International Referenced Rate Pricing for Prescription Drugs

Public Law 2021, Chapter 606 (LD 1636), An Act To Determine Potential Savings in Prescription Drug Costs by Using International Pricing , requires the Maine Health Data Organization (MHDO) to produce an annual report beginning in January 2023 that provides information regarding potential savings that could be achieved by subjecting drugs identified as the costliest and most frequently prescribed in the State of Maine to a referenced rate as defined in the law. This is MHDO's second annual report. MHDO's first annual report can be found here: https://mhdo.maine.gov/RxReferenceRates_Historical.htm.

Definitions for Terminology Used in this Report

Brand Drug – a prescription drug, having a unique NDC, marketed under a proprietary name or registered trademark name, including a biological product, and approved under a New Drug Application or Biologics License Application.

Drug Identification Number (DIN) – a computer-generated eight-digit number assigned by Health Canada to a drug product prior to being marketed in Canada. A DIN uniquely identifies the following product characteristics: manufacturer; product name; active ingredient(s); strength(s) of active ingredient(s); pharmaceutical form; route of administration.

Generic Drug – a prescription drug, having a unique NDC, whether identified by its chemical, proprietary or nonproprietary name, that is not a brand drug, is therapeutically equivalent to a brand drug in dosage, strength, method of consumption, performance and intended use, and approved under an Abbreviated New Drug Application. Generic Drug includes a biosimilar product.

Multi-Source Drug – a brand drug or generic drug that is available from more than one manufacturer.

National Drug Code (NDC) – a code maintained by the US Food and Drug Administration that is uniquely assigned by manufacturer, product, and packaging.

Pharmaceutically Equivalent Drug Products - brand drugs and/or generic drugs that are identical in active ingredient(s), dosage form, route of administration, and strength or concentration

Prices on Canadian Provincial Formularies - represent amounts paid by payers in the province

Single Source Drug – a brand drug or generic drug that is only available from one manufacturer.

Wholesale Acquisition Cost (WAC) – a manufacturer’s published list price for sale of a prescription drug product with a unique NDC to a wholesale drug distributor or other entity that purchases a prescription drug directly from the manufacturer, not including any price concessions. WAC represents the price paid in the US to manufacturers by drug wholesalers and almost never reflects actual amounts paid by payers in the US.

Reference Rates Determined

The following provisions in statute govern the determination of referenced rates of prescription drugs.

Part I

§8741, 2. A. Identify the 100 most costly prescription drugs and the 100 most frequently prescribed prescription drugs in the State of Maine, the Manufactures of these drugs and the average wholesale acquisition cost for each drug for the most current 12-month period.

  • MHDO identified the 100 most costly generic drugs and brand drugs and the 100 most frequently prescribed generic drugs and brand drugs in the State of Maine, the manufacturers of these drugs and the average wholesale acquisition costs for the most recent 12-month period, which is November 1, 2022 – October 31, 2023. These prescription drugs are identified by their National Drug Code (NDC).
  • The total number of distinct NDC’s identified in both categories of costliest and most frequently prescribed for both generic drugs and brand name drugs is 282.
  • The data below is a snapshot of the complete data set that is available in the Excel File here.

image of part of the top 100 most costly and most frequently prescribed generic and brand drug data for 2nd annual report

Part II

§8741 2. B. To the extent possible, determine the referenced rate for each drug identified in paragraph 2.A. (Part 1) by comparing the wholesale acquisition cost to the cost in official publications of the governments of the Canadian provinces of Ontario, Quebec, British Columbia, and Alberta. The referenced rate for each prescription drug must be calculated as the lowest cost among the resources described in this paragraph and the wholesale acquisition cost for the most recent 12-month period. If a specific drug identified in paragraph A is not included within the resources described in this paragraph, MHDO shall use for the purpose of determining the referenced rate the ceiling price for drugs as reported in other official publications of the government of Canada.

  • For 194 of the 282 NDCs identified in Part I of this report (which represents 68.8% of the total), there is not a corresponding Drug Identification Number (DIN) on a provincial formulary in Canada.
    • When comparing NDCs in the US to the equivalent DINs in Canada there are not as many prescription drug products available in Canada.
    • In Canada, multi-source brand drugs (brand drugs that are also available from generic manufacturers) are often excluded from provincial formularies and are instead replaced by lower cost generic equivalents.
  • A reference rate as defined above (the lowest cost option when looking at the WAC and the costs in the Canadian provinces) has been determined for 88 of the 282 NDCs identified in Part I of this report (which represents 31.2% of the total).
    • The reference rate for 23 of the 88 NDCs is based on the WAC as that is the lowest cost option; 21 of these 23 NDCs are for generic drugs and 2 NDCs are for brand drugs.
    • The reference rate for 65 of the 88 NDCs is based on the lowest cost option identified in the Canadian provinces; 14 of these 72 NDCs are for generic drugs and 51 NDCs are for brand drugs.
  • The data below is a snapshot of the complete data set that is available in the Excel File here.

image of part of the reference rate data for the 2nd annual report.

Part III

§8741 2. C. For each drug identified in paragraph A, the organization shall determine the potential savings that could be achieved by subjecting those drugs to the referenced rate as calculated pursuant to paragraph B. The savings must be determined based on the payments reported in the organization's claims database for the most current 12- month period.

  • A reference rate was calculated for the 88 NDCs as identified above.
  • The potential savings calculation for the 65 drugs with a reference rate based on the lowest cost option identified in the Canadian provinces is $171.1M; of which 0.8% of the potential saving is for generic drugs and 99.2% is for brand drugs. (Note: potential savings calculations do not consider the impact of rebates to net prices in the US market as rebate data at the NDC level is not available in the MHDO claims data).
  • The data below is a snapshot of the complete data set that is available in the Excel File here.


Key Findings Preparing This Report

  • When comparing NDCs in the US to pharmaceutically equivalent DINs in Canada there are not as many prescription drug products available in Canada.
  • Many drugs currently patented in the US are not under patent in Canada. This allows for generic competition in Canada while brand drugs remain the only products available in the US.
    • In Canada, multi-source brand drugs (brand drugs that are also available from generic manufacturers) are often excluded from provincial formularies and are instead replaced by lower cost generic equivalents.
  • Prices on Canadian provincial formularies represent amounts paid by payers in the province. In contrast, WAC represents the price paid to manufacturers by drug wholesalers and almost never reflects actual amounts paid by payers in the US.
    • Many generic drugs show no Reference Rate savings resulting from the comparison of Canadian paid amounts to the US WAC amounts.
  • The 12-month pricing period evaluated in this report overlaps with the 12-month period in MHDO’s first annual report by two months.
  • The NDCs evaluated in the second annual report are substantially the same as those included in the first report.
    • Five new NDCs were added and nine NDCs previously included were removed, including several Covid vaccines that are no longer available in the market.
  • A year-over-year comparison of key metrics is provided in the table below:
Report Year Distinct NDCs NDCs for which
Reference Rate
can be calculated
NDCs with Reference Rate
based on WAC Pricing
NDCs with Reference Rate
based on Canadian Pricing
Total Potential
Savings
2022 286 93 21 72 $146.7M
2023 282 88 23 65 $171.1M

Data Sources and Methodology

Under contract with MHDO, Ten2Eleven Business Solutions provided MHDO technical support in the preparation of this report.

MHDO performed its analysis using descriptive drug product, pharmaceutical equivalency, and historical pricing information compiled from Wolters Kluwer’s Medi-Span MedFile v2 (MediSpan) and Canadian Drug File data files, and pharmaceutical claims data submitted to the MHDO All Payer Claims Database as required by 90-590 Rule Chapter 243, Uniform Reporting System for Health Care Claims Data Sets, for the most recent 12-month period (April 1, 2022 – March 31, 2023).

Manufactures are incorporated as different corporate entities in the US and Canada. To compare country to country pricing between products by manufacturer, MHDO developed a crosswalk of US and Canadian manufacturers. Where possible, manufacturers were mapped by associating similar corporate names; when no match was found, MHDO performed internet research to determine corporate relationships between US manufacturers of NDCs on the Top 100 List and manufacturers of pharmaceutically equivalent products in Canada.

The MediSpan and Canadian Drug Files share a common proprietary data element that is maintained by Wolters Kluwer to denote pharmaceutically equivalent drug products. This Generic Product Identifier (GPI) was used together with the manufacturer crosswalk to map products that are identical with respect to active ingredient(s), dosage form, route of administration, and strength or concentration but without considering the presence of inactive ingredients.

Where US NDCs could be mapped to a Canadian DIN, and were priced on at least one provincial formulary, MHDO determined a Reference Rate for the NDC as described in §8741 2. B. Province pricing was evaluated based on amounts published as applicable for October 31, 2023, adjusted for the US / Canadian exchange rate of 1.3877 posted by the Wall Street Journal as of the close of the market on Tuesday, October 31, 20231. Reference Rate values were calculated per NDC unit of measure.

MHDO next calculated potential savings that could be achieved by subjecting NDCs on the Top 100 List to the Reference Rate. MHDO first determined the total quantity dispensed (by NDC unit of measure) and average percent markup above/below WAC for commercial claims during the claim review period (April 1, 2022 – March 31, 2023). The average rate of markup above/below WAC was then applied to both the average WAC per NDC unit of measure2 and the Reference Rate, and both metrics were multiplied by the dispensed quantity. Finally, resultant values were compared to determine total potential savings for each NDC

Potential savings values were updated on January 24, 2024, to incorporate additional claims for the claim review period (April 1, 2022 – March 31, 2023) that were initially omitted in error.

MHDO received one time funding from an external source to cover the annual data acquisition cost for the Canadian Drug File. Funding is needed to continue MHDO’s subscription to the data file on an annual basis.


MHDO posted this report December 7th, 2023


Footnotes:

11 Wall Street Journal Website. Markets. Accessed November 6, 2023 at https://www.wsj.com/market-data/quotes/fx/USDCAD/historical-prices

2 Average WAC per NDC unit of measure was calculated by summing the mathematical product(s) of the number of days during the most recent 12-month period (November 1, 2022 – October 31, 2023) that a drug product was priced at a unique WAC per unit value multiplied by the unique WAC per unit value and dividing the sum of all mathematical products by the number of days in the 12-month period. ((($a x 31 days) + ($b x 150 days) + ($c x 184 days)) / 365 days)