[Ip-health] Oxfam comments on WHO Roadmap to access to medicines

Mohga Kamal-Yanni mkamalyanni at Oxfam.org.uk
Tue Sep 11 07:18:32 PDT 2018

Oxfam’ comments on The WHO Roadmap for access 2019‐2023 -Comprehensive 
support for access to medicines and vaccine 
The roadmap is an important step to define WHO work on medicines. It 
defines ten critical issues that are essential for access to medicines and 
identifies the deliverables under each issue. Clearly, intensive work has 
gone into designing the roadmap building on WHO’s past and on-going work 
and taking into account the challenges in global health. However, WHO 
needs to elaborate on a number of issues in order to make the roadmap 
effective in achieving its goals. 

General comments: The roadmap needs to: 
1.       Highlight how the current changes in global health such as the 
epidemiological changes, impact access medicines in the introduction. 
2.       Focus the 10 topics as clear objectives- what would the 
deliverables intend to achieve by 2020 (see ideas below). 
3.       Emphasize the importance of diagnostics: New technology has 
increased the value and importance of diagnostics in public health. 
However, there is a huge need for R&D for new diagnostics for many health 
conditions including the rising antimicrobial resistance, NCDs in addition 
to neglected diseases. The high price of available diagnostics is a 
barrier for people to get correct diagnosis.   
4.      Emphasize the gender dimension of access to medicines. Gender 
differentiation goes well beyond maternal health. For example, women bear 
the brunt of out-of-pocket spending by their extra              unpaid 
5.      Incorporate specific recommendations from the High Level Panel on 
access to medicines. 
6.      Clarify the deliverables that have specific timeframe and those 
that require continuous work. 
Specific comments 
1)        Research and development for medicines and vaccines that meet 
public health needs 
Objective: R&D and financing for medicines, vaccines and diagnostics that 
meet public health needs. 

The roadmap needs to include a strong WHO role in: 
1.        Investigating models of delinking financing of R&D from the 
price of resulting products in relation to neglected diseases and AMR and 
across a broad spectrum of diseases. 
2.        Advocating and supporting countries to increase their funding 
for R&D including investing in national research institutions. 
3.        Including NCDs as a priority for R&D especially medicines and 
diagnostics appropriate for poor settings. 
4.        Supporting countries to prioritize financing for medicines, 
vaccines and diagnostics through increasing their health budget. 
5.        Prioritizing setting global standards for R&D and undertaking 
preliminary work for a global convention on R&D. 
2)        Fair pricing and financing policies 
Objective: Fair pricing policies and practices that result in affordable 
medicines, vaccines and diagnostics. 

1.        The focus on cost effectiveness in the document ignores the fact 
that high price makes many medicines/vaccines/diagnostics “not” cost 
effective. Therefore, the focus of the deliverables should be on how to 
decrease price in order to make a health product cost effective. Balancing 
“health gain” with “cost” requires challenging the high prices and not 
taking the current price as a given in calculating such balance. 
2.        Need to include specific actions for middle income countries. 
MICs have been excluded from global deals on low prices on medicines and 
vaccines. Some countries changed status over night from low to middle 
income without real change in poor people’ income or in the country’s 
spending on health. 
3.        Given that high price is a global challenge even in high income 
countries, WHO should be promoting initiatives that address the 
fundamental causes of high prices. 
4.        The definition of “fair price” needs further work to clarify 
because “sufficient market incentive” can actually mean high price.   
5.        Transparency on pricing and prices needs to be emphasized. Price 
reporting mechanisms such as the WHO reports on medicines for specific 
diseases should be expanded to include all medicines. This will require 
supporting the countries to enhance their capacity in data collection and 
in setting up transparency standards to make the prices publicly 
6.        WHO’ new work on biosimilar medicines needs to be prioritized. 
3)        Application and management of intellectual property to 
contribute to innovation and promote public health 
Objective: Intellectual property application that prioritizes public 
health and access to medicines. 

The road map needs to: 
1.        Emphasize and clarify WHO role in bilateral and regional free 
trade agreements. The role should include supporting the assessment of the 
health impact of an agreement during the negotiation and after it comes 
into effect. It is critical that WHO warns against provisions that can 
have negative impact on public health. 
2.        Support countries facing pressure when implementing any TRIPS 
3.        Protect the inclusion of TRIPS flexibilities in international 
arena, such as in relevant UN processes and high level meetings. 
4.        Promote and support countries’ use of the TRIPS flexibilities to 
enhance access to medicines. 
4)        Procurement and supply chain management 
Objective: Effective procurement systems that cover both public and 
private sectors. 

The roadmap needs to emphasise: 
1.        Prioritising market intelligence to predict shortages and 
establish mechanisms to deal with shortages. 
2.        Supporting governments’ actions to regulate the private sector 
involved in procurement and dispensing health products. 
5)        Appropriate prescribing, dispensing and use 
Objective: Health products are prescribed, dispensed and used in a way to 
enhance public health. 

The roadmap needs to emphasise WHO role in: 
1.        Supporting countries to ensure continuous in-service training 
for health workers for the appropriate prescribing and dispensing of 
2.        Supporting countries to enhance public awareness of the proper 
use of medicines. 
6)        Regulatory systems to ensure quality, safety and efficacy of 
medicines and vaccines 
Objective: Safe quality medicines, vaccines and diagnostics via effective 
regulatory systems, policies and practices. 

The roadmap should emphasise WHO strong role in: 
1.        Ensuring that global initiatives that target private sector role 
in procurement and dispensing medicines guarantees? the quality of 
medicines by, for example, not allowing the sale of medicines by the 
informal sector. 
2.        Expanding the pre-qualification program to include needed health 
products starting with the essential medicines list and including training 
and supporting national and regional regulators. 
3.        Supporting national capacity for effective regulation and 
monitoring the quality of products across private and public sectors. 
7)        Preparedness for emergencies 
Objective: Health products are available and affordable to respond to 
health emergencies. 

The roadmap needs to: 
1.        Clarify the general stream of work that responds to any general 
emergency e.g. the health products supply during an earthquake differ from 
specific medical emergencies such as Ebola. 
2.        Include actions to make products affordable and to secure 
systems of coordinated international support in purchasing products that 
strengthen national systems during health emergencies. 
8)        Good governance 
Objective: good governance is implemented through the whole chain of 
health products from R&D to patients’ use. 

The roadmap needs to include: 
1.        Supporting countries to regulate the private sector especially 
the informal sector. 
2.        Advocating for civil society involvement in monitoring and 
accountability mechanisms. 
3.        Including specific targets on transparency in all aspects of the 
chain of health technologies from R&D to dispensing.   
9)        Collection and use of key data on medicines and vaccines 
Objective: Countries implement and use good data collection systems for 
health products. 

The roadmap needs to include: 
1.        Supporting countries to include data from private sector 
procurement and dispensing of health products 
2.        Supporting countries to collect gender-differentiated data. 
10)        Health workforce capacity for access to medicines and vaccines 
Objective: Health workers have enhanced capacity in all aspects of access 
to medicines, vaccines and diagnostics. 

The roadmap needs to emphasise WHO role in: 
1.        Supporting mechanisms to ensure that health workers have easy 
access to evidence-based un-bias medical information that is free from 
market incentives. 

Finally, WHO should ensure appropriate funding for the implementation of 
the roadmap. 

Best wishes  مع أطيب التمنيات   
Mohga -Dictating to the computer so please forgive silly mistakes 
Dr. Mohga Kamal-Yanni
Senior health & HIV policy advisor, Oxfam GB 
Editor of www.globalhealthcheck.org 
John Smith Drive, Oxford, OX4 2JY, UK (GMT, CET-1, EDT+5, EST+6)
UK Mobile   + 44 (0)777 62 55 884 
Follow me @MohgaKamalYanni

Oxfam works with others to overcome poverty and suffering.

Oxfam GB is a member of Oxfam International and a company limited by guarantee registered in England No. 612172.
Registered office: Oxfam House, John Smith Drive, Cowley, Oxford, OX4 2JY.
A registered charity in England and Wales (no 202918) and Scotland (SC 039042)

More information about the Ip-health mailing list