How Do Stakeholders Perceive Canada’s Drug Pricing Reforms? An Analysis of Submissions to Canada’s Patented Medicine Prices Review Board

Background: Canada’s Patented Medicine Prices Review Board (PMPRB) regulates pharmaceutical prices to prevent excessive pricing. In June 2024, the PMPRB proposed major reforms including international price comparison (IPC) screening, annual re-benchmarking of existing medicines, and new complaint processes. Understanding how stakeholders responded to these proposals reveals the competing interests and strategic positioning that shape pharmaceutical price regulation. Methods: We conducted a systematic qualitative content analysis of all 54 public consultation submissions to the PMPRB’s 2024-2025 consultation on its Draft Guidelines. Using NVivo software, we coded submissions according to stakeholder type, main concerns, policy recommendations, and positions on specific regulatory mechanisms. We coded concerns and recommendations separately to compare them across stakeholder groups. Thematic analysis identified patterns within and across stakeholder groups. Results: Pharmaceutical companies and patient advocacy organizations raised different concerns yet converged on several of the same recommendations. Industry submissions described the proposals in constitutional and economic terms, characterizing annual re-benchmarking as jurisdictional overreach and warning of market exit. Patient organizations described the same proposals in terms of access and health equity, emphasizing delayed drug launches and impacts on vulnerable populations. Despite raising different concerns, some organizations in both groups recommended greater transparency in the review process and restricted, validated complaint eligibility, and complaint validation. Five concerns were dominant, raised primarily by pharmaceutical organizations: retroactive application of guidelines to existing medicines (21 of 34), expanded complaint eligibility risking strategic misuse (21 of 34), unclear compliance guidance (18 of 34), limited transparency in in-depth reviews (17 of 34), and insufficient transition periods (13 of 34). Patient organizations primarily sought inclusion in the PMPRB’s review processes, recommending patient participation in both therapeutic class comparison (TCC) and the complaint process. Conclusion: Pharmaceutical stakeholders positioned the proposed PMPRB guidelines as fundamental regulatory problems rather than technical refinements. Industry and patient organizations converged on a number of similar recommendations, highlighting the need for policy-makers to assess the evidence underlying shared recommendations.