The Lithuanian Free Market Institute (LFMI) has examined a Draft Governmental Decree on the Guidelines for Pharmaceuticals Policy and submitted its comments and proposals regarding points 23.2 and 23.9 of Chapter IV to relevant authorities. In principle, LFMI called for the rejection of the aforementioned points 23.2 and 23.9 of Chapter IV. Below is a summary of the arguments expressed.
On point 23.2 of Chapter IV: “To restrict the inclusion of expensive pharmaceuticals with cheaper analogues into the price list; to establish that combined pharmaceuticals may only be included into the price list if their basic price and premium do not exceed the combined prices of and premiums for the active substances combined.”
- In LFMI’s view, the methodology for price calculation provided in the proposal is disputable, because in addition to costs of active substances, the price of combined pharmaceuticals includes costs relating to manufacturing, market placement, etc.;
- there is no clarity as to what methodology will be used to determine the price of each active substance. It should be noted that the same active substance may have a different price depending on customers (wholesale or retail trade companies), seasons and markets.
On point 23.9 of Chapter IV: “To allow hospital pharmacies to sell (supply) pharmaceuticals to outpatients”.
- In LFMI’s view, the decision to allow state-owned health care institutions to engage in commercial activity is unjustified and poses a threat that public resources allocated for health care will be used for retail trade activities thus infringing the principles of fair competition.
The full position paper and further argumentation (in Lithuanian) is available here.