Healing an ailing pharmaceutical system: prescription for reform for U.S. and Canada

Our pharmaceutical systems are broken, and only fundamental reform can ensure universal access to safer, more innovative, and more affordable drugs

By Adam Gaffney, instructor in medicine ¹, Joel Lexchin professor emeritus ², US, Canadian Pharmaceutical Policy Reform Working Group
BMJ, Analysis, May 2018

To read the full proposal, see below or visit the BMJ website.

To access our economic analysis and supplemental materials, click here.

To read PNHP’s press release, click here.

To read and view media coverage of the proposal, click here.

Click on each section to see text.

Introduction

Drugs are among medicine’s most powerful tools. Yet the pharmaceutical systems of the United States and Canada are mired in dysfunction. The industry’s pricing practices—charging whatever the market will bear, especially in the US—strain budgets and put vital medicines out of reach for many patients.^1-4 Despite some notable advances, the industry’s overall rate of real innovation remains incommensurate with our vast drug spending; many new drugs are marketed each year but few represent substantial clinical improvements.^5-7 And commercial imperatives distort drug trials,⁸ research priorities, and drug regulation.^9,10

While many recognize the need for change, proposed remedies vary^3,11-13 and would fall short of achieving the fundamental reform that these deficiencies call for. The advocacy organization Physicians for a National Health Program therefore encouraged a working group of US and Canadian doctors, scholars, and advocates (the US/Canadian Pharmaceutical Policy Reform Working Group) to come together to craft a wide ranging reform proposal for both nations. Although political circumstances, including the influence of the pharmaceutical lobby, make full implementation of these reforms unlikely at present, shifting political winds may bring a more favorable policy climate. Hence, the working group aimed to craft an ambitious proposal for pharmaceutical reform to set an agenda for the future, including insurance coverage, pricing, drug development, clinical testing, regulatory approval, postmarketing monitoring, and promotion.

Although some of our recommendations (box 1) could be implemented within the existing US healthcare financing framework, full implementation would require a universal single payer system. Canada already has a single payer system but it would still require reforms because the system fully covers hospital and doctors’ services but not drugs out of hospital.^14,15

Our proposal rests on six principles:

Medical needs, not financial means, should determine access to medications
Drugs must be affordable to society
Drug development should be geared toward real innovation that maximizes population health
The human right to health¹⁶ must take precedence over intellectual property rights (patents)
The safety and effectiveness of medications must be independently and rigorously evaluated
Comprehensive and unbiased information on drugs should be available to prescribers and patients.¹⁷

Summary of proposed pharmaceutical reforms

Access to prescription drugs

The right to essential medications is often compromised in both the US and Canada (fig 1). High out-of-pocket costs leave millions unable to fill prescriptions^14,15,18 and drive many into bankruptcy.^19,20 In the US an estimated 28 million people remain uninsured for healthcare,²¹ while 3.5 million in Canada lack drug coverage.¹⁴

Cost sharing (copayments, deductibles, and co-insurance) also impedes access on both sides of the border.^15,22 It reduces needed and unnecessary care to similar degrees²³; is a factor in reduced adherence^24,25; and, for some conditions, exacerbates racial disparities in health,²⁶ raises non-drug healthcare spending, and worsens outcomes.^24,26 Notably, Wales, Northern Ireland, and Scotland have been able to provide universal drug coverage without cost sharing while using other cost control mechanisms to hold drug spending well below US or Canadian levels.^27,28

To improve access and population health, we propose universal,²⁹ first dollar coverage (full insurance with no cost sharing) of all medically necessary drugs, echoing Archie Cochrane’s famous invocation that “all effective treatments must be free.”³⁰ Each nation should establish a national formulary of covered drugs, which should include all medications shown to improve the length or quality of life—or the safest, most effective, and least expensive option when equivalent agents are available. A national technology assessment office would provide data on comparative effectiveness to guide formulary decisions. When clinically appropriate—eg, for allergies or other unique circumstances—off-formulary drugs should also be covered.

Drug prices

Spending on outpatient drugs is higher in the US ($1026 (£742; €833) per capita annually) and Canada ($713) than in other nations in the Organization for Economic Cooperation and Development (averaging $515, and as low as $240 in Denmark).²⁷ High prices (especially in the US) rather than high use explain these differences. For example, in 2014 a daily 50 unit dose of insulin glargine cost $186.38 a month in the US (after applicable discounts) versus $63.65 in the UK and $46.60 in France.³¹

Despite claims to the contrary, research and development costs cannot justify these high prices.³² For instance, the total research and development expenditures of 10 firms that recently introduced new cancer drugs amounted to $9bn, while those drugs generated $67bn in revenues.³³ Drug firms continue to sharply increase US prices decades after recouping development costs,^1,34-36 and their mean profits are consistently threefold higher than the average of other Fortune 500 firms—23% v 7% in 2016.³⁷

Several steps could reduce drug prices while ensuring that no uniquely effective medications are withheld. Each nation’s regulatory agency would continue to approve drugs without regard to price. Once approved, however, a public agency would negotiate with manufacturers over prices, guided (in part) by comparative effectiveness data. Experience internationally, and in the US, indicates that such negotiations can lower prices³⁸—probably by about 50% for branded drugs in the US.^27,39-41

While negotiations and a national formulary could reduce prices for many medications, when patented drugs lack competitors firms could still demand unreasonable prices, forcing nations to exclude the drug or strain their budgets.^42,43 Hence, additional options to assure reasonable pricing are necessary (fig 2). For instance, if price negotiations over branded drugs failed, governments would issue a compulsory license to allow generic manufacturing, a mechanism already sanctioned under international trade law,⁴⁴ US patent law,⁴⁵ and the Bayh-Dole Act.⁴⁶ Indeed, in 2001, both the Bush (US)^44,47 and Chretien (Canada) administrations,⁴⁸ facing fears of anthrax bioterrorism, threatened to break the patent on ciprofloxacin, causing Bayer to lower the price.

In some circumstances, however, even compulsory licensing might not give reasonable prices; the cost of some generic drugs has soared after sole generic manufacturers cornered the market.^1,35 We thus advocate creating public manufacturing capacity to produce drugs when no reasonably priced option is available. This capacity could also augment production during public health emergencies or drug shortages.⁴⁹

Finally, drugs developed through public funding by public entities would remain unpatented and available for generic manufacture worldwide at greatly reduced cost.

Preclinical drug development

The patent protection and market exclusivity that prop up drug prices are typically portrayed as critical to encourage innovation. This portrayal is misleading for two reasons.

Firstly, despite achieving some important advances, the drug industry’s record on innovation is derisory relative to its vast revenues and profits.⁵⁰ Most new drugs offer little new besides higher cost,^2,6,7,51-55 while firms often extend market exclusivity through trivial modifications and secondary patenting.^56,57

Secondly, it is far from clear that patents are the most important stimulus to therapeutic advance. Throughout history, curiosity and the intrinsic rewards of discovery, rather than financial incentives, have often driven scientific breakthroughs. Even today, most basic research underlying later drug innovation is carried out in non-profit or public institutions and funded by the National Institutes of Health (NIH) and the Canadian Institutes of Health Research (CIHR). Before the 1980 Bayh-Dole Act, the fruits of publicly funded research remained in the public domain in the US. Since 1980, however, publicly funded researchers have been allowed to patent their discoveries and sell them to drug firms,⁵⁸ as occurred with the hepatitis C drug sofosbuvir. Although Bayh-Dole permits government to break the patents of such drugs, this provision has never been used.⁴⁶

Thus, we propose the repeal of Bayh-Dole to keep drugs developed with public funding in the public domain. Meanwhile, for drugs developed fully by the private sector, the patent system should be reformed to encourage innovative drugs, not more look alike, “me-too” agents.

In the US, the criteria for issuing drug patents have been stretched far beyond the original requirement that a patentable discovery had to be useful, novel, and non-obvious.^57,59 As others have argued,^3,60,61 patent reforms could both lower prices and advance innovation. Minor variations or combinations of existing agents, drug isomers,³ and tweaks to drug delivery devices that don’t add important functionality should not be patentable. Some countries have already mandated similar restrictions.⁶²

Because the reforms we advocate risk reducing incentives for industry to develop marketable products from important new discoveries, we propose creating institutes for prescription drug development within the NIH and CIHR. The new institutes would have two divisions: for drug innovation and for clinical trials (fig 2). The drug innovation division would focus on the development of non-patentable agents to the point of clinical trials. This “public track” would—alongside private research—fund the development of novel pharmaceuticals. We propose public funding equal to about half of current preclinical private sector investment. All novel molecules developed by the division would remain in the public domain. This approach is a form of “delinkage” of drug development and pricing that others have proposed.^63,64

The drug innovation divisions might do some drug development themselves but would mostly fund efforts by academic or other non-commercial investigators. Priority would be given to potential drugs with the most clinical value, focusing on diseases that are neglected, commercially unprofitable, lacking effective treatments, or important for public health. The new, unpatented agents could be produced as generics by companies anywhere—a major advance for global health.

Clinical testing

Industry sponsored clinical trials have sometimes used unsound methods and reported incomplete findings, calling into question the interpretability, and sometimes the veracity, of their conclusions on safety and efficacy.⁸ For instance, trials have compared new agents with placebos rather than the best existing therapies, underdosed comparator drugs, or relied on surrogate endpoints⁶⁵ that may not predict outcomes. Some commercially funded researchers have also selectively published (and republished) positive results^8,66 or concealed negative findings,⁶⁷ while firms have ended trials prematurely for purely commercial reasons.⁶⁸

Meanwhile, corporate ownership of trial data can obscure safety problems and impede further research.⁶⁹ Although requiring preregistration of trials has been an important step forward, transparency problems persist.⁷⁰

Drug regulatory agencies must therefore raise evidentiary standards. Trials should, whenever possible, compare new agents to existing therapies and use a superiority design to discourage investment in unneeded me-too drugs. When new agents mimic existing ones, they should generally be tested in patients who do not respond to (or tolerate) existing products. And with infrequent exceptions, trials should assess hard clinical (rather than surrogate) outcomes.⁷¹ Anonymized patient level data from all trials (including older trials), should be made publicly available⁷⁰ (whether or not a drug gains approval) to facilitate accountability and further research.

Finally, because of concerns regarding the objectivity of industry funded trials and the need to test unpatented and unprofitable therapies, the clinical trials divisions within the new NIH and CIHR institutes would also fund and oversee trials (fig 2).^69,72 The divisions would select promising molecules developed by non-profit laboratories, academic investigators, and drug companies for clinical trials, which would mainly be designed and conducted by non-commercial investigators. They might also fund trials assessing new indications for existing agents or non-drug therapies.

Publicly funded trials would offer important benefits: minimizing commercial conflicts of interest; redirecting research from “me-too” drugs toward real innovations, and facilitating the development of unprofitable but essential treatments.^69,72 Although firms could still fund trials of their products,⁷² because clinical trials are costly and would be subject to enhanced regulatory scrutiny (based on past evidence of companies manipulating results), publicly funded trials would be likely to predominate in the long term.

Drug approval reform

Canadian and US regulatory agencies too often allow unsafe drugs to reach the market^73-76 and inadequately monitor them after approval.^77-79 Both agencies’ independence has been eroded by their reliance, starting in the 1990s, on funding from fees paid by drug companies. In the US, the FDA’s receipt of these funds is explicitly linked to its shortening of review times.^73,75

Meanwhile, an increasing proportion of new drugs qualify for programs that further reduce review times. By 2014, 69% of drugs submitted to the FDA gained “expedited review” through various designations or pathways.⁸⁰ The comparable figure for Canada for 1997-2012 was 26%.⁸¹ Although intended to accelerate the availability of innovative agents, these programs have been exploited to speed the marketing of many “me-too” drugs.^7,80 Some of these expedited review pathways have weaker standards of evidence. The recently enacted 21st Century Cures Act in the US creates even more such pathways, and mandates that the FDA evaluate the potential use of “real world evidence”— ie, not from clinical trials—for approving new indications for drugs.^82,83

Such evidentiary changes may increase the risk that unsafe drugs will enter the market.^76,84 And most,^73-75,85,86 but not all,⁸⁴ studies suggest that shorter review times are deleterious.

We propose several reforms to the drug approval process: Firstly, industry funding of drug regulatory agencies should be ended; governments should fully fund agency budgets. Secondly, expedited review should be reserved for drugs likely to offer genuine clinical advances. For instance, “first in class” drugs should not automatically qualify for expedited approval since many are not superior to existing products.⁷ Thirdly, requirements that trials use hard clinical endpoints and active comparators should be waived only in exceptional circumstances. Fourthly, while experts who receive commercial funding may appropriately offer testimony before advisory panels evaluating drugs, such experts should not be allowed to participate in the panels’ voting or decision making.⁸⁷ Finally, drugs should be required to demonstrate superiority—whether in efficacy, safety, or convenience of dosing or administration—over any existing agents to be eligible for market exclusivity.

Postmarketing surveillance

As regulatory agencies have approved more drugs based on surrogate endpoints and smaller or fewer clinical trials, they have often mandated postmarketing studies to confirm benefits or exclude serious risks.⁷⁷ However, this approach has serious shortcomings. Though large postmarketing studies are critical to assuring safety (especially for rare side effects), they should not be an excuse for weakening preapproval safety requirements. And while big data approaches to pharmacosurveillance (eg, the FDA Sentinel System) hold promise, their results to date are modest and cannot substitute for clinical trials.88

Unfortunately, enforcement of mandated postmarketing studies is currently lax. The FDA has failed to fully use its authority to penalize firms that don’t complete such studies,^77,78 while Health Canada has allowed firms to continue marketing drugs for years without completing required trials.⁷⁹

We propose several reforms to upgrade postmarketing safety efforts. Funding for such efforts within the FDA and Health Canada should be increased to a level on par with spending for review of new drug applications, and safety offices should have equal position in these agencies’ hierarchies to offices tasked with drug approval. Safety monitoring offices should be empowered to independently order safety warnings and remove unsafe drugs from the market, and agencies should use their legal authority more aggressively to pursue drug companies that fail to complete required postmarketing studies on time. Finally, information about delays must be made publicly available.

Some of these reforms could be accomplished without legislation: since 2007, for instance, the FDA has had authority to penalize companies that failed to conduct timely postmarketing studies. Yet it has not exercised that power in any meaningful way.⁷⁸ Recent legislation allows Health Canada to levy substantial fines in case of company non-compliance.⁸⁹

Promotion

Drug promotion—including industry “detailing” of physicians’ offices—consumes billions of dollars annually, more than total expenditure on medical student education in the US^90-92; expenditures for sales and marketing exceed those for research and development.¹³ In addition to diverting funds that might be better used to develop lifesaving medications, such promotion is often misleading or inaccurate.^93-95 This is especially true for direct-to-consumer advertising (DTC)—now widespread in the US⁹⁶ and, in attenuated form, Canada.⁹⁷ Advertising that mentions the brand name of a prescription-only medicine along with its indication is banned in all other developed nations except New Zealand.

Promotional spending dwarfs the tiny budgets of the FDA and Health Canada components that regulate marketing. The FDA is overwhelmed by the sheer volume of materials to review,^98,99 and Health Canada has delegated most of the regulatory oversight of promotion to third parties.⁹⁷

We propose a major expansion of promotional review. Regulatory agencies need more (and more predictable) resources to carry out rigorous assessments of all promotional materials.⁹⁹ They should not have to rely on funding contingent on meeting deadlines to complete reviews, which can foster a lenient approach, and money should come only from government to avoid conflicts of interest.⁹⁹

Improved monitoring should be coupled with stiffer sanctions for misleading or off-label promotion. In the past, even massive fines haven’t deterred industry violations¹⁰⁰ because, as one expert noted, “When you’re selling $1 billion a year or more of a drug, it’s very tempting for a company to just ignore the traffic ticket and keep speeding.”¹⁰¹ Hence, authorities should be empowered to suspend firms’ right to promote their products or, in extreme cases, pursue criminal complaints against drug executives.

While we also favor prohibiting direct-to-consumer advertising and industry detailing, constitutional challenges based on “commercial speech” rights may preclude such bans in the US.¹⁰² However, other tools are clearly constitutional, such as eliminating tax deductions for promotional activities; additionally, when alternative treatments are available, drugs promoted in these fashions might be excluded from the formulary. Industry detailing could also be countered by not-for-profit “academic detailing”¹⁰³ to optimize physician prescribing practices.¹⁰⁴

Finally, industry funding can bias continuing medical education (CME)¹⁰⁵ and clinical guidelines.¹⁰⁶ Licensing authorities should not accept industry funded CME for mandated credits. CME could, instead, be undertaken and coordinated by a body similar to the Australian NPS MedicineWise (www.nps.org.au), while clinical guideline development should, at a minimum, follow the recommendations outlined by the Institute of Medicine.¹⁰⁷

Economics of a national pharmaceutical program

Although our proposal would have large economic and budgetary implications, a detailed examination of those effects is beyond the scope of this article. Others have estimated that a national pharmaceutical program for Canada could save $7.3bn of the $22bn currently spent annually on prescription drugs in that nation, although that estimate did not contemplate the new investments in drug research, development, and regulation that we advocate.¹⁰⁸ For the US, we believe that savings on drug prices through the mechanisms detailed above could fully offset the added costs of universal, first dollar drug coverage and new public investments that we recommend.

Achieving change

Jonas Salk, inventor of the polio vaccine, eschewed patenting, declaring: “Could you patent the sun?” Today, in contrast, profiteering too often reigns, to the detriment of population health.

Our proposal calls for a fundamental reorientation of drug policy: it would make drugs more affordable for patients and society, promote innovation, strengthen efforts to assure the safety and effectiveness of medications, and upgrade the evidence available to prescribers and the public. Because drugs developed through the proposed new public pathways would remain in the public domain, they could be produced generically throughout the world, benefiting many nations.

The reforms we advocate face formidable political opposition, especially from drug firms, with those in the Fortune 500 in the US alone making total profits of $67.7bn in 2016.³⁷ However, most Americans—both Democrats and Republicans—now favor government action to lower drug prices,¹⁰⁹ and 91% of Canadians support a universal pharmaceutical benefit.¹¹⁰ These are unmistakable popular mandates for change. The trail from sentiment to policy will doubtless be arduous. Yet history is replete with examples of sweeping reforms—often enabled by unpredictable shifts in political circumstances—that overcame entrenched interests. We aim with this proposal to provide a blueprint for reform that anticipates—and may kindle—transformative changes in our nations’ pharmaceutical systems.

Contributors and sources

This proposal was drafted by a writing committee comprising Adam Gaffney (cochair), Joel Lexchin (cochair), Marcia Angell, Michael Carome, David U Himmelstein, Gordon D Schiff, Sidney M Wolfe, and Steffie Woolhandler. Other members of the US/Canadian Pharmaceutical Policy Reform Working Group were: Brook Baker, Monika Dutt, Marc-André Gagnon, Gordon Guyatt, Ritika Goel, Brian Hutchison, Richard Klasa, Michael C Klein, Danielle Martin, Barbara Mintzes, Karen S Palmer, Danyaal Raza, and Robert F Woollard.

Competing interests: We have read and understood BMJ policy on declaration of interests and declare the following interests: JL has received payments from non-profits for consulting on projects that investigated indication based prescribing and which drugs should be distributed free of charge by general practitioners. He received payment from a for-profit for being on a panel that discussed expanding drug insurance in Canada.

This proposal has been endorsed by Physicians for a National Health Program and Canadian Doctors for Medicare; authors and working group members are active in both organizations. Physicians for a National Health Program is not-for-profit organization that advocates for a single-payer healthcare system for the United States. Canadian Doctors for Medicare is a not-for-profit organization that advocates on behalf of Canada’s public single-payer system.

Provenance and peer review: Commissioned; externally peer reviewed.

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75. Olson MK. The risk we bear: the effects of review speed and industry user fees on new drug safety. J Health Econ 2008;27:175-200. 10.1016/j.jhealeco.2007.10.007 18207263

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77. Moore TJ, Furberg CD. Development times, clinical testing, postmarket follow-up, and safety risks for the new drugs approved by the US Food And Drug Administration: the class of 2008. JAMA Intern Med 2014;174:90-5. 10.1001/jamainternmed.2013.11813 24166236

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81. Lexchin J. Health Canada’s use of its priority review process for new drugs: a cohort study. BMJ Open 2015;5:e006816. 10.1136/bmjopen-2014-006816 25967989

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Published by the BMJ Publishing Group Limited. For permission to use (where not already granted under a licence) please go to http://group.bmj.com/group/rights-licensing/permissions.

Author credentials: 1. Department of Medicine, Cambridge Hospital/Harvard Medical School, Cambridge, MA 02139, USA; 2. School of Health Policy and Management, York University, Toronto, Ontario, Canada

Privacy Policy

Last updated: January 07, 2021

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.
Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Physicians for a National Health Program, 29 E. Madison, Ste. 1412, Chicago, IL 60602.For the purpose of the GDPR, the Company is the Data Controller.
Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Country refers to: Illinois, United States
Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
Facebook Fan Page is a public profile named Physicians for a National Health Program specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/doctorsforsinglepayer
Personal Data is any information that relates to an identified or identifiable individual.For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to Physicians for a National Health Program, accessible from https://pnhp.org
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Email address
First name and last name
Phone number
Address, State, Province, ZIP/Postal code, City
Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies: Cookies: What Do They Do?.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies: Type: Session Cookies Administered by: Us Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies: Type: Persistent Cookies Administered by: Us Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies: Type: Persistent Cookies Administered by: Us Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
Tracking and Performance Cookies: Type: Persistent Cookies Administered by: Third-Parties Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, for payment processing, to contact You.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

Salsa Labs: Their Privacy Policy can be viewed at https://www.salsalabs.com/privacy-policy

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

PayPal: Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full
Shopify: Their Privacy Policy can be viewed at https://www.shopify.com/legal/privacy

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
Request correction of the Personal Data that We hold about You. You have the right to to have any incomplete or inaccurate information We hold about You corrected.
Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the Facebook Fan Page https://www.facebook.com/doctorsforsinglepayer, the Company and the operator of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.

For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/full_data_use_policy

CCPA Privacy

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

Category A: Identifiers. Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.Collected: Yes.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.Collected: Yes.
Category C: Protected classification characteristics under California or federal law. Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).Collected: No.
Category D: Commercial information. Examples: Records and history of products or services purchased or considered.Collected: Yes.
Category E: Biometric information. Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.Collected: No.
Category F: Internet or other similar network activity. Examples: Interaction with our Service or advertisement.Collected: Yes.
Category G: Geolocation data. Examples: Approximate physical location.Collected: No.
Category H: Sensory data. Examples: Audio, electronic, visual, thermal, olfactory, or similar information.Collected: No.
Category I: Professional or employment-related information. Examples: Current or past job history or performance evaluations.Collected: No.
Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.Collected: No.
Category K: Inferences drawn from other personal information. Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.Collected: No.

Under CCPA, personal information does not include:

Publicly available information from government records
Deidentified or aggregated consumer information
Information excluded from the CCPA’s scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.
Indirectly from You. For example, from observing Your activity on our Service.
Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:

To operate our Service and provide You with our Service.
To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
For internal administrative and auditing purposes.
To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D: Commercial information
Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal Information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D: Commercial information
Category F: Internet or other similar network activity

Share of Personal Information

We may share Your personal information identified in the above categories with the following categories of third parties:

Service Providers
Payment processors
Our affiliates
Our business partners
Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

Sale of Personal Information of Minors Under 16 Years of Age

We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
- The categories of personal information We collected about You
- The categories of sources for the personal information We collected about You
- Our business or commercial purpose for collecting or selling that personal information
- The categories of third parties with whom We share that personal information
- The specific pieces of personal information We collected about You
- If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
  - The categories of personal information categories sold
  - The categories of personal information categories disclosed
The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request please contact Us.
The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
- Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

By email: info@pnhp.org

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if we cannot:

Verify Your identity or authority to make the request
And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
The EDAA’s opt-out platform: http://www.youronlinechoices.com/
The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

“Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
“Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

By email: info@pnhp.org

PNHP pharma reform proposal in the news

Healing an ailing pharmaceutical system highlights the need for fundamental reform

Healing an Ailing Pharmaceutical System: Prescription for Reform in the United States and Canada was unveiled May 17, 2018 at the National Press Club in Washington, D.C. (To read the full proposal, click here. To read PNHP’s press release on the proposal, click here.) Please see below for a sampling of the substantial media coverage related to the proposal.

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Video summary

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Introductory press conference

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Webinar by Dr. Adam Gaffney

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News coverage

How to fix the American drug industry
By Ryan Cooper
The Week, May 17, 2018
In America, medication is extremely expensive — and it’s getting worse. Stories of Wall Street bloodsuckers snatching up the patent on some lifesaving drug and jacking up the price by many thousands of percent are routine Continue reading…

Doctors in Canada and US call for ‘fundamental reform’ on prescription drug prices
By Cherise Seucharan
The Toronto Star, May 17, 2018
A new report written by doctors in Canada and the U.S. is calling for major reforms to lower the price of drugs. Published in the British Medical Journal, the report is the result of a two year-study by the U.S./Canadian Pharmaceutical Policy Reform Working Group. Continue reading…

US doctors propose universal health care to fix ‘dysfunctional’ system
By Ellen Daniel
Pharmaceutical Technology News, May 17, 2018
A group of 21 doctors from the US and Canada has published a proposal aimed at ensuring access to ‘safe, innovative, and affordable’ medications. Continue reading…

Rebuking Industry-Friendly Trump Plan, Doctors Offer Blueprint to Confront ‘Greed of Big Pharma’
By Jake Johnson
Common Dreams, May 17, 2018
After President Donald Trump conclusively demonstrated last week that he is unwilling to take on the pharmaceutical industry and has no “legitimate plan” to lower drug prices, a group of 21 American and Canadian doctors on Thursday unveiled an ambitious plan. Continue reading…

Can an Obscure, 100-Year-Old Patent Law Take On Big Pharma?
By Jacquie Lee
Bloomberg, May 21 2018
Proposed solutions for lowering drug prices typically hinge on sweeping transformations within the drug-supply chain, but what if there’s a more immediate solution? There is, according to Sidney Wolfe, founder of Public Citizen’s health research group. Continue reading…

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Opinion pieces

Trump’s plan won’t lower prescription drug prices. Ours would.
By Adam Gaffney, M.D.
Washington Post, May 23, 2018
The drug price reforms that President Trump recently proposed are as potent as a placebo, but not as harmless. Trump once blustered that drug firms were “getting away with murder,” but his real-life plan caused pharmaceutical stocks to surge. Continue reading…

No, raising drug prices in Canada will not help the U.S.
By Joel Lexchin
National Post (Toronto), May 18, 2018
Donald Trump’s solution to soaring American drug prices is to have other countries, such as Canada, raise their prices. This is not a new position; American officials have been advocating this approach for at least the past 15 years. Continue reading…

Only a healthy democracy will save us from Big Pharma
By Ed Weisbart, M.D.
St. Louis Post-Dispatch, June 8, 2018
I’m a physician who volunteers in safety-net clinics in St. Louis, constantly seeing patients who can’t afford the medicines I prescribe. Even patients with insurance often can’t afford their co-pays and deductibles, and many treatments simply aren’t covered by their plans. Continue reading…

Healing an ailing pharmaceutical system: economic analysis and supplemental materials

Physicians for a National Health Program and Canadian Doctors for Medicare have joined forces to develop a landmark proposal, “Healing an Ailing Pharmaceutical System: Prescription for Reform in the United States and Canada.” Below, please find an economic analysis and supplemental materials related to the proposal. To read media coverage of the proposal, click here. You may also wish to read and/or distribute our one-page handout, which includes a useful summary of the proposal.

One-page handout: Healing an ailing pharmaceutical system

Slideshow: Prescription for Pharmaceutical Reform by Ed Weisbart, M.D.

Table 1: Examples of problems in drug access and pricing in the US and Canada

Table 2: Global evidence of lagging innovation in the drug development process

Table 3: Examples of problems in industry-sponsored clinical trial design

Table 4: Examples of problems in drug approval and regulation

Table 5: Examples of problems in postmarketing surveillance of drugs

Table 6: Examples of problems in drug promotion

Table 7: Estimated effects of proposed reforms on U.S. national pharmaceutical expenditures, 2017 (includes methodology)

Tables 1-7: References

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