On April 15, 2021, the Regulation respecting exceptions to the prohibition against paying or reimbursing the price of a medication or supply covered by the basic prescription drug insurance plan came into force.
The purpose of this Regulation is to set out the exceptions to the newly implemented ban on a commercial practice preventing manufacturers, wholesalers and other intermediaries in the drug supply chain from paying or reimbursing anyone covered by the basic prescription drug insurance plan for the price of a medication or supply covered by this plan (section 80.2 to the Act respecting prescription drug insurance).
Financial assistance is therefore permitted only in the following circumstances:
- when the medication is included on the List of Medications but is not subject to the lowest price method;
- when no generic or biosimilar version is listed; or
- when a person covered by the basic plan was already benefiting from such financial treatment for this medication before April 15, 2021.
On May 19, 2021, the Régie de l’Assurance Maladie du Québec (RAMQ) issued a Q&A confirming that the following financial assistance is prohibited: co-pay cards, rebate on invoices, reimbusement of the price of a medication or supply, and free doses (bridging). This prohibited practice is therefore expected to impact patient support programs. Read the full infoletter here (in French).
On July 23, 2021, the RAMQ confirmed that this prohibition on financial assistance does not apply to biologics and biosimilars since they are not subject to the lowest price method. Therefore, financial assistance is permitted. Read the full infoletter here (in French).