On November 5th, 2020 AmCham Bulgaria sent its position and proposals for improvement of the Draft Bill on the 2021 National Healthcare Insurance Fund Budget (NHIF). The position was prepared by the Healthcare Committee and was approved by the Board of Directors.
There are two major issues addressed in the letter: Underbudgeting in 2021 NHIF Budget and creation of administrative precedent that could have a domino effect on national and EU level.
Underbudgeting in 2021 NHIF Budget
2021 Budget of the NHIF for pharmaceutical products is underbudgeted. The proposal of the Chamber is that the 2021 NHIF pharma budget should not be lower than 2020 net spending after rebates and before excess compensation. Thus, the NHIF will ensure sustainability of pharmaceutical supply, patients access to innovation and legal certainty and predictability for pharma-companies in BG.
Current proposal in the NHIF Pharma Budget is planned to increase by BGN 89M 7,16% (BGN 1,243 M in 2020 to BGN 1,332 M in 2021). However, this increase is insufficient due to app. BGN 80 M less 2021 Budget vs. 2020 Net Spending from the previous year principle (based on 2020 estimations).
Potential consequences could be:
- Withdrawal of pharmaceutical products
- Companies from BG market;
- Bulgarian citizens will not have access to all available solutions of modern medicine,
- endangered people’s health.
Objection against administrative precedent
In addition the Draft Bill introduces an administrative precedent of HIV Therapies by the proposed 10% decrease of the price of specific pharmaceutical products (Appending 3 of the Positive Drugs List (PDL)) at the Ministry of Health e-tender.
AmCham Bulgaria’s position is that such an approach should not be adopted. The chamber addressed it already in August 2020. Again, the 2021 Budget should aim to ensure sustainability of pharmaceutical supply, patients’ access to innovation and legal certainty and predictability for pharma-companies in BG and not to cause any issue in the EU. Also, such an imperative change should not be introduced anyhow. This proposal states that the price can’t be higher than 90% of the price of the same medical product in the PDL. It will impact the international drugs reference and will create a spill-over effect and erosion of the referent prices.
The potential Domino effect could impact the reference medicine price model that works in all of the EU countries. If introduced, such a change will affect other EU markets as well.
The potential consequences include;
- Withdrawal of pharmaceutical products;
- Jeopardizing the quality therapy,
- Access to medicines and
- Proper treatment of HIV patients (either in Bulgaria or in the EU).
- Also, it could impede an institutional reaction: address or even potential infringement procedure by the European Commission.