Advisory regarding use of RAMQ in APS (April 2016)
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Wondering if there had been any consideration to loop back with RAMQ on this guidance?
More specifically around "off-label" criteria, as I'm sure there are quite a few brands impacted, and the inability to even mention RAMQ for a tool.
Based on our reading of the document, even removal of discrete off-label criteria and maintenance of on-label criteria, wouldn't abide by their requests if all indications are presented.
Given these requests were provided directly to PAAB, we were wondering if there would be an opportunity to inquire with RAMQ whether there is anything that can be done? For example, is there something that could be said to just direct people to the website to find out more without implying coverage/criteria? Could a general statement of "For information on availability of formulary coverage in Quebec, please visit https://www.ramq.gouv.qc.ca/en/about-us/list-medications" (or something similar to add mention of potential criteria) be acceptable by RAMQ and PAAB?
We're open to additional thoughts around potential alternatives or next steps!
Jennifer Carroll last edited by
Great question. To clarify, the request from RAMQ is to ensure that the coverage criteria are always clear and complete, so as not to suggest the indication is the coverage criteria (except where this is indeed the case). The document states: Coverage claims must be accompanied by reimbursement criteria (if applicable to the indications promoted in the piece). This means, that not all criteria are required in the piece. The discrete criteria which are not for the indicated population (i.e. off-label criteria), CAN be removed from the coverage criteria. All formulary claims, across Canada, for discrete off-label use would need to be removed, this is not exclusive to RAMQ. If there are additional indications for the product, which RAMQ does not cover, the formulary presentation/claim should be clearly limited to the indications with RAMQ coverage.
A statement similar to “For information on availability of formulary coverage in Quebec, please visit link” would still allude to RAMQ and be subject to the RAMQ request. However, to reiterate, the RAMQ request does not preclude the removal of off-label discrete coverage.