EFPIA welcomes the debate on access to health services, valuing its important contribution in the face of challenges to European health systems sustainability. It is for this reason, though, that we believe the debate must go beyond a discussion on the cost of individual medicines and the pharmaceutical sector in isolation.

Europe needs outcomes driven, sustainable models of healthcare delivery that focus on improving patients’ health in a holistic and evidence-based way. Europe must have systems that allocate resources towards those interventions that deliver the best possible outcomes and away from those that don’t, these systems improve quality. This is often less expensive in the long-term and thus more sustainable than the current transaction-oriented approach to healthcare.

Pharmaceutical expenditure in recent years, has been growing at a lower rate than overall healthcare expenditure. Moreover, according to IMS predictions annual expenditure growth in the top 5 European markets will be 1%-4% between 2014 and 2018.

This underscores the vital role of pharmaceuticals in addressing the significant twin challenges of increasing chronic conditions and population ageing. It also suggests that, far from being problem in itself, increased pharmaceutical expenditure has led to more readily available medicines that have helped both to prevent health complications and the use of alternative, costly health care services.

To address the financial challenges faced by health systems, Europe needs urgently to move away from a transactions-oriented approach to healthcare, towards outcomes-driven, sustainable models that focus on improving patients’ health in a holistic and evidence-based way. This means a transition towards systems that allocate resources to those interventions that deliver the best possible outcomes, abandoning those that don’t.

EFPIA points out that there is no immediate and automatic correlation between increased price transparency and greater savings for healthcare systems.  In fact enhanced transparency may have a negative impact in terms of patient access and incentives for innovation.

Moreover, we accept that, while prices set for innovative medicines may be discussed and debated, this should not lead to a questioning of the existing patent system. EFPIA supports a quick and effective transition to off-patent markets, but this process should not come in the form of an enforced mechanism to address pricing issues to the detriment of innovation.

In the interests of improving on this opinion, EFPIA recommends: prioritising access issues and potential solutions by explaining on what other factors, beyond costs, access to health services depends (e.g. health system coverage etc.); addressing the current thinking on innovative pricing approaches incorporating outcomes performance, adaptive pathways and use of real-world evidence; undertake further research to understand the causes of drug shortages and work towards their prevention; and support the establishment of interoperable repositories or database systems containing unique identifiers for prescription medicines.

The full response to the public consultation can be accessed here.