For some of the larger companies, this could lead to an increased fee, whilst for many of the smaller companies, this will lead to a reduced fee.
When the fee for participants in the Norwegian NMVS was first agreed between the organisations representing MAHs in Norway it was agreed to share the costs of establishing and operating the NMVS on an equal basis, so that every MAH received an equal share of the total cost.
This model was evaluated in 2019 with input from several companies of various size and product structure. The feedback was that the current model was predictable and easy to understand, but also that a flat fee per. MAH (currently NOK 52.000) did not truly reflect the activity generated on the system. We see that some of the largest companies in the market are only represented by one or two MAHs, whilst many niche providers are represented by five or more MAHs and start-up’s with minimal sales pay as much as the largest companies per. MAH, creating an uneven share of the cost burden for operating the NMVS.
A change in the fee model was broadly supported provided that a new model would be predictable, easy to calculate and consistent over time. The revised model has been presented and accepted by LMI and Parallellimportørforeningen. Based on the feedback Nomvec, therefore, presents a new fee-model for 2021, 2022 and 2023.
Unfortunately, the true number of uploaded packs, verification and dispense transactions is currently not a measure that is available for budgeting or fee calculation, as this would have been the most accurate measure for cost allocation. The revised model will, therefore, be partly based on actual revenue to calculate the fee.
New entrants will still be charged a new-entrant fee of NOK 30.000.
As of 2021, the NMVS fee will be split 50/50 between a flat fee and a sales-based fee. For 2021 the new model will be calculated as follows:
- A flat fee of NOK 27.500 per. MAH
- A new fee based on reported (actual) sales (aka. GIP) for 2020 of between 0,045% and 0,055% of sales. The exact fee will be calculated early February 2021 based on net sales (as reported to the NCA). For companies that have not reported net actual sales we will use sales data (AIP) as reported from the pharmacies.
We hope that by making these changes we have created a model that compensates more for the differences between the companies and a model that distributes the cost more evenly between the participants.
Download the letter with information of change in fee model for 2021 for the Norwegian Medicines Verification System here: