While it is true that the linkages between patent protection, price, and pharmaceutical R&D have changed in Canada since the original PMPRB regulatory framework was created, it is also true that the pharmaceutical policy environment has changed significantly on a global basis. Unfortunately, none of Health Canada’s and/or PMPRB’s proposals concretely reflect how other jurisdictions are balancing innovation and health system costs, let alone how Canada could integrate those practices into its own policies.

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