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21 Recommendations for Open Vaccination

Information about vaccine purchases and distribution is not open yet. We review the Open Government Partnership recommendations for Governments to make it happen.

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We are open government

By Laura Ortiz. Published: May 14th 2021

Access to COVID-19 vaccines is necessary to save lives and indeed to enable economies to recover. In this context, open government can be a valuable tool to mitigate corruption risks, build trust and ensure that vaccines are delivered to the people who need them most.

Citizens have the right to know how public money is spent and what measures are taken to protect their health while public money is actually used for the benefit of all. Governments have heavily funded vaccine research, manufacturing, and distribution. Still, in most cases, they are not disclosing how funds are granted, nor have they published the agreements signed with the pharmaceutical companies, which are already distributing the vaccines in different countries. As recently as last week, Joe Biden threw his support behind waiving intellectual property rights for COVID-19 vaccines, as previously requested by other world leaders. However, more than that is needed.

The Open Government Partnership (OGP) has published a vaccine-related handbook for governments. It provides 21 recommendations for researching, purchasing, distributing, and monitoring vaccines under open government principles. The publication is part of its series of “Open Government and Coronavirus Guides.”

This initiative follows the path set by other organizations, such as Open Contracting Partnership (OCP), multiple academic publications, and journalistic investigations, highlighting the importance of transparency, accountability, and citizen engagement against the skepticism generated around the entire vaccination process. In this regard, together with the Palta Network, we researched the legal and tax benefits that pharmaceutical companies obtain in the purchase of vaccines. You can find the data used in this research in our dashboard application “COVID Vaccine Tracker in Latin America."

The recommendations, which you will find at the end of this article, come as a complementary tool to the World Health Organization’s (WHO) Guidance on developing a national deployment and vaccination plan for COVID-19 vaccines, which already highlights the importance of ensuring a robust, accountable and transparent decision-making structure and process. The recommendations can be summarised as follows:

  • It is crucial to engage non-governmental experts in the vaccine approval process and being open about vaccines' safety and efficacy to gain public confidence. For example, nowadays, an Independent organization, the European Medicines Agency (EMA), is responsible for the scientific evaluation, supervision, and monitoring of the safety of medicines in the EU and, consequently, for approving the licensing of COVID-19 vaccines. The EMA Management Board consists of 36 members “appointed to act in the public interest, who do not represent any government, organization or sector” and 7 scientific committees involving experts from all over Europe. Their reports are public, although not provided in reusable formats.
  • It is necessary to implement open procurement processes for efficient resource management. It will reduce corruption risks by making information available in a transparent, accessible, and reusable manner and by including citizen participation, especially health sector experts, throughout the life cycle of vaccines. OCP has provided governments with a Guide to collect, publish and visualize COVID-19 procurement data and has released a tool that tracks COVID-19-related procurement in 9 countries.
  • Open distribution processes should have clear information on how the public can access the vaccines and how distribution will be carried out. Leaders and social groups should support the process to address citizens' concerns. A good example of this is the guide published by G-Watch in the Philippines, which compiles all citizens' rights in their government’s vaccination program. Another example is AccountabilityLab’s Coronavirus CivActs Campaign initiative, which addresses misinformation about the pandemic in seven African countries and provides easily understandable information to citizens.
  • The demand for multiple channels for monitoring and control allows governments to be accountable for their vaccination policies and outcomes and civil society to monitor these policies. Since the pandemic began, many public platforms have been created to provide data on the coronavirus, including information about the vaccination processes. However, there have been significant deficiencies in data quality, the formats they use to open the data, and the (im)possibility of reuse. In Spain, the Castile and Leon Regional Government’s Open Data platform has been one of the most recognized portals for its excellent management of information on the pandemic. They are the only Autonomous Community in the country to have published the minutes of the meetings of the COVID-19 expert committees from the start.

21 OGP recommendations

Review and Approval

Clinical Trials

  1. Require that pharmaceutical companies disclose clinical study reports and record trial-related information in a publicly accessible register, including:

    • Trial protocols (how they were structured, who was involved, changes made)
    • Summary of results
    • De-identified participant-level data

Authorization

  1. Involve citizens in the planning and monitoring of budgets for vaccines and vaccine-related expenses (e.g., logistics, syringes, software, waste management)
  2. Publish machine-readable data on budget allocations, including revenue sources such as donor assistance or debt instruments

Procurement and Spending

Budgeting

  1. Involve citizens in the planning and monitoring of budgets for vaccines and vaccine-related expenses (e.g. logistics, syringes, software, waste management)
  2. Publish machine-readable data on budget allocations, including revenue sources such as donor assistance or debt instruments

Procurement

  1. Publish the contracting process and contracts around vaccines (research, development, manufacturing, and distribution) and vaccine-related services, with a focus on disclosing::

    • Quantity of vaccines (or other products) procured
    • Price paid, including unit price
    • Delivery schedule
    • Risk sharing and liability clauses
    • Exclusive manufacturing agreements
    • Intellectual property and licensing agreements
    • “March-in” rights (to take over vaccines if not provided on reasonable terms)

  2. See the Open Contracting Partnership’s Guide to publishing COVID-19 emergency procurement information

  3. Publish the beneficial ownership information for all contracts, including a debarment list based on past poor performance or fraud

Spending

  1. Publish machine-readable data – disaggregated by region, sex, and social group – on the vaccine and vaccine-related expenditures
  2. Establish multiple channels for monitoring (see Monitoring and Oversight section below)

Distribution

Planning Process

  1. Involve citizens, particularly community health workers, in developing and guiding the implementation of rollout plans through multi-stakeholder groups like the National Coordinating Committees (NCCs) and subnational planning groups.

  2. Publish and socialize vaccine rollout plans that include:

    • Doses to be distributed and timeline
    • Resources and funding
    • Coordination structure, including opportunities for public engagement
    • Strategies for identifying and engaging vaccine-hesitant communities
    • List of prioritized populations, including rationale
    • Supply chain and distribution process
    • Monitoring and evaluation structures

Rollout

  1. Publish data on vaccine availability, including the number of vaccines, type of vaccine, and accessory supplies in stock, as well as supply chain (e.g., cold chain) capacity

  2. Communicate who is eligible for vaccines (e.g., by age group, vulnerability), and when

  3. Publish data on vaccine uptake and coverage over time, disaggregated by region, sex, and age group at a minimum.

    • Where possible, include data disaggregated by type of vaccine, occupation, comorbidities, context (e.g., school, prison), and socioeconomic, ethnic, or any socially disadvantaged group
    • Protect personal data privacy by de-identifying recipient data

  4. Proactively communicate any Adverse Events Following Immunization (AEFI), including information about the events, as well as investigation findings and results.

  5. Share information on entitlements and benefits, including how to access vaccination programs, targeting marginalized groups in particular

Public Trust in Vaccines

  1. Manage misinformation, disinformation, and vaccine hesitancy

    • Establish surveillance systems to understand sources of misleading information
    • Partner with NGOs to engage local communities, identify concerns, and share factual information
    • Use multiple channels – online and offline – to proactively share information about vaccination and rollout plans, including in local languages

Monitoring and oversight

  1. Empower civil society and government actors (such as State Audit Institutions) to track the procurement and distribution of vaccines by establishing oversight bodies with access to real-time spending, inventory, and delivery data, such as vaccine usage and wastage rates by region

  2. Establish grievance mechanisms through which citizens can file complaints if they are unfairly denied vaccines or experience other issues during vaccination

    • Enable citizens to report on vaccine delivery through several channels

  3. Create feedback loops through which governments commit to investigate and respond to citizen alerts and grievances

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