Starting january 1, 2025, Pharmeca a.s. will provide an overview of issued decisions by the State Institute for Drug Control (SÚKL) and the Ministry of Health of the Czech Republic (MZ ČR) related to pricing and reimbursement on its website.
For marketing authorization holders, knowledge of SÚKL and MZ ČR decisions in the area of pricing and reimbursement is essential. The outcomes of individual proceedings shape decision-making practices that influence future decisions.
To address this need, Pharmeca a.s. now offers an interactive overview of decisions issued in the past five weeks.
Pharmeca a.s. provides services in the areas defined by this
legislative framework:
Act No. 48/1997 Coll.,on
Public Health Insurance and on Amendments to Some Related Acts, as
amended.
Implementing Regulation:
Decree
No. 376/2011 Coll.,
which implements certain provisions of the Public Health Insurance Act, as
amended,
Decree
No 384/2007 Coll., on
the list of reference groups, as amended,
Decree
No 385/2007 Coll., on
the list of active substances for adjunct or add-on therapy;
Decree
No. 63/2007 Coll.,
on the reimbursement of medicinal products and foods for special medical
purposes, as amended.
Decree
No. 618/2006 Coll.,
which issues framework agreements, as amended,
Decree
No. 134/1998 Coll.,
which issues a list of medical services with point values, as amended,
Decree
No. 527/2021 Coll.,
on determination of the amount of reimbursement of expenses for
professional acts and the method of determination of the amount of
compensation of expenses for professional consultations carried out by the
State Institute for Drug Control under the Public Health Insurance Act, as
amended,
Decree
on the determination of point values, the amount of payments for paid
services and regulatory restrictions - always issued for the current year,
Government
Regulation No. 307/2012
Coll., on local and temporal availability of health services, as amended.
Act No. 551/1991 Coll., on the
General Health Insurance Company of the Czech Republic, as amended.
Act No. 280/1992 Coll., on
departmental, branch, corporate and other insurance companies, as amended.
Act No. 592/1992 Coll., on
public health insurance premiums, as amended.
Implementing Regulation:
Decree
No. 351/2022 Coll.,
on the transmission of data on the consumption of medicinal products by
insured persons of the public health insurance when changing the health
insurance company, as amended
Price
Regulation of the Ministry of Health No. 4/2024/OLZP, on the
determination of a special distribution surcharge for medicinal products
released from the reserve stock system,
Price
Decision of the Ministry of Health No. 3/2024/OLZP, dated November 29,
2023, setting out lists of ATC groups with the relevant route of
administration, for which the ex-factory price of the medicinal product is
not subject to price regulation or maximum price regulation,
Price
Regulation of the Ministry of Health No. 2/2024/OLZP, dated November
29, 2023, on the price regulation of medicinal products and foods for
special medical purposes,
Price
Regulation of the Ministry of Health No. 11/2023/OLZP, dated October
25, 2023, on the determination of the distribution and dispensing
surcharge for medicinal products reimbursed under Section 32c of Act No.
48/1997 Coll.,
Price
Regulation No. 3/2022/OLZP, on the price regulation of individually
prepared medicinal products containing cannabis for medical use.
Price Regulations – Medical Devices:
Price
Regulation of the Ministry of Health No. 1/2024/OLZP, dated October
25, 2023, on the price regulation of medical devices and in vitro
diagnostic medical devices,
Price
Regulation of the Ministry of Health No. 2/2022/OLZP, dated January 7,
2022, amending Price Regulation No. 1/2019/CAU, dated May 22, 2019, on the
price regulation of medical devices,
Price
Decision 2/13-FAR, establishing a list of medical devices with
deregulated manufacturer prices.
Act No. 378/2007 Coll., on
Pharmaceuticals, as amended.
Implementing Regulation:
·
Decree No. 457/2023 Coll.,
establishing a list of human medicinal products exempt from the obligation of
the marketing authorization holder to ensure their supply after the announced
date of supply interruption or discontinuation, as amended.
Decree
No. 84/2008 Coll., on
good pharmaceutical practice, detailed conditions of handling
pharmaceuticals in pharmacies, healthcare facilities and other operators
and facilities supplying medicinal products, as amended,
Decree
No. 85/2008 Coll., which
lays down a list of active substances and excipients which may be used in
the preparation of medicinal products, as amended,
Decree
No 226/2008 Coll., on
good clinical practice and detailed conditions of clinical trials on
medicinal products, as amended,
Decree
No. 228/2008 Coll.,
on the marketing authorisation of medicinal products, as amended,
Decree
No. 229/2008 Coll.,
on the manufacture and distribution of pharmaceuticals, as amended,
Decree
No. 236/2015 Coll.,
on the determination of conditions for prescription, preparation,
distribution, dispense and use of individually prepared medicinal products
containing cannabis for medical use, as amended,
Decree
No. 329/2019 Coll.,
on prescribing medicinal products in the provision of health services, as
amended,
Decree
No. 463/2021 Coll.,
on the detailed conditions for conducting a clinical trial of medicinal
products for human use, as amended.
Act No 167/1998 Coll,
on addictive substances and
amending certain other acts, as amended
Implementing Regulation:
Decree
No. 53/2014 Coll.,
on forms under the Addictive Substances Act, as amended,
Decree
No. 123/2006 Coll., on evidence
and documentation of
addictive substances and preparations, as amended,
Decree
No. 243/2009 Coll., on
establishing a list of persons indicating their workplaces for their work
is not required permit to treatment of addictive substances and
preparations containing them, as amended,
Government
Regulation No. 463/2013 Coll.,
on lists of addictive substances, as amended,
Decree
No. 235/2022 Coll.,
on the cultivation and processing of cannabis plants for medicinal use, as
amended,
Decree
No 53/2022 Coll.,
on the determination of the amount of compensation of expenses for
professional acts performed by the State Institute for Drug Control
pursuant to the Act on Addictive Substances, as amended.
Act No. 375/2022 Coll., on
medical devices and in vitro diagnostic medical devices, as
amended.
Implementing Regulation:
Decree
No 377/2022 Coll.,
on the implementation of certain provisions of the Act on medical devices
and in vitro diagnostic medical devices, as amended,
·
Decree No. 378/2022 Coll., on the
template of the inspector's identification card of the State Institute for Drug
Control under the Act on Medical Devices and In Vitro Diagnostic Medical
Devices, as amended.
Decree
No 379/2022 Coll.,
on the determination of the amount of compensationof
expenses for professional acts performed by the State Institute for Drug
Control pursuant to the Act on Medical Devices and In Vitro Diagnostic
Medical Devices, as amended.
Act No 376/2022 Coll.
amending certain acts in connection with the adoption of the Act on medical
devices and in vitro diagnostic medical devices, as amended.
Act No.268/2014 Coll.,on
medical devices and amending Act No. 634/2004 Coll., on administrative
fees, as amended.
Act No. 89/2021 Coll., on
medical devices and amending Act No. 378/2007 Coll., on pharmaceuticals and on
amendments to certain related acts (Act on pharmaceuticals), as amended.
Implementing Regulation:
·
Notification of the Ministry of Health No.
54/2022 Coll., on the commissioning of the central repository of electronic
vouchers.
Act No. 22/1997 Coll., on
Technical Requirements for Products and amendments to some related
acts, as amended.
Act No. 90/2016 Coll., on the
assessment of the conformity of specified products when they are placed on the
market, as amended.
Act No. 372/2011 Coll., on
health services and conditions for their provision (the Health
Services Act), as amended.
Decree No. 373/2016 Coll., on the
transfer of data to the National Health Information System, as amended.
Act No. 40/1995 Coll., on the
regulation of advertising and on amending and supplementing Act No. 468/1991
Coll., on the operation of radio and television broadcasting, as
amended.
Act No 242/2022 Coll., on the
services of video sharing platforms and amending certain related acts (Act
on the services of video sharing platforms), as amended.
Act No. 387/2024
Coll., on General Product Safety and Amendments to Certain Related Acts, as
amended.
Act No. 500/2004 Coll.,
Administrative Code, as amended.
The European Medicines Agency (EMA) has
announced the launch of a new platform designed to routinely monitor shortages
of centrally authorized medicines. This platform is a direct result of Regulation
(EU) 2022/123, which aims to improve preparedness for and mitigation of
medicine shortages across EU member states.
Key Points:
Platform
Availability:
The European Shortages Monitoring Platform (ESMP) is now accessible
online.
Mandatory
Usage:
Starting from February 2, 2025, all Marketing Authorization Holders (MAHs)
with centrally authorized products will be required to use the ESMP.
Early
Familiarity:
EMA encourages MAHs to familiarize themselves with the platform before the
mandatory deadline.
Data
Submission:
Until February 2, 2025, MAHs and National Competent Authorities (NCAs) can
submit data on supply, demand, and availability of both centrally and
nationally authorized medicines to the EMA's Executive Steering Group on
Shortages and Safety of Medicinal Products (MSSG).
Medicine
Monitoring:
The platform will be used for routine monitoring of all centrally
authorized medicines and may also be used for monitoring nationally
authorized medicines under special circumstances.
The European Medicines Agency (EMA) has announced the launch of a new platform designed to routinely monitor shortages of centrally authorized medicines.
From January 1, 2025, Slovakia will include medicines
and medical devices in the reduced VAT rate of 5%. This move is part of a
broader tax reform aimed at improving access to essential goods for the
population while reducing the financial burden on patients. The changes are
likely a response to the European Commission’s assessment of public finances
and an effort to reduce the budget deficit.
This change contrasts with developments in the Czech
Republic, where, as of January 1, 2024, the VAT rate on medicines increased
from the original 10% to 12%, as we mentioned in our previous article Changes
in VAT Rate for Pharmaceuticals.
What Impact Will the Reduced VAT Rate Have in
Slovakia?
The lower VAT rate is expected to significantly reduce
costs for patients in Slovakia for medical devices and medicines, both in
outpatient and hospital care. The direct financial impact on individuals will
depend on specific measures and pricing policies. For comparison, Slovakia’s
VAT on medicines has dropped from 10% to 5%, which could lead to a more
noticeable impact on final prices than in the Czech Republic, where the rate
was increased.
Impact on External Price Referencing for Medicines
The reduced VAT rate in Slovakia, however, will not
affect the external price referencing (EPR) of medicines, used by some
countries to set maximum prices and reimbursement levels in their markets. The
VAT change does not reflect in EPR because the reference price is almost
universally based on the manufacturer’s price.
At the same time, this change offers an opportunity to
compare tax policies across the EU, where VAT rates on medicines and medical
devices vary significantly. For example, according to data
from EFPIA (European Federation of Pharmaceutical Industries and
Associations) as of January 1, 2024, Spain applies a 4% VAT rate on medicines,
while Denmark has a standard rate of 25%.
Stay tuned to our website for more updates on
legislative changes and their impact on healthcare in the EU.
From January 1, 2025, Slovakia will introduce a significant change in its tax policy. This step is part of a broader tax reform aimed at improving access to essential goods for the population while reducing the financial burden on patients.
The European Health Data Space should lead to the empowerment of citizens and support for research and innovation.
EU residents will have more control over their health data,
being able to access it electronically and share it across borders. This
is particularly beneficial for cross-border healthcare, allowing
individuals to access medical records and receive care seamlessly
throughout the EU.
The EHDS promotes the secondary
use of health data for research, innovation, and policy-making.
Researchers and innovators will be able to access health data more easily
and securely, which could drive the development of new treatments, medical
devices, and AI applications.
The main objectives of the European Health Data Space (source: excerpt from the Communication from the Commission to the European Parliament and the Council: The European Health Data Space: Harnessing the power of health data for people, patients, and innovation):
EHDS - main points:
3 May 2022 –
European Commission launched the EHDS regulation proposal to easier exchange
and access health data at EU level.
6 December 2023 – The EU Council approved the regulation proposal.
15 March 2024 – After five tripartite meetings between Parliament, the Council
and the Commission, so called “trialogue”, an agreement on provisional proposal
was reached between the European Parliament and the EU Council. The compromised
text contains e.g. a right to opt-out of the system, an electronic health
records system assessment, a data localisation and some specific timelines of implementation.
24 April 2024 - The European Parliament formally approved EHDS regulation proposal.
After the end of the legislative process, the European Parliament and the
Council will adopt the final text of the new Regulation.
The proposal is currently in its first
reading procedure, document
identifier COM(2022)0197. The European Parliament is expected to decide on the
proposed amendments
by the end of December 2024.
EHDS general information:
One key feature
of the EHDS is the introduction of common standards for electronic health
record (EHR) systems across the EU, fostering interoperability and creating a
single market for these systems. This includes a mandatory self-assessment for
systems to ensure secure data storage and transfer.
The regulation
also establishes an opt-out system where individuals can choose to
restrict access to their data for secondary purposes, such as research, while
still allowing essential data sharing for healthcare delivery. Member States
will manage access requests for health data and may implement stricter rules
for sensitive information like genetic data.
The EHDS
framework is expected to enhance patient care by reducing unnecessary testing
and improving evidence-based decision-making. It also strengthens privacy
protections while enabling the reuse of health data for public health and
research purposes.
The European Health Data Space (EHDS) has advanced significantly since the initial concept of a digital transformation in healthcare across all EU member states.
CTIS byl
zřízen farmaceutickým zákonem v rámci Nařízení o klinických studiích (Nařízení (EU) č. 536/2014) a po 30.
lednu 2025 kompletně nahradí původní systém pro klinické studie EudraCT
(Databáze klinických studií orgánů pro regulaci léčiv Evropské unie).
Evropská léková agentura (EMA) průběžně
publikuje zprávy, jak proces přechodu na nový systém pokračuje.
V předchozím článku jsme
ukazovali, jaká byla situace v únoru 2024, v tomto článku jsme informace o počtu
podání a rozhodnutí o přechodu aktualizovali ke konci srpna 2024.
Obr. č. 1 – Změny v počtu
podaných žádostí, resp. v počtu podání, kde již bylo rozhodnuto, v porovnání
s předchozím měsícem
V průběhu léta aktivita podávání
žádostí poklesla, ale ve srovnání se stavem v únoru je celkový počet podaných
žádostí vice než dvojnásobný a počet studií s rozhodnutím je také skoro
dvojnásobný.
Nicméně stále jsou klinické studie,
pro které je třeba podat žádost.
EMA
publikuje novinky v této oblasti každé dva týdny, kde mj. uvádí, jaké změny
v systému CTIS provedla.
Klinické studie zahájené po 30.
lednu 2023 – všechny žádosti o počáteční klinické studie v
Evropské unii (EU)/Evropském hospodářském prostoru (EHP) musí být podány
prostřednictvím CTIS
Klinické studie ukončené před 30.
lednem 2025 – Klinická studie je spravována v systému EudraCT nebo národních
systémech
Klinické studie, u kterých se očekává, že
budou pokračovat po 30. lednu 2025 – je nutný přechod z
EudraCT nebo národních systémů na CTIS.
Obr. č. 2
– schéma přechodu na nový informační systém pro klinická hodnocení
CTIS was established by pharmaceutical law in the Clinical Trials Regulation (Regulation (EU) No 536/2014) and will completely replace the previous system for clinical trials EudraCT (European Union Drug Regulating Authorities Clinical Trials Database) after 30th January 2025. CTIS supports interactions between clinical trial sponsors (researchers or companies that run a clinical trial and collect and analyse the data) and regulatory authorities in the EU Member States and EEA countries, throughout the lifecycle of a clinical trial.
CTIS is guaranteed by European Medicines
agency (EMA) and works in a secured workspace.
The important milestones for clinical trials:
CT starts after
30th January 2023 – the submission must be completed through CTIS
CT ends before
30th January 2025 – CT is maintained in EudraCT or national
systems
CT is expected
to continue after 30th January 2025 – transition from the EudraCT or
national systems to the CTIS is necessary.
Although the deadline is still 11 months away, according to the EMA's recommendations, the transition process should begin without delay. There are a few tricky points in the transition process that are worth noting.
The transition should take 2 months (according to the EMA methodology) but be prepared for a longer period. Once the process is complete, all information and data are processed through CTIS.
The new country should be included in clinical trial after the transition in all current clinical trial countries is complete.
The national language especially with special characters, can be a problem. You must provide labels in the national language.
Relation in workspace can be unstable, in which case the submission may not complete successfully and a resession may be required.
Because the system is not intuitive and not easy to use (experience), there are guidance and Q&As from EMA (link) as well as webinars (link) for users and sponsors.
CTIS podporuje interakce mezi sponzory klinických studií (výzkumníky nebo společnostmi, které provádějí klinickou studii a shromažďují a analyzují data) a regulačními orgány v členských státech EU a zemích EHP po celou dobu životního cyklu klinické studie.
Based on the amendment to Act
No. 235/2004 Coll., on Value Added Tax, as of January 1, 2024, there has been a
change in VAT rates, particularly impacting the increase in prices and
reimbursements for medicinal products. In the infographics, we will illustrate
how the individual rates have changed and examine the international comparison
to assess the impact on the Czech Republic.
While the standard VAT rate
remains at 21 percent, the original reduced rates of 15 percent (for medical
devices) and 10 percent (for medicinal products) have been unified into a
single 12 percent rate. The newly introduced zero rate applies exclusively to
books, although the inclusion of medicinal products could have been possible in
line with European legislation.
The infographics provides an
overview of the changes in rates as follows:
In international comparison, the
Czech Republic finds itself in the less favorable top positions of the ranking
of applied VAT rates on reimbursed medicinal products. Many countries still
maintain lower, extra reduced, or even zero VAT rates on medicinal products
despite the current economic situation.
Source: Statista. (2023, December
21). VAT rate on prescription-only drugs in Europe by country 2023. https://www.statista.com/statistics/458957/vat-rate-on-prescription-only-drugs-in-europe/
Based on the amendment to Act No. 235/2004 Coll., on Value Added Tax, as of January 1, 2024, there has been a change in VAT rates, particularly impacting the increase in prices and reimbursements for medicinal products. In the infographics, we will illustrate how the individual rates have changed and examine the international comparison to assess the impact on the Czech Republic.