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15 October 2001 HAI comments on the paper, "Updating and disseminating the WHO Model List of Essential Drugs: the way forward" |
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Dear Dr. Hogerzeil: ________________________________________________________________________________________ |
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Health Action International |
HAI Africa
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15 October 2001 |
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________________________________________________________________________________________ Dear Dr. Hogerzeil: Health Action International* appreciates having the opportunity to provide our comments on the document Updating and Disseminating the WHO Model List of Essential Drugs: the way forward (revised version 10 September 2001). Before offering our comments on the specific issues identified by WHO specifically for reaction, we would like to make the following overarching points:
We commend WHO and members of the expert committee for all of the work that has gone into identifying ways to improve the model list. The proposed way forward is sound, feasible and it will address important information needs. The model list is an essential public health care tool for the vast majority of countries, especially in those that are resource poor. It is vital that WHO keep it up-to-date, so we strongly urge WHO to have the expert committee meet in early 2002, as the last update was in 1999. We also fully endorse these current efforts to ensure ways are being found to make the model list an even better and more useful tool. We therefore strongly support a final version of this paper being submitted to the director general for discussion and decision at the 109th session of the WHO Executive Board in January 2002 so that these changes can start to be implemented, as much as feasibly possible, during the next updating process. Below are our responses to the specific issues identified by WHO for comment. Issue 1: Description of Essential Drugs (selection criteria and conditions for provision) The World Health Assembly (WHA) in its resolutions (WHA 28.66 and WHA 31.32) endorsed the need to provide essential drugs at reasonable cost. The latest description of essential drugs, as defined by the expert committee, i.e., the competent technical body, in 1999, is clearly based on the language and intent of WHA resolutions, and therefore we support and endorse this description. Issue 2: Categories of drugs on the Model List 2.1. We support the proposal of maintaining two categories, i.e., the
core and complementary one, with any drugs that previously would have
been labelled "reserve" being integrated into the complementary
category if they qualify for inclusion on the list. Issue 3: Structure of the Model List 3.1. We support any effort to revise the list to make it easier and
more useful to use. Simplicity and consistency should be priority criteria
in any systematic review. Issue 4: Steps for reviewing an application 4.1. We support the proposed process outlined for reviewing an application. Issue 5: Presentation of the Committee's recommendations We support the proposed approach to speed and increase access to the latest model list, the reasons for the recommendations, notes and other relevant information. Issue 6: External participation to the review process by the Committee The proposed procedure for updating the EDL provides the most equitable way for all interested parties to participate in the discussion during the review process. This also allows all parties to give their input openly and at the most opportune time. After all inputs have been considered, the technical body, i.e., the Committee, should be allowed to make its recommendations in a totally independent position. We therefore support the recommendation that representatives of the healthcare industry or patient advocacy groups will not be invited as observers. We also propose that (a) a clear process for appeals be set and (b) there is full transparency of the criteria for membership in the Committee, e.g., minimum technical qualifications and credentials needed and full disclosure of competing interests. The final choice of members should ensure their competency and independence. The secretariat should take due care for equitable geographic representation and representation of women on the committee. Members should be listed in the EDL library of information, including a short summary of their qualifications. Issue 7: Systematic review of evidence for drugs on the model list We support a full systematic review, as proposed. Over time as more information becomes available via the internet, WHO should consider providing links to the major evidence sources. Issue 8: Organizing the WHO Essential Drugs Library The WHO list is considered one of the most important public health tools for many developing countries and health care service providers. For some it may be the only technical document available. We therefore strongly endorse the additional information and the creation of the essential drugs library. We also support cross referencing to other fields, e.g., the ATC and DDD be added. Linkages with some of the existing pricing databases would address some of the complexities that may arise in providing cost information. Issue 9: The next meeting of the Committee Keeping the model list updated should be seen as a priority public health task. The value of the list depends, in part, on the timeliness of the information. The committee should meet in early 2002. The updating work of the expert committee should not be linked in any way to the status of this paper and/or the recommendations made in it in WHO deliberations. It is our hope that these comments are useful. We wish you every success in finalising the recommendations. Sincerely yours, K. Balasubramaniam, coordinator HAI Asia and the Pacific Beryl Leach, coordinator HAI Africa
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