[Ip-health] Oxfam comments on WHO Roadmap to access to medicines
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.
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
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
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
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
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
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
Finally, WHO should ensure appropriate funding for the implementation of
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
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