Position Statement of The Hong Kong Association of the Pharmaceutical Industry
The Introduction of a Standard Drug Formulary in Hong Kong
Background
Founded in 1968, members of The Hong Kong Association of the Pharmaceutical Industry (the Association) include the top 20 global pharmaceutical companies. Over 70% of the prescription medicines used in Hong Kong is supplied by our members. The Association aims to enhance public health of Hong Kong citizens through recommendations to local healthcare policy-makers on behalf of the pharmaceutical industry.
Our Position
In principle, the Association supports the government’s initiative to launch the Standard Drug Formulary (SDF). However, the Association emphasizesthat the development and review process for the drug formulary should be transparent and conducted in consultation with involved parties. Moreover, to ensure that patients can effectively access the needed medication, the introduction of the formulary should be supported by a clearly defined mechanism for purchasing self-financed drugs. The following points outline the Association’s position and recommendations on the SDF.
1. As the Hospital Authority (HA) has reiterated that SDF is not a cost-cutting policy, drugs should not be excluded from the standard list simply because they are more expensive or only have preliminary medical evidence. Clinical efficacy and benefits for patients should be the most important paramount consideration.
Innovative, new evidence-based drugs that demonstrate efficacy with fewer side-effects should be introduced and available to physicians and patients. Clinical outcome should be the primary concern when evaluating the introduction of a drug. In addition, we oppose the concept of ‘therapeutic substitution’. The use of generic, older and less effective drugs with more side effects should not be encouraged for the sake of cost containment.
2. SDF should contribute towards standardizing the drug procurement and supply policy in public hospitals. This ensures equitable treatment for patients with the same diseases. It also simplifies the administrative procedures within hospitals and the working relationship between hospitals and the pharmaceutical industry. Apparently, this is not the case as the cluster DTCs will continue to draw up their own drug lists instead of simply referring to the SDF drawn up by the HA Head Office.
The diagram below illustrated the drug purchasing process at present:
Clearly, the role of DTC within clusters basically overlaps with the role of the DAC, thus creating further barriers for the introduction of the new drug.
Instead, we recommend that the role of units involved in the drug purchasing process should be defined as follows:
DAC:Only evaluates the safety and efficacy of pharmaceutical products which have already been approved for sale and use in Hong Kong. All approved drugs will automatically become an SFI item (Non-standard list without safety net)
PFMT:only evaluate the cost-effectiveness of drugs and categorize them as follows:
1) HA standard drug, provided by HA
2) Specialty Drug, subsidized by indications
3) Non-standard list with safety net;
4) Self-financed items
DTC:This step should be removedsince the DAC has approved all drugs.
3. The compilation and review of SDF should be conducted in a transparent manner with active participation from the concerned stakeholders. Channels and mechanisms of communication should be established so that no decision concerning the SDF will be taken without thorough public consultation.
The Association believes that the government should publicize the selection criteria and the guiding principles by which different drugs are classified and prescribed. The patients, the public, and the industry needs to have a clear understanding of the process to avoid confusion and build confidence especially on the principle of using Specialty Drugs.
Aside from consulting with internal medical professions and experts, the HA should also consult with patients’ group, specialists in private practice, pharmacists, and representative from the pharmaceutical industry. Reviews and changes to the standard drug formulary should be representative and should address the need of community. This will ensure that the standard drug formulary comprehensively takes into account the needs of patients, the autonomy of doctors in drug prescription, and the supply of pharmaceutical products.
In addition, we recommend establishing an appeal system for drugs marked for deletion from SDF to ensure potential concerns from patients and stakeholders are addressed thoroughly.
4. Logistics: Appropriate logistical arrangements should be in place before a drug is taken out of the standard list. The HA should ensure that a clear mechanism exists whereby patients can become aware of these drugs to make educated choices, and for patients to have convenient access to those ‘self-financed items’.
The whole arrangement should be joint planned by the HA, the pharmaceutical industry, community drug stores and pharmacists, and patient groups. Patients' interests will be protected only if a drug taken out of the standard list is readily informed as well as available in the market. The pharmaceutical industry of Hong Kong will be able to better ensure that the supply of drugs can meet public demand if the mechanism can be well established, and the industry is well-informed before implementation.
5. Drug education: It is also our concern that patients mayface difficulties when they have to rely more on themselves to access drugs outside the HA system.
We call upon the HA, the pharmaceutical industry, the medical profession, the community drug stores, and the patient groups to work closely together to provide effective health and drug education to patients.