On 11 November 2020, the Finnish Competition and Consumer Authority (FCCA) published an extensive report on the pharmacy market. As a result of the report, a list of proposals has emerged that can reduce the cost of medication for customers and society, as well as improve their availability. The aim of the report is the same as previously in the so-called pharmaceutical roadmap published by the Ministry of Social Affairs and Health (STM).
The regulatory framework for pharmaceutical services is quite complex. To the credit of the FCCA's report, it should be mentioned that the regulatory framework has been opened up in a very understandable way, and even so that the special role of medicines as part of the treatment package has not been forgotten. The FCCA's report immediately started a discussion in various media. Despite the plain language of the report, proposals and findings – openings of the debate – have been commented on in some dismissive and even accusing tones on social media.
In the report, the FCCA highlights four reasons as to why the regulation of pharmaceutical supply should be reformed. As in previous reports of the Ministry of Social Affairs and Health (STM 5:2019 and STM 1:2020), the FCCA's report also finds the high prices of medicines rising to the top. The problem is highlighted through the business performance of pharmacies. However, the debate seems to focus too heavily on pharmacists' incomes. The set of issues to be solved and developed is much wider than this.
The second challenge is the number of barriers to entering the market. If entering and leaving the market were sufficiently straightforward, competition would work in the best way for the benefit of the end user and society. More competition is not a cross-objective for quality and safety. By targeting regulation to ensure and control the various dimensions of rational pharmacotherapy, the best interests of the customer can be safeguarded, even if stronger competition is allowed.
The third problem with the system listed in the report is that regulation is sidelined in terms of the end goal. One might ask whether the interests of the user of medication and society are realised in the best possible way in terms of the effectiveness, safety, quality, equality, and economy of pharmacotherapy when regulating company form and ownership. As the FCCA points out in its report, the key question to be considered in the future is the right balance between market regulation and free market conditions. The answer is probably to be resolved once it has been determined what is required of pharmacy operations as part of care packages and pathways, as well as the various service productions associated with them.
The fourth challenge of the current system is the functioning of price competition, i.e. what kind of price regulation system affects the pricing of medicines by pharmaceutical companies in Finland. On the other side of the scale is the availability of medicines and the safeguarding of access to medicines at different stages of the life cycle of a pharmaceutical product. The availability of medicines is affected by different types of mechanisms, depending on whether they are new medicines, long-standing medicines on the market, or medicines for which patent protection has expired. For this reason, different price control mechanisms are needed for different stages of the life cycle of a medicine, so that medicines are not overpaid in Finland. In addition to price regulation, this whole is also influenced by the regulation of the marketing authorisation system for medicines and exemptions for release for consumption.
The FCCA proposes seven solutions to the four pain points in the pharmaceutical market listed above. The proposals vary in size and none of them, taken alone, will have the desired effects in terms of the objectives of rational pharmacotherapy.
The aim of the FCCA report was to find areas for regulatory development that could make the market more efficient so that consumers can buy their medicines safely and at the lowest possible price. In this, the report seems to have been successful.
Some of the proposals are ones that we at Tamro have also considered appropriate. Some of the proposals are ones in which we will be happy to continue the discussion and bring our own views.
We consider it important that, by the end of 2021, the evaluation of alternative models for the overall reform of pharmaceutical distribution be completed and that an implementation plan be drawn up for the next parliamentary term. During this parliamentary term, we consider it important to assess changes to improve access to medicines. In addition to the compulsory storage of medicines identified by STM, the development of special licensing practices and the renewal of Fimea's right to access information, the necessary measures would be to improve the processes and market functioning of the online pharmacy and mechanical dose distribution activities for medicines. We agree with the Association of Finnish Pharmacies that the reform of the pharmacy economy should be continued. We believe that new structural changes to the rate would be needed. The development of the pharmacy economy should be phased in such a way that the other development of the pharmacy system and the opportunities it offers for streamlining operations are taken into account in the reform of the pharmacy economy.
At Tamro, we are an everyday partner in pharmaceutical services for both pharmacies and pharmaceutical and health product companies. With the same attitude, we are also acting in the best interests of patients and society, and we are taking initiatives to enable renewable medicine delivery services. We want to discuss pharmaceutical sector and, more broadly, social and health care reforms, with an understanding of different perspectives. All studies are welcome to increase understanding this complex system. Open debate is necessary for widening perspectives. People are satisfied with pharmacy services and Finns appreciate the work of pharmacies. The problem is the regulatory entity of the retail distribution system, which in its current form leads to an unreasonable burden to pay for pharmaceutical care and has polarised the pharmacy field and stiffened the development of customer-oriented pharmaceutical support services.
Yesterday (16 November 2020), Yle launched a campaign to improve the Finnish discussion culture. The campaign invites all interested parties to participate in the debate on social issues and seeks to bridle the culture of intentional misunderstanding. Pharmacotherapy is a part of every Finn's everyday life, and everyone is entitled to participate in a discussion related to it with their own expertise. There will be a discussion of the future with appreciation, respecting the views of the various parties. We all certainly have the interests of the medicine user and Finland as a common goal.
Heidi Tahvanainen
Public Affairs Manager
