Is Independent Vaccination Fair and Wise?

Press Release:
Is Independent Vaccination Fair and Wise?

Jakarta, March 2 2021. On February 27 2021, LaporCovid-19 held a public discussion with the theme Is Independent Vaccination Fair and Wise?. This discussion was held in response to the decision of the Minister of Health of the Republic of Indonesia to allow the implementation of independent vaccines by business entities for their employees, as written in Minister of Health Regulation Number 10 of 2021 concerning Implementation of Vaccinations in the Context of Overcoming the COVID-19 Pandemic. The government claims that independent vaccines are necessary to achieve the target of group immunity (herd immunity) because more groups will be vaccinated with the involvement of the private sector. However, instead of achieving group immunity, the independent vaccine scheme is actually problematic, both from a legal perspective and the principles of public health science. In discussion Is Independent Vaccination Fair and Wise?, Director of YLBHI Asfinawati explained the issue of independent vaccines from a legal perspective, while epidemiologist from Griffith University, dr. Dicky Budiman, conveyed his views from the perspective of public health science.

Asfinawati, Director of YLBHI, explained that:

1. Vaccine priority needs to be given to vulnerable groups, namely health workers and the elderly, in accordance with Article 28H paragraph (2) of the 1945 Constitution and Article 5 of the Health Law. Article 28H paragraph 2 of the 1945 Constitution emphasizes that everyone has the right to receive special treatment to achieve equality and justice. That is, resources in the field
health care, including vaccines, needs to be given to vulnerable groups as a form of special treatment by the state. The problem is, an independent vaccine scheme could thwart this plan. Because, in the independent vaccine scheme, vaccines are given to company employees, not vulnerable groups.

2. The independent vaccine regulatory framework is written incompletely in one regulatory document. Article 4 paragraph (1) Presidential Regulation Number 14 of 2021 states that Vaccine procurement is carried out, among other things, through direct appointment to the provider business entity, but it is not explained who the provider business entity is. These details are only listed in Minister of Health Regulation Number 10 of 2021. This can cause confusion in the community.

3. Article 6 paragraph (6) Minister of Health Regulation Number 10 of 2021 states that The vaccination needs plan as stated in paragraph (1) and paragraph (4) is a reference in procuring the COVID-19 vaccine, supporting equipment and logistics required for implementing vaccination, both for program vaccination and mutual cooperation vaccination.. This means that implementing independent vaccines not only requires vaccine availability, but also supporting equipment, logistics and distribution processes. However, the question is, is this supporting equipment currently available in sufficient quantities and not experiencing shortages? So, is the distribution of government program vaccines going well and is there no shortage of people and facilities?
This critical question is worth asking because in a pandemic situation, vaccines and equipment are items that are sought after by many people, so they have the potential to experience shortages. In this situation, it is worth asking whether the procurement of independent vaccination support equipment will not interfere with the procurement of support equipment for the government-run vaccination program?

4. Article 11A paragraph 2 of Presidential Regulation Number 14 of 2021 is a form of shifting government responsibility to private entities. The article states that The government takes over responsibility for providing vaccines (safety, efficacy and immunogenicity) as long as the production and distribution process has been completed. fulfill good drug manufacturing and/or good distribution methods. This means that when a citizen experiences a negative impact from a vaccine, the government will return the responsibility to the vaccine manufacturer. Based on the legal track record, privatization of public goods to the private sector causes problems because there is no party who will be responsible when problems occur.

5. The action of throwing away government responsibility is also stated in Article 9 of Minister of Health Regulation Number 10 of 2021. According to that article, the implementation of COVID-19 vaccination for priority groups can be carried out through an independent independent vaccine program. This means that vaccines for priority groups can be carried out by private parties, and are not the government's responsibility.

Meanwhile, Dr. Dicky Budiman reminded that the function of vaccines is based on epidemiological studies and the role of the state in ensuring the achievement of this function:

1. Vaccines are health products that have advantages and disadvantages, so they need regulation and the government needs to play a role in regulating regulation and distribution to ensure public health.
2. Providing equal access to vaccines is a major component of human health rights (WHO, 2012). Therefore, there is a human obligation for the government to provide equal access to vaccines.
3. Quote UN General Assembly Resolution (2020), vaccines and the implementation of vaccination are public good, not an economic good where availability is based on market needs and demand. When vaccines are positioned as economic goods, the function of vaccines to prevent transmission will be difficult to achieve.
4. The function of vaccines in controlling pandemics, based on epidemiological studies, is:
   a. To prevent and reduce the number of cases and reduce the death rate by protecting the most vulnerable groups.b. Saving more and more lives, not saving the economy. To save many lives, the priority for vaccines is vulnerable populations.c. Provide social benefits. Vaccines are not for economic needs, but save lives, reduce mortality rates, prevent serious illness. Independent vaccines are not in line with the function and purpose of vaccines based on epidemiological studies because vaccines are given to employees, not vulnerable groups with a high risk of exposure.
5. In a situation of limited vaccine availability, it is necessary to determine priority groups and also optimal use of vaccines by the government so that the vaccine will be appropriate, beneficial and on target. Vaccines that are able to reduce symptoms or severity of disease and prevent death need to be given to individuals, cities or provinces that tend to have populations that will suffer worse conditions if infected with COVID-19. The government needs to create an effective program so that the distribution of the COVID-19 vaccine is adequate and the private sector only supports this program. Effective vaccine distribution and also administering vaccines to vulnerable groups determine the success of the vaccine.
6. The private sector is only a supporter in vaccine implementation and an appropriate strategy is needed:
   a. Private involvement could be an option to increase vaccination coverage. However, when you want to increase coverage by involving the private sector, you must refer to the 3 functions of vaccines based on epidemiological studies. b. Presidential regulations and Minister of Health regulations need to clearly define the functions and roles of the private sector if the private sector is to be involved in vaccine implementation. WHO determines that the function of private services is
   collaboration and support the health system and epidemiological function of vaccines (saving the most lives, protecting groups at greater risk, and ensuring social benefits).
7. Several strategies need to be implemented because of the risks and challenges in involving the private sector in the vaccination program: a. United Nations Office on Drugs and Crime (UNODC) or the United Nations Office on Drugs and Crime has seen the risk of corruption in vaccines, namely the entry of quality vaccines substandard, vaccine theft, nepotism in vaccine distribution, corruption in vaccine procurement. Therefore, UNODC emphasizes that human rights principles must be the central focus in handling the public health crisis. Management based on public health must be the reference, namely focusing on prevention, promotive and curative, not on policies based on an economic focus.b. There is still little scientific evidence that private involvement in vaccination programs can have an impact on equitable access to vaccines. There are still many countries that have low flying hours in terms of private sector involvement in providing vaccine services as a public good. Many countries also experience problems and obstacles when handing over responsibility for public services to the private sector.c. When the private sector is involved in providing vaccine services, mechanisms and regulations are needed to regulate the quality of the vaccine service. The Australian government had involved a third party in implementing the vaccination, but problems occurred in its implementation, namely administering the wrong dose. Strong collaboration between the private sector and government is also needed, such as training and increasing the capacity of the private sector in providing public services for administering vaccines.d. The government needs to ensure that the vaccines used for the independent vaccine program are halal vaccines. Through this public discussion, it is hoped that the government will again use the principles of epidemiology and public health in developing vaccine implementation strategies. This is important to achieve vaccine goals that are consistent with scientific evidence and legal and human rights perspectives.

Contact:
Amanda Tan, LaporCovid-19 volunteer (+62- 858- 6604-4058)

Please download this Press Release via the following link.

Please download the presentation material by Dr. Dicky Budiman via the following link.

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