) The re-determined median international price, and (b) The Non-Excessive Average Price derived from the ordinary application of the CPI-Adjustment Methodology (see Schedule 9). 12 MIPC in Introductory Price Tests Level of Therapeutic Improvement Breakthrough Substantial Improvement Moderate Improvement Introductory Price Tests MIPC Higher of: - Top of TCC - MIPC Higher of: - Mid point (Top of TCC and MIPC) - Top TCC Top of TCC Slight/No Improvement Lower of: - Bottom of TCC - MIPC 13 If no comparator is identified Or if price of comparator is excessive Or if cannot derive dosage regimen Or If no public price is found MIPC Interim MAPP: Example 1 (MIPC) Drug product A introduced in March 2010 Pivotal test establishing the MAPP at introduction : Median International Price Comparison (MIPC) test In 2010, Drug product A is sold in Italy ($10) and in the US ($20) Interim MIPC = Interim MAPP (2010) = $15 14 Interim MAPP: Example 1 (MIPC) Scenario 1: Three years (2013) In 2011, 2012 and 2013, drug A still sold in only 2 countries MIPC = $15 Post-Interim MAPP is set by MIPC 2013 N-NEAP (based on CPI-Adjustment Methodology) = $14 Post-Interim MAPP (2013) = $15 Final 2013 N-NEAP = $14 Impact on future requests for DIP application: IBP remains at $15 15 Interim MAPP: Example 1 (MIPC) Scenario 2: Five countries (lower PI-MAPP) In 2012, Drug product A is now sold in 5 countries: Italy ($10), France ($10), Germany ($10), Switzerland ($10), US ($20) MIPC = $10 Post-Interim MAPP is set by MIPC N-NEAP (based on CPI-Adjustment Methodology) in 2012 is $13 Post-Interim MAPP (2012) = $10 Final 2012 N-NEAP = $10 If 2012 N-ATP > Final 2012 N-NEAP, Company is given one year to adjust N-ATP to be ≤ 2013 N-NEAP (2012 N-NEAP + CPI) Impact on future requests for DIP application: IBP reset in 2012 to $10 16 Interim MAPP: Example 1 (MIPC) Scenario 3 : Five countries (higher PI-MAPP) In 2012, Drug product A is now sold in 5 countries: Italy ($10), France ($17), Germany ($17), Switzerland ($17), US ($20) MIPC = $17 Post-Interim MAPP is set by MIPC N-NEAP (based on CPI-Adjustment Methodology) in 2012 is $13 Post Interim MAPP (2012) = $17 Final 2012 N-NEAP = $13 Impact on future requests for DIP application: IBP remains at $15 17 Interim MAPP: Example 2 (Higher of TCC and MIPC) Drug product A introduced in March 2010 Level of therapeutic improvement : Substantial Improvement Test establishing the MAPP at introduction : Higher of top of Therapeutic Class Comparison (TCC) test and the MIPC test In 2010, top of TCC = $10 A is sold in Italy ($10) and in the US ($20) Interim MIPC = $15 In this case, the Interim MAPP is set by the Interim MIPC Interim MAPP (2010) = $15 18 Interim MAPP: Example 2 (Higher of TCC and MIPC) Scenario 1 : Three years (2013) Drug product A still sold in only 2 countries. MIPC =$15 Post-Interim MAPP is set by MIPC N-NEAP (based on CPI-Adjustment Methodology) = $14 Post-Interim MAPP (2013) = $15 Final 2013 N-NEAP = $14 Impact on future requests for DIP application: IBP remains at $15 19 Interim MAPP: Example 2 (Higher of TCC and MIPC) Scenario 2 : Five countries (lower PI-MAPP) In 2012, Drug product A now sold in 5 countries: Italy ($10), France ($9), Germany ($9), Switzerland ($9), US ($20) MIPC = $9 Post-Interim MAPP is set by TCC ($10) N-NEAP (based on CPI-Adjustment Methodology) in 2012 is $13 Post-Interim MAPP (2012) = $10 Final 2012 N-NEAP = $10 If 2012 N-ATP > Final 2012 N-NEAP ($10) Company will be given one year to adjust N-ATP to be ≤ 2013 N-NEAP (2012 N-NEAP + CPI) Impact on future requests for DIP application: IBP reset in 2012 to $10 20 Interim MAPP: Example 2 (Higher of TCC and MIPC) Scenario 3 : Five countries (higher PI-MAPP) In 2012, Drug product A now sold in 5 countries: Italy ($10), France ($17), Germany ($17), Switzerland ($17), US ($20) MIPC = $17 Post-Interim MAPP is set by MIPC N-NEAP (based on CPI-Adjustment Methodology) in 2012 is $13 Post-Interim MAPP (2012) = $17 Final 2012 N-NEAP = $13 Impact on future requests for DIP application: IBP remains at $15 21 Interim MAPP: Example 3 (Higher of TCC and Mid Point) Drug product A introduced in March 2010 Level of therapeutic improvement : Moderate Improvement Test establishing the MAPP at introduction : Higher of top of TCC test and Mid Point (Average of top of TCC and MIPC) In 2010, Top of TCC = $10 Drug product A is sold in Italy ($10) and the US ($20) Mid Point = $12.50 Interim MAPP is set by Mid Point Interim MAPP (2010) = $12.50 22 Interim MIPC = $15 Interim MAPP: Example 3 (Higher of TCC and Mid Point) Scenario 1: Three years (2013) Drug product A is still only sold in 2 countries MIPC =$15 Mid Point = $12.50 Post-Interim MAPP is set by Mid Point N-NEAP (based on CPI-Adjustment Methodology) in 2013 is $13 Post-Interim MAPP (2013) = $12.50 Final 2013 N-NEAP = $12.50 If 2013 N-ATP > Final 2013 N-NEAP ($12.50) Company will be given one year to adjust N-ATP to be ≤ 2014 N-NEAP (2013 N-NEAP + CPI) Impact on future requests for DIP application: IBP remains at $12.50 23 Interim MAPP: Example 3 (Higher of TCC and Mid Point) Scenario 2: Five countries (lower PI-MAPP) In 2012, Drug product A now sold in 5 countries: Italy ($10), France ($9), Germany ($9), Switzerland ($9), US ($20) MIPC = $9 Mid Point = $9.50 Post-Interim MAPP is set by TCC ($10) N-NEAP (based on CPI-Adjustment Methodology) in 2012 is $13 Post-Interim MAPP (2012) = $10 Final 2012 N-NEAP = $10 If 2012 N-ATP > Final 2012 N-NEAP ($10) Company will be given one year to adjust N-ATP to be ≤ 2013 N-NEAP (2012 N-NEAP + CPI) Impact on future requests for DIP application: IBP reset in 2012 to $10 24 Interim MAPP: Example 3 (Higher of TCC and Mid Point) Scenario 3: Five countries (higher PI-MAPP) In 2012, Drug product A now sold in 5 countries: Italy ($10), France ($17), Germany ($17), Switzerland ($17), US ($20) MIPC = $17 Mid Point = $13.50 Post-Interim MAPP is set by the Mid Point N-NEAP (based on CPI-Adjustment Methodology) in 2012 is $13 Post-Interim MAPP (2012) = $13.50 Final 2012 N-NEAP = $13 Impact on future requests for DIP application: IBP remains at $12.50 25 Interim MAPP – Meaning and implications - A MAPP based on any test that includes a MIPC test is interim when the MIPC is based on data from less than 5 countries. - A post interim MAPP is calculated 3 years after intro or when the drug product is sold in five countries, whichever comes first. - The final N-NEAP will be the lower of the post-interim MAPP and the N-NEAP based on the CPI-Adjustment Methodology 26 DIP Methodology 27 Simplified DIP Methodology: Reminders 28 Patentee acquires DIN from previous patentee prior to January 1, 2010: patentee to obtain original IBP from previous patentee for DIP applications Benefits at introduction: consider reporting transactions with and without benefits on separate lines in Form 2 Block 4 Pay attention to Form 2 Block 5 Canada price 2003 2004 2005 2006 Form 2 Block 5 Canada $20.00 $16.00 $16.00 $16.00 N-ATP $20.00 $12.00 $12.00 $20.00 IBP/IBP* $20.00 $16.00 $16.00 $16.00 Regular DIP Methodology: Calculation of IBP* Block 5 Canada price increase < annual (one year) CPI Use lower of : annual (one year) CPI and % increase of Form 2 Block 5 Canada price 2008 2009 2010 $0.8284 $0.8284 $0.8391 $0.8391 $0.8533 % Bl5 increase 2.5% 1.3% % annual CPI 2% Form 2 Bl5 Canada 29 2005 2006 $0.8085 2007 2.1% 1.7% 2.4% 0.3% 1.8% IBP/IBP* $0.8085 $0.8101 $0.8101 $0.8206 $0.8206 $0.8346 N-ATP $0.8085 $0.7958 $0.7724 $0.7277 $0.7304 $0.8300 N-NEAP $0.8085 $0.8247 $0.8213 $0.8002 $0.7313 $0.7501 Regular DIP Methodology: Calculation of IBP* No increase in Form 2 Block 5 Canada price for at least 3 years Use lower of: Cap % increase in Form 2 Block 5 Form 2 Bl5 Canada 30 2005 2006 2007 $0.8085 $0.8284 $0.8284 2008 2009 2010 $0.8284 $0.8284 $0.8533 % Bl5 increase 2.5% 3% % annual CPI 2% 2.1% 2.4% 0.3% 1.8% Cap 3% 3.2% 3.6% 0.5% 2.7% IBP/IBP* $0.8085 $0.8101 $0.8101 $0.8101 $0.8101 $0.8320 N-ATP $0.8085 $0.7958 $0.7724 $0.7277 $0.7304 $0.8300 N-NEAP $0.8085 $0.8247 $0.8213 $0.8002 $0.7313 $0.7501 Regular DIP Methodology: Calculation of IBP* When Form 2 Block 5 Canada price increases every year, CPI-Adjustment Methodology considered. 2008 2009 2010 $0.8284 $0.8450 $0.8872 $0.8961 $0.9158 % Bl5 increase 2.5% 2% 2% 0.3% 2.2% % annual CPI 2% 2.1% 2.4% 0.3% 1.8% % Cap 3% 3.2% 3.6% 0.5% 2.7% % CPI Adj. Factor 2% 4.2% 6.6% 4.9% 4.5% Form 2 Bl5 Canada 2005 2006 $0.8085 2007 IBP/IBP* $0.8085 $0.8247 $0.8412 $0.8580 $0.8606 $0.8791 N-ATP $0.8085 $0.7958 $0.7724 $0.7277 $0.7304 $0.8300 N-NEAP $0.8085 $0.8247 $0.8213 $0.8002 $0.7313 $0.7501 2010 CPI 0.8412 X 1.045 = 0.8791 CAP 0.8606 X 1.027 = 0.8838 % Bl5 increase 0.8606 X 1.022 = 0.8795 31 PMPRB 101 32 PMPRB 101 33 Where? PMPRB office, 14th floor, 333 Laurier Avenue West, Ottawa When? December 6, 2012 from 10:00 a.m. to 3:30 p.m. For whom? Employees from pharmaceutical companies who need to understand PMPRB basic operations such as filing, calculation of intro prices and ongoing NEAPs What? Introduction to PMPRB processes Overview of Filing Session for PMPRB 101 • The different forms that need to be filed • Section 82: Notification of Intent to Sell • Form 1 • Form 2 • Filing timelines • Reporting process 34 Overview of Filing Session for PMPRB 101 • Failure to File • Common filing errors • Compliance Status Reports • Where to find the forms on the PMPRB website 35 Overview of the Introductory Price Analysis Scientific Review Submission Process for Scientific Data on New Drug Products Human Drug Advisory Panel (HDAP) Scientific Review Process 36 Levels of Therapeutic Improvement Selection of Comparators Selection of Dosage Regimens Overview of the Introductory Price Analysis Introductory Price Review Introductory Price Tests Median International Price Comparison (MIPC) Therapeutic Class Comparison (TCC) Mid-point Reasonable Relationship (RR) Highest International Price (HIPC) Criteria for Investigation at Introduction Communication of Results to Patentees 37 PMPRB 101 Let’s Talk Numbers Price Review of Existing Medicines • • 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 38 Communication with Board Staff Query to PMPRB Staff Guidelines: Ginette Tognet Tel: (613) 954-8297 E-mail: ginette.tognet@pmprb-cepmb.gc.ca Scientific and new meds: Catherine Lombardo Tel: (613) 952-7620 E-mail: catherine.lombardo@pmprb-cepmb.gc.ca Filing Form 1 and 2: Beatrice Mullington Tel: (613) 952-2924 E-mail: beatrice.mullington@pmprb-cepmb.gc.ca Investigation: Senior Regulatory Officer assigned to Company Form 3: Lokanadha Cheruvu Tel: (613) 954-9812 E-mail: lokanadha.cheruvu@pmprb-cepmb.gc.ca Website: Carol McKinley Tel: (613) 960-4550 E-mail: carol.mckinley@pmprb-cepmb.gc.ca All other questions: 1-877-861-2350 39 pmprb@pmprb-cepmb.gc.ca