Time, information needed for public consultation on drug price control
LETTER | While Malaysians are increasingly concerned about rising prices for basic necessities, the issue of drug prices seems to have escaped public attention.
A public consultation on the effect of price controls on medicines is currently underway. I would like to draw the public’s attention to this and urge the public to participate in this process by expressing their comments and concerns on this issue.
The public comment period began on November 29, 2021 and will end on December 6, 2021, too short a period for such an important topic, in my opinion.
The public consultation focuses on the preliminary results of a cost-benefit assessment (CBA) of the implementation of drug price control proposed by the Ministry of Health (MOH).
The CBA is coordinated by the Malaysian Productivity Corporation (MPC), a statutory body under the Ministry of International Trade and Industry (Miti), with the collaboration of several government agencies, economists and private industry groups such as the ‘Pharmaceutical Association of Malaysia (Phama), Association of Private Hospitals of Malaysia (APHM) and, oddly enough, Pharmaceutical Research & Manufacturers of America (PhRMA).
This collaboration was governed by a steering committee chaired by the deputy general secretary of Miti and a technical committee chaired by the deputy general manager of MPC and a representative of the industry of Pama. The study was conducted by an anonymous third-party consultant.
A single public consultation document summarizing ACA’s preliminary findings has been posted for review. A public webinar was also hosted by the MPC on December 1, 2021, during which a reading of the consultation document was held, followed by a short question-and-answer session.
Public consultation takes time, transparency and information
The ACB’s preliminary findings suggest that the implementation of drug price controls will have a negative effect on the private health sector and the Malaysian economy as a whole.
Preliminary results also suggest that the negative impact will outweigh the positive benefits of drug price controls.
In reaching this conclusion, the ACA included an impressive array of potential negative impacts, including reduced profit margins for the pharmaceutical industry and private hospitals, large-scale closures of general practice clinics and private hospitals. , and a reduction in medical tourism, and compared it against what appears to be a unique benefit, which is patient savings.
It is not clear from the public consultation document whether other potential benefits were considered, such as lives saved, better health outcomes, increased productivity through better health, better quality of life, savings in public health expenditure, or even an increase in expenditure in other economic sectors due to the reduction in direct health expenditure.
The public consultation document also lacks technical information on some of the assumptions and the data on which the conclusions are based.
I believe that a public consultation requires ample time, transparency and information to be provided to the public before conclusions can be drawn.
I strongly urge the MPC, MITI, and the CBA Steering and Technical Committees to make public the full CBA technical report and data, along with a full description of the methodology and assumptions used.
This is to allow the results to be examined and validated in order to reassure the public.
As the topic has a huge impact on public health and accessibility of healthcare, I would also recommend that all members of the CBA technical committee provide full information and conflict of interest statements to the public.
Finally, I once again urge the MPC to extend the public comment period and encourage members of the public to participate in this public consultation process and to voice their concerns and comments.
The website for the public consultation can be found here.
MARK CHEONG WING LOONG is Senior Lecturer at the School of Pharmacy, Monash University Malaysia.
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