Written Submission for the Pre-Budget Consultations in Advance of the Upcoming Federal Budget
Recommendation 1: That the Government of Canada, through the Public Health Agency of Canada, formally recognize and support implementation of Breast Cancer Canada and REAL Canadian Breast Cancer Alliance evidence-based standards of care as a national framework to promote equitable, timely, and consistent breast cancer treatment across all provinces and territories.
Recommendation 2: That the Government of Canada invest in regulatory modernization, including reducing barriers and red tape, precision oncology infrastructure, and equitable access initiatives to accelerate timely access to innovative breast cancer diagnostics, biomarker testing, and treatments for patients across Canada, regardless of geographic location.
Recommendation 3:That the Government of Canada provide funding support to Breast Cancer Canada for the continued development and implementation of PROgress Tracker, the nation’s only country-wide breast cancer patient reported outcomes study, to inform patient-centred research, identify gaps in care and survivorship, and support improved health system planning across Canada.
In Canada, 1 in 8 women will be diagnosed with breast cancer in their lifetime, accounting for approximately 25% of new cases of cancer and 14% of all cancer deaths in Canadian women. Every year, over 5,500 Canadian women lose their lives to breast cancer, a statistic that has seen no substantial changes in 20 years. Addressing this requires a unified approach to breast cancer detection, treatment, and care, grounded in evidence-based national standards.
That is why Breast Cancer Canada brought together leading experts and patient advocates to develop the REAL Canadian Breast Cancer Alliance guidelines, a made-in-Canada framework designed to standardize and elevate the quality of breast cancer care from diagnosis through to survivorship. When care is guided by consistent, evidence-based standards, it reduces the burden on patients and the healthcare system, improving outcomes and quality of life at every stage of the journey while improving the economy.
In addition, Breast Cancer Canada’s PROgress Tracker has shed important light on the financial strain experienced by patients under 55, with 69% of Canadians agreeing that a breast cancer diagnosis would severely affect their financial plans, there is a clear and shared need for stronger support.
Breast Cancer Canada is presenting three recommendations to the federal government: standardizing breast cancer care through the adoption of the REAL Canadian Breast Cancer Alliance national guidelines, improving access to innovative treatments, and strengthening real-world data collection through the expansion of PROgress Tracker. Together, these recommendations represent a defining opportunity for Canada to become a global leader in breast cancer care, creating a more sustainable health system through optimized resource use and supporting the national economy by helping patients return to their lives and work sooner. By acting now, we can ensure that no one faces this disease without the support and resources they need.
Recommendation 1:That the Government of Canada, through the Public Health Agency of Canada, formally recognize and support implementation of Breast Cancer Canada and REAL Canadian Breast Cancer Alliance evidence-based standards of care as a national framework to promote equitable, timely, and consistent breast cancer treatment across all provinces and territories.
The REAL Canadian Breast Cancer Alliance is a dynamic coalition of multi disciplinary clinical and academic leaders from across the country dedicated to transforming breast cancer treatment.
The REAL Alliance was established by Breast Cancer Canada to address critical gaps in treatment, including a lack of national, modern, evidence-based standards that can be used by health professionals across Canada. Provincial variation in chemotherapy use has been documented across BC, Manitoba, Ontario, and Nova Scotia, with differences driven by local practice norms rather than patient need. Each year, the REAL Alliance develops and updates a series of guidelines for improving breast cancer treatment in Canada.
These clinical consensus recommendations and standards of care are developed through a structured and collaborative process designed to ensure comprehensive, evidence-based treatment.
These national consensus recommendations focus on various important topics in breast cancer treatment, including:
- Treatment of HER2+ Breast Cancer
- Clinical Breast Cancer Staging Criteria (Stage 0-IV)
- Treatment Management of HR+ Early Stage Breast Cancer
- Treatment Management of HR+ Metastatic Breast Cancer
- Treatment Management of Triple Negative Breast Cancer
The Public Health Agency of Canada (PHAC) has been directly involved in the funding and/or development of guidelines in several other instances, such as:
- The National Advisory Committee on Immunization’s recommendations on the use of vaccines in Canada, and
- The National Advisory Committee on Sexually Transmitted and Blood-Borne Infections interim guidance on the treatment of uncomplicated gonococcal infections.
With the precedent of PHAC adopting expert advisory recommendations as federal health guidelines, Breast Cancer Canada recommends that the Public Health Agency of Canada adopt the REAL Canadian Breast Cancer Alliance recommendations and treatments as standard guidelines.
This would ensure that all breast cancer patients across Canada have equitable and timely access to care, and aligns with the fact that nearly all Canadians (95%) believe that public healthcare policy should be heavily influenced by recommendations from industry experts, positioning Canada as a global leader in breast cancer research, diagnosis and treatment.
Recommendation 2: That the Government of Canada invest in regulatory modernization, including reducing barriers and red tape, precision oncology infrastructure, and equitable access initiatives to accelerate timely access to innovative breast cancer diagnostics, biomarker testing, and treatments for patients across Canada, regardless of geographic location.
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Every patient deserves timely access to the latest diagnostics and therapies, regardless of geography, age, or socioeconomic status. Regulatory barriers and red tape in Canada prevent companies from being able to introduce their therapies into the Canadian market in a timely, efficient way. Additionally, health systems across the country are not created equal. It is not uncommon for one province’s health system to be ill-equipped to deliver innovative therapies while others can.
If Canada streamlines its regulatory pathways, and creates a competitive market for innovation, it can attract investments that create high-value jobs and contribute to the country’s long-term, economic growth. Delayed access to breast cancer drugs can also have a direct effect on overall survival, progression free survival and life years lost. Additionally, those with breast cancer, and survivors are also faced with a higher than average financial toxicity due to costs not covered by insurance and sometimes, the inability to work.By ensuring rapid access to innovation, the government can reduce healthcare utilization costs and support the continued economic participation of affected Canadians.
All levels of government have a role to play in ensuring equitable access to innovative solutions for Canadian patients and there have been some efforts made in Canada to address some of these barriers and improve patients’ timely access to treatments.
For example, Project Orbis is an initiative of the U.S. Food and Drug Administration (FDA) Oncology Center of Excellence, which aims to give patients faster access to promising cancer treatments through collaborative efforts with seven regulatory agencies, including Canada.
- Project Orbis partners work together on the review of submissions for cancer drugs through concurrent reviews and information sharing, which can lead to earlier access to new treatments.
- Itovebi, a drug approved through Ontario’s Funding Accelerated for Specific Treatments (FAST) program which fast tracks drugs that have received a positive final CDA-AMC recommendation and are a part of Project Orbis, took 12 months compared to the average wait time of nearly two years for public access.
While Project Orbis is a step in the right direction of getting patients faster access to better cancer treatments, there are still challenges with the broader approval process for accessing new treatments across Canada.
That is why we are calling on the federal government to invest in policies and investments that reduce barriers to cutting-edge therapies. By ensuring rapid access to innovation, the government can reduce healthcare utilization costs and support the continued economic participation of affected Canadians.
Recommendation 3: That the Government of Canada provide funding support to Breast Cancer Canada for the continued development and implementation of PROgress Tracker, the nation’s only country-wide breast cancer patient reported outcomes study, to inform patient-centred research, identify gaps in care and survivorship, and support improved health system planning across Canada.
Longitudinal, real world health data and effective use of Artificial Intelligence (AI) have the potential to enhance early detection, improve personalized treatment, and provide clinicians with treatment pathways to support informed decision making. AI improves the reliability of self-reported data, guides patients through complex questionnaires, and structures pathology reports and can even identify when a participant may need a break, creating a more positive data collection experience.
Breast Cancer Canada’s national study, PROgress Tracker, collects real world evidence from patients and demonstrates the power of AI in patient-centered care. It captures the full patient journey, from diagnosis to treatment to long-term survivorship. This data can inform policy, helps to identify gaps in care, and advance treatments based on real-world experience.
Currently, PROgress Tracker is primarily a self-referred research study where participants complete validated questionnaires every 3 months, tracked over a 10-year period. Data from the PROgress tracker has already revealed a disproportionate level of financial hardship in survivors under 55 – a finding which has informed some of our previous advocacy efforts.
Broader adoption amongst clinicians and awareness of the research study would help to expand the availability of diverse, national real world data related to breast cancer diagnosis and treatment, in turn helping to spur innovation and improve health outcomes. Breast Cancer Canada has undertaken efforts to expand the reach of the PROgress tracker, but within our current mandate and competing priorities, more support is needed to make meaningful changes on strengthening data collection through the PROgress tracker.
Federal funding of $850,000 would support the core infrastructure and outreach activities needed to expand PROgress Tracker nationally. This includes investment in database development and management through academic partners at the University of Calgary, study ethics oversight, training of clinicians and volunteers, and sustained awareness and education campaigns across Canada. Funding would also support partnerships with non-profit patient organizations and community recruitment networks to ensure the study reaches a broad and diverse population of patients and survivors.
This is why we recommend that the Government of Canada provide funding to BCC to support advocacy efforts for adoption of PROgress Tracker throughout the country.
Ultimately, the path forward for breast cancer care in Canada today is reflected in our recommendations for improving access to the best treatments and supporting the resources and innovation that support the person going through the treatment.
By establishing national standards of care, accelerating access to innovative therapies, and building a better understanding of the patient journey through real-world data, we can create a system that is as compassionate as it is effective. Breast cancer touches the lives of hundreds of thousands of Canadians, and the opportunity before us is to ensure that when it does, every person has the resources they need to not only survive, but thrive.
Breast Cancer Canada (BCC) is the only national breast cancer organization in Canada with a dedicated focus on research, advocacy, and education. Since 1991, BCC has been committed to saving lives through cutting-edge research and advancing patient-centred care through four core pillars:
Access & Equity: Developing and sharing national standards of care so every breast cancer patient, regardless of location, has access to high-quality breast cancer care.
Research: Investing in precision oncology and innovative treatments to improve outcomes for patients across Canada.
Patient-Focused Advocacy: Championing policies that enhance breast cancer screening, treatment access, and patient survivorship nationwide with an emphasis on elevating the patient voice.
Education: Providing Canadians with accurate, timely information and outcomes related to breast cancer prevention, screening, diagnosis, treatment, and survivorship.
