Feedback for Proposed Changes to the DPRA regulations

Pharmacist  ·  March 26, 2015

Regarding:

  1. Nothing in this Part prohibits a pharmacy from publishing, displaying, distributing or using, or permitting, directly or indirectly, the publication, display, distribution or use of, an advertisement that relates solely to the co-payment or dispensing fee charged by the pharmacy for supplying a drug that is a listed drug product under the Ontario Drug Benefit Act to an eligible person under that Act. O. Reg. 58/11, s. 48.

I would like to propose that discounts advertised for professional services and drug products should apply to all patients who receives the equivalent service or product and not just select and privileged groups. For example, if there is a $2.00 co-pay discount policy, it should apply to everyone with an insurance policy with a co-pay and all cash patients.

My rationale is:

1) The co-pay discount is advertised and provided only to members of the group with Ontario Drug Benefit coverage. This is promoting a discount to members of a preferred patient group to the exclusion of other groups, which is unethical. It is disallowed to create or advertise a preferred patient club (ex. CostCo pharmacy members) with rewards programs, including medication discounts. In effect, advertising this special discount creates an exclusive "ODB-eligible patients" group. This is done for the sole purpose of increasing the perception of value and competitiveness, which are financial motivations. This creates inequitable access to pharmacy services for other patients and adversely influences patient choice over pharmacist for ODB patients.

2) Many stores and chains prominently advertise co-pay waiving for ODB patients in order to appear more competitive. This may create a false perception of value for drugs dispensed to non-ODB patients. When the co-pay discount is advertised on the radio or on signs, this may mislead non-ODB eligible members of the public into thinking that the pharmacy can provide them more value than another. This may influence patient choice over their pharmacy on false pretenses.

In summary: I believe that when a pharmacy advertises a discount for a professional service or a drug product, the discount should apply to every patient who receives the equivalent service or drug product. $2 co-pay waiving is a form of price discrimination whereby drug products are discounted for an exclusive group. This creates inequitable access and adversely effects patient choice.

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