2004N-0115 - Prescription Drug Importation; Public Meeting
FDA Comment Number : EC52
Submitter : Mr. G.Edwin Howe Date & Time: 06/02/2004 09:06:17
Organization : Aurora Health Care
Drug Industry
Category :
Issue Areas/Comments
May 27, 2004

Honorable Members
Task Force on Drug Importation
U.S. Department of Health & Human Services

Dear Task Force Members:

This is to provide you with Aurora Health Care!|s comments on the issue of Canadian drug importation. Aurora Pharmacy, Inc., a subsidiary of Aurora Health Care, is the 2nd largest retail pharmacy chain in the State of Wisconsin with $285 million in gross revenue in 2003 and 138 pharmacies statewide.

As President and CEO of Aurora Health Care, I support the importation of drugs from Canada as a means to lower the cost of retail drugs. Access to a more affordable supply of drugs is important for both patients and retail pharmacies. Free trade would benefit the pharmaceutical industry just as it currently benefits other industries in the U.S economy.

Additional points related to this issue are as follows:

?h Drug prices paid by the American consumer include a subsidy for pharmaceutical research and development. Consumers and manufacturers all over the world benefit from this R&D. Legalizing Canadian importation would be a first step towards eliminating this unfair subsidy and leveling the playing field.

?h Quality and safety issues that have been raised regarding drug importation could be addressed by implementing the same quality and safety standards in Canada that we have in the U.S. today.

?h Currently, U.S.-based pharmaceutical wholesalers are either located in Canada or networked with Canada. These existing arrangements would greatly facilitate the importation of Canadian drugs, if it is legalized.

?h Aurora Pharmacy in Wisconsin as well as pharmacies in other border states could be part of a demonstration project sponsored by the U.S. DHHS to test the impact of drug importation on quality and service.

?h Drug manufacturers control the Average Wholesale Price as well as the cost of drugs purchased by retail pharmacies. This method of pricing is
unique to the pharmaceutical industry and should be examined closely to determine whether it provides the right economic incentives.

Aurora Health Care believes local pharmacists should be a patient!|s first choice for obtaining retail drugs since they provide the additional benefits of medication therapy management and patient counseling. However, patient access to safe and affordable drugs must be our priority. Drug importation should be legalized as a way to improve access to drugs for U.S. citizens.

If you have any questions or require additional information about Aurora Pharmacy, Inc., feel free to contact Jim Moore, President of Aurora Health Care Ventures, at (414) 454-6466.


G. Edwin Howe
President & CEO
Aurora Health Care