[Ip-health] Oxfam submission to the WHO Draft Concept Note Concerning the General Programme of Work

Mohga Kamal-Yanni mkamalyanni at Oxfam.org.uk
Fri Oct 13 11:20:33 PDT 2017

Oxfam comments to WHO 13th General Programme of Work
This document provides Oxfam comments on the Draft concept note towards 
WHO’s 13th General Programme of Work 2019–2023 (GPW13) made available on 
the WHO website Keep the World Safe, Improve Health, Serve the Vulnerable. 
Draft Concept Note towards WHO’s 13th General Programme of Work 2019–2023 
is available here: http://who.int/about/gpw-thirteen-consultation/en/ 
 and open for comment from until Friday 13 October 2017. This is in 
addition to the submission of Acton for Global Health. 
Oxfam welcomes the new WHO DG prioritization of Universal Health Coverage 
(UHC) and the right to health and the emphasis on the health of women and 
marginalized groups in his first 100 days including at the 2017 United 
National General Assembly and the WHO regional committees. We also welcome 
the nomination of a diverse and competent new leadership team. 
Oxfam appreciates the sharing of this concept note and the establishment 
of a process for consultation and engagement in the development of the 
13th WHO General Programme of Work. 
This is an extremely important moment for WHO and for global health. It is 
essential that this new General Programme of Work empowers not only WHO 
but also governments, civil society, and the whole UN system to address 
global health challenges and opportunities, as well as to adapt to be able 
to respond to the commitments made in the Agenda 2030 Sustainable 
Development Goals (SDGs) framework. 
General comments:
Oxfam would like to share the following general comments: 
·       Oxfam welcomes the priorities and directions outlined in the 
concept note. There is close alignment among the five leadership 
priorities, highlighting the strategic direction proposed, and the 
assessment of needs that Oxfam witnesses throughout our work on health and 
·       The concept note needs stronger recognition of the global crisis 
of innovation and access to medicines and the links between this crisis, 
UHC and Agenda 2030 objectives of the Sustainable Development Goals. It 
should reference the strategies needed to stop the rationing of essential 
medical care due to high prices or lack of innovation in health 
·       As the concept note appropriately reflects, the world needs a 
strong WHO. This requires Member States to appropriately resource WHO and 
to enable the organization to have the authority to independently 
implement its mandate - free from conflict of interest. This includes 
providing data and technical guidance and convening to set up new norms. 
WHO should also call on governments and non-governmental actors to amend 
their policies that could have negative impact on public health. 
·       Oxfam agrees with the WHO recognition that some of the most 
significant health “gains” originate in policies from sectors outside of 
health and, thus, the notion that all the SDGs are health related. We 
would like to suggest that the draft also recognize that the most 
significant “threats and challenges” to health also originate from sectors 
outside of health, such as the impact that intellectual property monopoly 
protections pursued in trade agreements have on innovation and access to 
medicines and other health technologies. It is therefore important for the 
WHO work plan to set up a clear intersectoral work strategy and to 
leverage the mandates and expertise within the UN system in order to adapt 
the global health response to countries’ needs. For example, the WHO 
should recognize and enable better responses at global and national levels 
to the interdependence between health and trade, development, human rights 
and inequality. 
·       It is essential that WHO maintain and strengthen its normative and 
technical functions, which constitute a role that nobody else can play and 
that has a huge impact at country-level. For example, there should be an 
emphasis on the important role of the WHO in creating essential medicine 
lists and on the pre-qualification programme for medicines, vaccines and 
·       It is important to highlight the critical value that WHO’s 
convening role to develop global norms, conventions, regulations, and 
frameworks has played and needs to continue playing. The Framework 
Convention on Tobacco Control and the International Health Regulations 
were landmark normative processes that WHO needs to continue its work in 
implementing. Oxfam agrees with the comments of the government of India 
(at the 70th SEARO regional committee meeting) that the time has come for 
WHO to lead on the negotiations for a global Research and Development 
(R&D) agreement which would provide global norms for funding R&D as a 
public good, as recommended by many, including the WHO CEWG (Consultative 
Expert Working Group on Research and Development: Financing and 
Coordination) report and the UN Secretary General’s High Level Panel on 
Access to Medicines.
·       As the concept note recognizes, while it is important to set up 
norms and strategic plans, it is vital to then ensure these are 
implemented. WHO already has strong mandates that have yet to be funded 
and implemented. For example, it is critical for the WHO to be able to 
lead on the implementation of existing mandates like those included in the 
WHO Global Strategy and Plan of Action on Public Health, Innovation and 
Intellectual Property and the resolutions adopted to follow up from the 
CEWG. WHO has not sufficiently prioritized the implementation of these 
existing mandates, and therefore in its next work programme the WHO needs 
to prioritize implementing plans and frameworks relevant to access to 
medicines and innovation. 
·       Beyond the essential implementation and resourcing of existing WHO 
mandates, WHO must go further. The 2030 Agenda for Sustainable Development 
requires a broadening and adaptation of WHO mandates on access to 
medicines and innovation in order to respond to the universality and 
sustainability of the new goals. 
Specific Recommendations: 
A WHO work programme and strategy that responds to the 2030 Agenda for 
Sustainable Development needs to:
·       Recognize and address the challenge of lack of access to medicines 
and innovation due to a broken innovation system. The challenge has now 
become global as it affects UHC ambitions in all countries, irrespective 
of their development or economic level. 
§       Oxfam welcomes the creation of a cluster on essential medicines 
and hopes that the increased attention and resources will ensure that WHO 
plays its leading role in securing quality health technologies that are 
available and affordable for all. WHO should ensure that any new cluster 
addressing medicines, vaccines and diagnostics fully integrates R&D and 
access into an integrated strategy. 
§       WHO should provide normative and political assistance to all 
countries to facilitate the use of the TRIPS flexibilities to promote 
price-lowering competition and the creation of innovation policies that 
can deliver a public return on public R&D investment. 
§       WHO should expand its role in setting priorities and coordinating 
health R&D for medicines, vaccines, diagnostics and other health 
technologies, while ensuring that such medical tools are of assured 
quality and are available, affordable and accessible for all. Efforts by 
WHO to help R&D funders implement and increase policy coherence on R&D 
norms and principles should be strengthened and prioritized – for example 
through the work of the WHO CEWG, the WHO Blueprint for R&D for epidemics 
and the global stewardship and development framework for antimicrobial 
resistance (AMR).
§       WHO should expand activities to improve transparency: High 
medicine prices are often due to the pervasive secrecy surrounding health 
technologies’ development costs. WHO can and should play a leading role to 
expand transparency – building on successful efforts to expand clinical 
trial data transparency as well as transparency of pricing, most notably 
through the Vaccine Product, Price and Procurement (V3P) initiative. WHO 
could do more to clearly outline the cost and investments for R&D, as well 
as to expand efforts to improve patent, pricing and registration 
o       WHO should ensure that strategies address the unmet needs of all 
those left behind, especially vulnerable populations, refugees and 
internally displaced persons. Nearly 60 million people are currently 
fleeing conflict or persecution around the world. Millions of refugees 
face dangerous and often inhumane conditions without access to medical 
care, while many others remain wholly excluded from existing health care 
o       As recognized in the synthesis report on the post-2015 development 
agenda by the former United Nations Secretary-General Ban Ki-moon, there 
is a need to address the challenges caused by the existing policy 
incoherence in international, regional and domestic legal and policy 
frameworks. Such incoherence has negative impacts on public health. For 
example, governments’ obligations under human rights laws clash with their 
adoption of the investor-state dispute settlement mechanism in trade 
agreements that could stop governments from regulating inappropriate 
marketing of products that can damage public health. 
o       There is a great need for WHO leadership to prioritize the 
evaluation and implementation of the recommendations that are included in 
the UN High Level Panel on Access to Medicines at the WHO, the UN and 
other all other relevant forums. 
o       The achievement of the SDGs requires a high-level UN and 
whole-of-government approach to Health and Equity, beyond the essential 
role of Ministers of Health at the World Health Assembly. WHO needs to 
work better with the whole UN system to promote policy coherence for 
health and equity. 

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
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