Pangaea Express: Update On Bill 92 And Commercial Practices

September 5, 2018

By Ghislain Gauthier

On August 29, RAMQ released an info-letter (#180) that was sent to all wholesalers and drug manufacturers. It is a reminder of the Bill 92 Regulation about limiting supply medications to a restricted number of owner pharmacists for any product listed on RAMQ, the Quebec drug formulary.

RAMQ has received complaints, especially in cases of products listed on the “exception” list that require special authorization. Pharmacists must have access to all products and supply without restriction. (Bill 92, art. 80.2, 2nd paragraph).

The info-letter reminds all wholesalers, manufacturers or any intermediaries that they could be subject to a $10,000 fine that could escalate to $1,000,000 (Bill 92, art. 84.3) should there be an infraction. Fines will apply upon first infraction, there will be no second chance.

RAMQ has also clarified that funding of the training and education programs to Quebec pharmacists and lab technicians, by recognized drug manufacturers, is accepted as long the cost of the event remains reasonable.

As well, we anticipate hearing very shortly the final resolution regarding the exceptions to patient support programs for drugs covered by the basic prescription drug insurance plan. The regulation was published in the Gazette early July and the period for consultation and adjustments closes this week. We will keep you posted on the final Regulation as it is published.

For more information, please contact Ghislain Gauthier (