Open consultation on Canada’s National Pharmacare Program: Our recommendations

The Health Canada’s Advisory Council on the Implementation of National Pharmacare (the Council) is leading a national consultation on how to implement affordable national pharmacare for Canadians and their families.

While Canadians benefit from a publicly funded health care system, prescription drugs are not covered in a consistent way across the country. Canadians are invited to share their thoughts and ideas on what a national drug plan could look like to ensure that life-saving medication such as epinephrine auto-injectors are covered under the program.

Below is our submission to the Council for this consultation. Have your say and provide your submission to Health Canada before September 28, 2018. Click here to learn more.

September 24, 2018

Advisory Council on the Implementation of National Pharmacare Secretariat
Brooke Claxton Building
70 Colombine Driveway
Ottawa, Ontario K1A 0K9

Sent via email: pharmacare-assurancemedicaments@canada.ca

Re: Public Consultation Submission on Canada’s National Pharmacare Program

Food Allergy Canada welcomes the federal government’s public consultation on how to implement an affordable National Pharmacare Program for Canadian families. As the national advocacy and education organization for more than 2.6 million Canadians with a potentially life-threatening food allergy, we are acutely aware of the role government can play in supporting individuals with food allergies and their families. We encourage measures to provide accessible and affordable medication to Canadian families, including epinephrine auto-injectors, life-saving devices used to treat serious allergic reactions.


Food allergies are a growing public health issue. Given that even a small amount of a food allergen, if ingested, could cause a serious allergic reaction and be potentially life-threatening, access to epinephrine is essential. In the event of a reaction, research has shown that early administration of epinephrine can reduce the severity of symptoms and improve an individual’s outcome. Quick access and prompt administration of this medication may mean the difference between life and death. Epinephrine is also recommended as first line treatment for other serious allergic reactions to insect stings, medication and latex, which affect thousands more Canadians.

Canadians at risk of an anaphylactic reaction should carry an epinephrine auto-injector with them at all times, in case of an emergency. We believe strongly that everyone who requires this potentially lifesaving medication should have access to it, regardless of price or ability to pay. While we are fortunate to live in a country with a strong public health care system, we recognize that there are Canadians who are not covered by a private or public drug plan and may not be able to afford an auto-injector. For those who are covered by a drug plan, issues of deductible costs or annual limits on epinephrine auto-injectors may also cause financial challenges.

Over the past year, our community has been faced with ongoing shortages of epinephrine auto-injectors (i.e. EpiPen). Food Allergy Canada would welcome policies and processes aimed at improving access to epinephrine for all Canadians by expanding the product options available to Canadians. We are actively advocating for a minimum of two providers in Canada.

Food Allergy Canada’s approach to reducing the risk of allergic reactions in both children and adults is focused on self-management, community engagement, understanding, and respect. We are pleased to work with government, industry, the medical community, and other key stakeholders to contribute to policies that will ensure affordable access to medicine for all.

If you have any questions regarding our submission, please do not hesitate to contact me via the coordinates below.


Jennifer Gerdts
Executive Director, Food Allergy Canada