On Wednesday, September 25, 2024, Laura Syron, President and CEO and Glenn Thibeault, Executive Director of Government Affairs, Advocacy & Policy were invited to speak to the Senate Social Affairs, Science and Technology Committee about Bill C-64, An Act respecting pharmacare. Read the full remarks and recommendations below.
Thank you Chair, members of the Committee,
We know that having access to the right diabetes medications and devices reduces the risk of complications from diabetes and helps to avoid costly hospitalizations. However, these medications and devices can cost people thousands of dollars annually. In fact, based on a study by Diabetes Canada, the out-of-pocket costs – drugs, devices, supplies – for people in Canada who live with diabetes can be as high as $18,000/year if they are solely reliant on public coverage.
For at least one quarter of people living with diabetes, especially those in health equity seeking communities, these costs often mean that they can’t afford to stick with their prescribed treatment regimens, resulting in significant risks to their short and long-term health.
That’s why Bill C-64 is so important and why Diabetes Canada has been a prominent voice about it since its introduction. However, we continue to raise concerns about its implementation, just like we did this past May when we appeared before the Standing Committee on Health. At that time, we spoke to the significant gaps in coverage that unfortunately persist for individuals with diabetes in Canada, and which will continue to exist under the pharmacare program as proposed. As we appear before you today, we believe these issues have not yet been resolved.
Accordingly, we have three primary recommendations to improve Bill C-64:
Diabetes management strategies should align with Diabetes Canada’s clinical practice guidelines (CPGs), which guide healthcare providers in making informed decisions about patient care. However, the current draft formulary for diabetes medications under the pharmacare program does not align with our CPGs and is limited in scope, excluding many essential treatments and including outdated products.
We must see an expansion and update of the formulary to reflect the CPGs. To help with this, we have developed a Comparison Report that we have shared with the Committee that outlines gaps in the plan compared to both Diabetes Canada’s CPG’s, and the Non-Insured Health Benefits for First Nations and Inuit.
We therefore recommend a more developed comprehensive formulary, in consultation with people with lived experience of diabetes, healthcare experts, the provinces and territories, and Indigenous communities.
Another concern which continues to be raised by our stakeholders is the potential impact on private health coverage for diabetes medications. We must ensure that individuals do not lose access to drugs that are already covered by their private plans and are not included on the public formularies.
The Minister of Health for Canada has stated publicly his expectation that there will be no changes to Private Health Insurance coverage through this plan and the Parliamentary Budget Officer has published his findings on costs for this program based on keeping existing Private Health Insurance & Public formularies in place. However, the language in this legislation, outlining universal, single payer, first dollar, differs from those two statements.
We are therefore calling for the inclusion of a “do no harm” provision to ensure that there are no unintended consequences to those currently using private insurance coverage. Similar protections were included in the previously passed dental care legislation, which could be used as a model for this bill.
To be comprehensive, a national pharmacare program must be provided with the appropriate level of funding to ensure it covers a broad base of medications and eliminates gaps in coverage. We are therefore calling for the Government of Canada to increase and accelerate the planned budget allocation to the pharmacare program.
The initial commitment of $1.5 billion over 5 years should act as a basis of funding, not a ceiling. With the yearly cost of diabetes medications estimated to be close to $4 billion per year, the initial Budget 2024 allocation - that is split between diabetes medications and contraceptives - only provides the baseline of support that is needed.
Since the announcement of Bill C-64, we’ve seen significant goodwill across the provinces & territories, including the announcement of a Memorandum of Understanding with British Columbia. But there is more to be done. There is also more to be done when it comes to an announcement from the government regarding the launch of its Device Access Fund.
We continue to encourage Canada’s Parliament to proceed thoughtfully and with all people who live with diabetes front of mind as it develops a program to improve access to life-changing diabetes medications and devices.
Thank you Chair, members of the Committee,
We know that having access to the right diabetes medications and devices reduces the risk of complications from diabetes and helps to avoid costly hospitalizations. However, these medications and devices can cost people thousands of dollars annually. In fact, based on a study by Diabetes Canada, the out-of-pocket costs – drugs, devices, supplies – for people in Canada who live with diabetes can be as high as $18,000/year if they are solely reliant on public coverage.
For at least one quarter of people living with diabetes, especially those in health equity seeking communities, these costs often mean that they can’t afford to stick with their prescribed treatment regimens, resulting in significant risks to their short and long-term health.
That’s why Bill C-64 is so important and why Diabetes Canada has been a prominent voice about it since its introduction. However, we continue to raise concerns about its implementation, just like we did this past May when we appeared before the Standing Committee on Health. At that time, we spoke to the significant gaps in coverage that unfortunately persist for individuals with diabetes in Canada, and which will continue to exist under the pharmacare program as proposed. As we appear before you today, we believe these issues have not yet been resolved.
Accordingly, we have three primary recommendations to improve Bill C-64:
- Ensure the public formularies are fulsome, inclusive and provide a continued commitment to the improvement of care.
- Include a do-no-harm provision in the legislation, like the provision that was included in the dental care legislation.
- Provide sufficient funding in Budget 2025 and beyond to fund a comprehensive national pharmacare program for diabetes medications.
Diabetes management strategies should align with Diabetes Canada’s clinical practice guidelines (CPGs), which guide healthcare providers in making informed decisions about patient care. However, the current draft formulary for diabetes medications under the pharmacare program does not align with our CPGs and is limited in scope, excluding many essential treatments and including outdated products.
We must see an expansion and update of the formulary to reflect the CPGs. To help with this, we have developed a Comparison Report that we have shared with the Committee that outlines gaps in the plan compared to both Diabetes Canada’s CPG’s, and the Non-Insured Health Benefits for First Nations and Inuit.
We therefore recommend a more developed comprehensive formulary, in consultation with people with lived experience of diabetes, healthcare experts, the provinces and territories, and Indigenous communities.
Another concern which continues to be raised by our stakeholders is the potential impact on private health coverage for diabetes medications. We must ensure that individuals do not lose access to drugs that are already covered by their private plans and are not included on the public formularies.
The Minister of Health for Canada has stated publicly his expectation that there will be no changes to Private Health Insurance coverage through this plan and the Parliamentary Budget Officer has published his findings on costs for this program based on keeping existing Private Health Insurance & Public formularies in place. However, the language in this legislation, outlining universal, single payer, first dollar, differs from those two statements.
We are therefore calling for the inclusion of a “do no harm” provision to ensure that there are no unintended consequences to those currently using private insurance coverage. Similar protections were included in the previously passed dental care legislation, which could be used as a model for this bill.
To be comprehensive, a national pharmacare program must be provided with the appropriate level of funding to ensure it covers a broad base of medications and eliminates gaps in coverage. We are therefore calling for the Government of Canada to increase and accelerate the planned budget allocation to the pharmacare program.
The initial commitment of $1.5 billion over 5 years should act as a basis of funding, not a ceiling. With the yearly cost of diabetes medications estimated to be close to $4 billion per year, the initial Budget 2024 allocation - that is split between diabetes medications and contraceptives - only provides the baseline of support that is needed.
Since the announcement of Bill C-64, we’ve seen significant goodwill across the provinces & territories, including the announcement of a Memorandum of Understanding with British Columbia. But there is more to be done. There is also more to be done when it comes to an announcement from the government regarding the launch of its Device Access Fund.
We continue to encourage Canada’s Parliament to proceed thoughtfully and with all people who live with diabetes front of mind as it develops a program to improve access to life-changing diabetes medications and devices.