GroupNews – July 2021

Eckler’s GroupNews monthly newsletter provides commentary on the issues affecting Canadian group benefit plans.

In this edition:

• Health Canada announces further delays to drug pricing regulations
• Quebec releases RAMQ rates effective July 1, 2021
• Nova Scotia expands cancer support programs
• Federal Budget Bill C-30 receives Royal Assent
• Federal government introduces Bill C-35, Canada Disability Benefit Act
• Prescription medication use in Canada
• Canadian Institute of Actuaries: Pharmacare – Is There a Pill for That?

Benefit plan management

Health Canada announces further delays to drug pricing regulations

Health Canada has announced that it will delay changes to Canada’s drug pricing regime for a further six months in order to allow pharmaceutical companies time to prepare for the changes. In response to requests for more time to respond to the proposed changes, Health Minister
Patty Hajdu announced the regulations will be delayed until January 1, 2022.

The Patented Medicine Prices Review Board  (PMPRB) regulations govern the steps taken by the PMPRB when assessing whether a patented medicine appears to be priced excessively in the Canadian market, and the required information patent-holding companies in Canada must provide to the PMPRB in order to assess pricing. The regulations are the result of consultations with interested stakeholders that began in November 2019, with draft guidelines released in July 2020. Health Canada first postponed the regulations until July 1, 2021, to provide pharmaceutical manufacturers with additional time to make changes required by the new reporting requirements.

Impact: The regulations are intended to protect Canadian consumers and plan sponsors from excessive drug prices. Lower drug costs will help workplace benefit plans remain sustainable in the face of more specialized, potentially high-cost drugs. The delay may prove costly for plan sponsors, especially now that discussions between the government and interested stakeholders have resulted in further delays past July 2021.

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Benefit plan management

Quebec releases RAMQ rates effective July 1, 2021

Every year, on July 1, the Régie de l’assurance maladie du Québec (RAMQ) sets the rates for the Public Prescription Drug Insurance Plan for the plan year. However, to minimize the financial consequences caused by COVID-19, the RAMQ rates were also adjusted for the period from January 1 to June 30, 2021.

The table below summarizes the old rates (effective January 1 to June 30, 2021) and new rates effective
July 1, 2021, to June 30, 2022. Any changes made are in bold.

Impact: While both the RAMQ monthly deductible and the co-insurance payments remain stable, the maximum monthly contributions and premiums have increased. Changes to the RAMQ rates generally do not materially affect private plan costs as active members of private drug plans are not eligible for coverage under RAMQ before they reach age 65. Residents over age 65 who are eligible for drug coverage under a private plan have a choice between their private plan and RAMQ, with private plan sponsors having the ability to charge for opting out of RAMQ; changes in the RAMQ premiums could influence that charge.

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Benefit plan management

Nova Scotia expands cancer support programs

The government of Nova Scotia is expanding support for cancer care in the province through the Nova Scotia Cancer Care Program. The announcement made on July 5, 2021 will:

• Establish a CAR T treatment program ─ a potentially curative method of immunotherapy that modifies immune cells (T cells) to help fight cancer ─ allowing eligible adult lymphoma patients who might otherwise seek treatment in the United States to receive treatment close to home;
• Increase the household income threshold for the existing Boarding, Transportation and Ostomy and Drug Assistance for Cancer Patients program from $25,500 to $35,000; and
• Increase the travel rate in the Boarding, Transportation and Ostomy program from $0.20/km to $0.45/km.

Nova Scotia is the only province in Atlantic Canada to offer CAR T therapy to help recognize and fight cancer. According to the Nova Scotia Minister of Health and Wellness, discussions are underway with other Atlantic provinces about the possibility of expanding access to CAR T therapy/treatment to those provinces.

Impact: As the Drug Assistance for Cancer Patients program helps those without drug coverage access certain cancer-related drugs, the change is not expected to have any significant impact on private plan sponsors. However,  the expanded program will help to reduce out-of-pocket costs for travel, accommodation, ostomy supplies and cancer drugs for patients.

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Legal and legislative news

Federal Budget Bill C-30 receives Royal Assent

On June 29, 2021, Bill C-30, An Act to implement certain provisions of the budget tabled in Parliament on April 19, 2021 and other measures received Royal Assent. Bill C-30 enacts several measures proposed in the 2021 Federal Budget, the first full budget released in almost two years.

Measures enacted by Bill C-30 include:

• The extension of several COVID-19 relief programs, including income support programs (Canada Recovery Benefit and Canada Recovery Caregiving Benefit) and subsidies (Canada Emergency Wage Subsidy and Canada Emergency Rent Subsidy) for employees and employers;
• Funding to enhance the maximum payment period for sickness benefits from 15 to 26 weeks, plus amendments to the Employment Insurance Act and Canada Labour Code to ensure that workers in federally regulated industries have the job protection they need while receiving EI sickness benefits; and
• Amending the employee life and health trust rules to allow for the conversion of health and welfare trusts to employee life and health trusts.

Further regulations are expected to provide additional direction to stakeholders with respect to the measures enacted by Bill C-30.

Impact: Plan sponsors who currently provide a disability program that is integrated with the EI disability plan will be positively impacted by this proposal as the public plan picks up a greater portion of the total benefit payments. However, those plan sponsors providing a comparable disability program and taking advantage of available EI premium reductions will potentially have to increase their maximum period for sickness benefits up to 26 weeks, depending on the design of their STD/ LTD programs. Once the regulations are known, plan sponsors are encouraged to review the design of their disability programs holistically to ensure compliance. GroupNews will monitor the progress of this Bill and report in future editions.

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Legal and legislative news

Federal government introduces Bill C-35, Canada Disability
Benefit Act

The federal government has introduced Bill C-35, An Act to reduce poverty and to support the financial security of persons with disabilities by establishing the Canada disability benefit and making a consequential amendment to the Income Tax Act.  Bill C-35 establishes the Canada Disability Benefit to “reduce poverty and to support the financial security of working age persons with disabilities.”

Bill C-35 is the first step in the government’s Disability Inclusion Action Plan, with one of the stated goals to create a new benefit to support working age Canadians with disabilities. The proposed Canada Disability Benefit will provide supplemental financial support along with existing federal and provincial programs for Canadians.

The government plans to meet with provincial ministers and interested stakeholders to determine the design of the new benefit. According to government surveys, nearly 21% of working age Canadians with disabilities currently live in poverty.

The government also announced that public consultations on its Disability Inclusion Action Plan will be open until August 31, 2021. Canadians are encouraged to complete the online survey and share their views, to help guide the development of the Plan.

Impact: Canadians with disabilities were particularly affected by financial pressures due to the COVID-19 pandemic. The Canada Disability Benefit will provide supplemental income and help provide the impetus for Canadians with disabilities to recover financially.

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Research

Prescription medication use in Canada

New research from Statistics Canada examines the use of prescription medications among adults in Canada from 2016 to 2019. The study, Prescription medication use among Canadian adults, 2016 to 2019 surveyed adults between 18 to 79 years of age and reveals the wide scale use of prescription medication in the country. Below are highlights of the report.

• Fifty-five percent of adults aged 18 to 79 used at least one prescription medication in the past month, while 36% used two or more, and 24% used three or more.
• The use of prescription medication increases with age: 38% between the ages of 18 to 39 reported taking at least 1 medication, this increased to 56% for those 40 to 59 years and 81% between the ages of 60 to 79. Meanwhile, 7% between the ages of 18 to 38, 22% between 40 and 59 and 52% between 60 and 79 years of age reported taking at least three medications.
• Prescription medications used to treat high blood pressure were most commonly reported. Sixteen percent of adults reported taking prescription medication to treat high blood pressure, 12% reported taking medication for high cholesterol and 10% for a mood disorder such as depression, bipolar disorder, mania or dysthymia.

Impact: The study further reveals the pressures private benefits plans will continue to face with the use of prescription medications

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Actuaries’ corner

Canadian Institute of Actuaries: Pharmacare – Is There a Pill for That?

The Government of Canada continues to consider potential options for a national pharmacare strategy given the varying levels of prescription drug coverage available to Canadians under a mix of public and private plans. The 2021 Federal Budget, tabled on April 19, 2021, reiterated the Government’s ongoing funding of $500 million toward initiatives aimed at high-cost drugs for rare diseases but provided no further details on the potential direction for a national universal pharmacare program.

The Canadian Institute of Actuaries (CIA) strongly supports the Government of Canada’s view that no Canadian should be left without prescription drug coverage and issued a Public Statement in February 2021 entitled Pharmacare: Is There a Pill for That?. This publication suggests the best way to achieve increased health outcomes across the country is through a Canada-wide framework with elements jointly managed by the federal, provincial/territorial governments and private insurance.

Under the current health care system, approximately 19% of the Canadian population has either no prescription drug insurance or inadequate insurance to cover their medication needs and, for those with private insurance plans, the employee’s portion of costs has risen rapidly over the past decade. Furthermore, the COVID-19 pandemic has elevated the importance of improving various aspects of the current health care system, including for those Canadians who lost private coverage due to job losses.

The CIA’s proposed framework for prescription drug coverage for all Canadians is as follows:

Provincial flexibility:

• Allow provinces and territories the flexibility to design their own public drug plan and create a structure for the coordination of their public plan with the existing private drug insurance marketplace (e.g. managing high-cost drugs through prior authorization and stop loss insurance)

Oversight:

• Establish an overseeing body comprised of decision-makers from federal, provincial/territorial, insurance industry and other relevant experts to negotiate drug prices (e.g. wholesale prices and rebates offered by manufacturers, ranges of mark-ups and dispensing fees from pharmacies) on behalf of all public and private plans across Canada;
• Support the use of biosimilars and encourage patients and prescribers to choose the most cost-effective therapies to ensure the sustainability of the framework; and
• Task the overseeing body with researching improved protocols for more effective use of pharmaceuticals to help limit cost increases and improve health outcomes.

Coverage:

• Establish a national formulary to define the core and specialty medicines that will be covered, at a minimum, by all public and private plans; and
• Study and monitor the impacts of cost-sharing mechanisms on health outcomes and enforce a drug plan design to ensure the costs to patients are limited to an affordable amount.

Insurance and reinsurance:

• Private plans and provinces/territories continue to cover costs up to a certain limit and federal government to cover the costs beyond the defined limit; and
• High-cost drugs on a national formulary, including for orphan diseases, to be reinsured by the federal government on an individual basis for both public and private plans.

The CIA believes a prescription drug framework should build on what works within the private and public programs and make them better – by pooling costs at the highest level where risk can be better absorbed, by negotiating prices using the greater weight of the whole country, and by making sure that all Canadians can access the same medicines, fairly and equitably.

The full implementation of a universal pharmacare program is projected to shift between $19 billion to $26 billion annually from provincial/territorial budgets and private sector payers to the federal budget and impose $7 billion to $12 billion per year in additional costs for taxpayers, after allowing for savings from formulary adoption and price regulation. The CIA highlights the need for more consistent cost projections and argue that its proposed framework would cost taxpayers a lot less than the Hoskins Report’s proposal for pharmacare.

The CIA’s public position on this matter is that even if there are many questions and unknowns to be addressed and discussed regarding the cost, administration and mechanisms of ensuring access to affordable prescription drugs to all Canadians, steps should be taken to start gaining improvements right away instead of waiting for the “perfect plan.”

Impact: The continued progress toward a national pharmacare strategy will help enhance coverage options for Canadians and could have significant cost implications for private plans offering prescription drug benefits. The extent of the impact will depend on the size and scope of the formulary, the coverage levels and maximums, and whether the public program will be the first or the second payer of drug costs for eligible employees. The CIA highlights that starting to implement a well-managed framework that builds on the strengths of existing public and private plans can result in lower overall drug costs, better health outcomes for all Canadians, and more predictable costs for plan sponsors.

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