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Good Governance for Medicines
         in Jordan




        Dr. Lubna Qusous

    Rational Drug Use Department
 Jordan Food and Drug Administration
JORDAN
• Jordan is a low middle – income country
• Population in millions: 5,894,960
• 10.4 % of the Jordanian GDP is spent on health with one
third of this spent on medicinal drugs.
• One quarter of the drug expenditure is spent in the public
sector with the remaining three quarter spent in the private
sector.
• Medicines expenditure growth 17% per annum compared to
GDP growth of 3.3%.
Good Governance for Medicines
      programme: a model process
Clearance
   MOH


             PHASE I                 PHASE II                PHASE III

               National             Development            Implementation
            transparency            national GGM            national GGM
             assessment              framework               programme


                       Assessment          GGM framework            GGM Strategic
                         report               officially            Plan of Action
                                              adopted
PHASE I   PHASE II   PHASE III




          Assessment of transparency and
          accountability October - November /2007
                                 •   Assesses vulnerability to corruption of systems in
                                     place
                                 •   Looks at key functions of the pharmaceutical
                                     sector systems
       National
    assessment
                                      Regulation: registration, inspection, promotion
                                      Supply: selection, procurement, distribution
                                      •Elements evaluated:
                                      - Country's regulations and official documents
                Assessment
                     report           - Written procedures and decision-making
                                         processes
                                      - Committees, criteria for membership and
                                         conflict of interest policy
                                      - Appeals mechanisms and other monitoring
                                         systems
General Findings
   Area            Total      Number of   Score on 10      Degree of
                indicators       Key      point scale   vulnerability to
                             Informants                   corruption
Registration        16          10           7.52         marginally

 Promotion          12          10           1.88         extremely

 Inspection         11          10           5.79        moderately

 Selection          12          10           7.71         marginally

Procurement         15           11          8.59         minimally

Distribution        15          10           8.41         minimally

   Total            66           61          6.65         marginally
General Findings
   Area                   Strength                                Weakness
Registration - Documented and standardized.          - No written guidelines on COI
               - Fair access to information          - For some committees: No clear criteria
               - Formal appeals process              for selecting the members & no written
               - Specialized TC                      guidelines for the committees decision-
                                                     making process
Promotion      Pre-approval of promotional and       - Lack of legal coverage
               advertising materials for public is   - No sanctions for breaching the law
               officially required                   - Pre-approval of promotional and
                                                     advertising materials are not officially
                                                     required.
 Inspection    - Comprehensive provision in the      - No written guidelines COI
               medicines legislation                 - No clear criteria for selection and
               - Written guidelines on               recruitment of inspectors.
               classification of GMP                 - No written procedures to prevent
               - Written SOPs for inspectors on      regulatory capture
               how to conduct inspection             - No appeal system for companies.
General Findings
   Area                    Strength                                      Weakness
 Selection     JRDL is available in a printed format-      - No written guidelines on COI
               and in the website of the JFDA              - Membership is not time-limited.
                Clear guidelines for addition-deletion-    - The criteria for selecting drugs are not
               for medicines from the list                 publicly available
               - 17 selection committees is appointed to   - Only includes experts from medicine and
               give technical advice on the revision and   pharmacy field.
               updating of the RDL

Procurement    transparent procedures for procurement-     - No written guidelines on COI
               of pharmaceutical products                  - Not all medicine procured are from a national
                Formal appeals process -                   rational drug list.
               - Clear and specific criteria for tender
               committee membership.

Distribution   Medicines can be identified by imprints-    - There is no effective security management to
               on containers and external packaging.       oversee storage and distribution
               There is systematic and orderly shelving-   - There is no programme exist for monitoring
               of products in warehouses.                  and evaluating the performance of the medicine
               The warehouses are subjected to internal    distribution system.
               and external auditing.
               - A computerized system
Areas of Improvement
Registration     - Conflict of interest policy
                 - Committee composition & TOR
Promotion        - Complete provisions to cover all
                 Activities related to drug promotion
Inspection       - Conflict of interest policy
                 - Clear criteria for selection of inspectors
Selection        - Conflict of interest policy
                 - Selection criteria for members
Procurement      - Conflict of interest policy
                 - Audit results publicly available
General Recommendations


• Revision of the laws and procedures
• There should be written guidelines on COI
• Publish all available regulations, guidelines, SOPs
  concerning each area to the public.
• Develop and adopt a framework for good governance
  in the public pharmaceutical sector
• Develop expertise-train Jordanian officials and staff on
  good governance and ethical practices in drug
  management
PHASE I   PHASE II   PHASE III   Assessment of
                            transparency in Jordan
                        • The results of the assessment and
                        recommendations were disseminated to the
                        stakeholders through a national workshop in
                        February/2008
                         • Assessment report was published and
                        disseminated in January 2009
                        • Improvements in the procedures of the
                        pharmaceutical sector took place
Activities to achieve phase II plan
• Conducting a National Multi-Stakeholders workshop
  to disseminate results of the transparency assessment;
• Nominating and selecting National GGM Team
  Steering Committee and the task force (TOR);
• Committing to meet on weekly basis and the TF
  members prepared the GGM Framework over their
  regular duties
• training and building capacity of a national core team
• Finalization and getting consensus and approvals for
  the GGM Framework
• Set a plan for Phase III, socialization and
  dissemination of the Framework.
GGM Steering Committee
• Members are high level policy makers
• Responsible for the overall management, adoption and
evaluation of the GGM programme
• Ensure implementation of recommendations made in
assessment report
• Ensure that the national Framework for Good Governance in
the public pharmaceutical sector is officially adopted
• Ensure the establishment of policies and procedures for the
control of reprehensible acts
• Ensure the establishment of a whistle-blowing mechanism
• Ensures the establishment and implementation of a GGM
programme (phase III)
GGM Task Force
The GGM Task Force main tasks include:
1. Manage the national consultations process necessary to:
a. Share the results of the national assessments of transparency
and vulnerability to corruption in the public pharmaceutical
sector and
b. Develop and implement the national GGM framework that
approved by the steering committee
2. Follow-up and act upon the recommendations made in the
national assessments report and by the steering committee.
3. Coordinate the development, adoption, and socializing the
national ethical framework and the code of conduct
Jordan GGM Framework Partnership
• Ministry of Health.
• Ministry of Public Sector Development.
• Jordan Food & Drug Administration.
• Anti Corruption Commission.
• Royal Medical Services.
• High Health Council.
• Joint Procurement Department.
• Jordan University Hospital.
• World Health Organization.
Jordan GGM Framework
    Sequence of the document
1. Introduction to GGM Framework
  1. GGM Framework purpose, guiding principles and
     requirements
  2. Scope and mandate to improve transparency and
     accountability
  3. Mechanisms and approaches (desk review, national GGM
     team dynamics, authority gained by SC high level
     representation)
  4. Output and expected impact (deliverables: document,
     competent team, better access to quality affordable
     medicines, more efficiency in the public sector resources
     and to have a good model in the region)
Jordan GGM Framework
       Sequence of the document
2. Governance         and AC
•   definition, requirements, local and global initiatives International, regional,
    bilateral and UN agreements and treaties in addition to AC work in Jordan
    to date:
     – Law of litigation No 16 of 1960
     – Jordan Constitution in 1952
     – The Inspection and Control Bureau in 1992.
     – The Economic criminals law in 1993.
     – Anti Corruption Department in the Intelligence department in 1996.
     – Higher Committee for transparency and accountability in 2002.
     – The national committee against corruption , nepotism & favoritism to
         implement Jordan First Initiative in 2002.
     – The Anti-corruption Commission in 2006
     – The Ombudsmen Bureau in 2008 (harmful actions and inactions)
Jordan GGM Framework
      Sequence of the document
3. Good Governance in the Ph. Sector
• medicine chain cycle and management functions
    – R&D
    – Clinical research
    – Production, registration and pricing
    – Licensing and certification to individuals and institutions
    – Inspection
    – Selection, procurement & distribution
    – Prescription and dispensing practices
    – Pharmacovigilance
    – Promotion
• expected types of corruption; conflict of interest, bribery, promotion,
   tenders and distribution.
• impact of corruption on health systems and health outcomes, directions and
   actions for future protection
• Directions for strengthening and protection
Jordan GGM Framework
      Sequence of the document
4. Integrity system in Jordan and in the Ph. Sector.
• National integrity system components (leadership, restructuring, rule of
    law, public awareness and AC bodies)
• GGM Framework in the Ph. Sector approach in Jordan
     – Elements of GGMF
1. Ethical framework of moral values & ethical principles
     – Justice/fairness
     – Truth
     – Service to common good
     – trusteeship
2. Code of conduct developed in Jordan in 2002
     1. Duties & responsibilities of the Public servant
     2. Respect and equity consideration in providing services
     3. Confidentiality and disclosure
     4. Acceptance of gifts, privileges and other benefits
     5. Conflict of interest
Jordan GGM Framework
     Sequence of the document
5. Socialization of the programme
      Raising awareness, dissemination of TA results, encourage critical
      thinking and discussions, situation analysis and setting targets and
      promote individual responsibility and moral values practices
      Transformation of dysfunctional mental models and supporting the
      culture for good practices and moral values (awards ceremonies and
      incentive linked to performance and moral practices
6. Promotion of Moral Leadership
   1. basic elements of the conceptual framework
   2. Capabilities grouped in categories that facilitate personal
      transformation in a healthy relationships and team work in addition to
      the capabilities needed for social transformation
   3. Activities to be taken
Jordan GGM Framework
        Sequence of the document
7.   Enforcement of existing Anti-corruption laws
      - UN Treaty for Anti corruption in 2004
      - Related legislations in Jordan
            - AC Law No 62 in 2006
            - JFDA Law No 41 in 2008
            - Public health Law No 47 in 2008
            - Medicine and Pharmacy law No 80 in 2001
            - Criminal Law
            - Pharmacy licensing law No 43 in 1972
            - Bureau of Audit Law
            - Administration inspection court law in 1992
            - Ombudsmen law No. 11 year 2008
            - General procurement law No 32 in 1993 and its amendments
            - Civil Service Bylaws No 30 year 2007
            - Joint Procurement Law No 91 year 2002

      Strengthening institutions and departments working on Anti-corruption in Jordan
Jordan GGM Framework
   Sequence of the document
• Whistle Blowing
  – Strict criteria for WB
  – Clear mechanisms
  – Protection & security for reporter
• Sanctions on reprehensible acts
  – Internal sanctions by the government entity
  – Sanctions by the AC agencies and legislative courts
Jordan GGM Framework
    Sequence of the document
8. Improving management system
    Criteria for selecting committee members
    GGM Framework implementation
    Policies and mechanisms to ensure implementation
     of SC recommendations
    Monitoring plan for enforcement of GGM SC
     resolutions
Jordan GGM Framework
    Sequence of the document
9. Inter-institutional Collaboration
  Audit department in MOH,JFDA
  Ministry of Public Sector Development
  AC Commission
  Audit Bureau
  Ombudsmen Bureau
10. Management & evaluation of GGM
  programme
  full time staff
  Setting targets and indicators
Jordan GGM Framework
       Sequence of the document
• Role of Media and Civil Society
   – Empowerment, involvement and building their capacity to act as a
     watch dog and pressure groups
   – Involvement in raising awareness and education of the public
• Role of private sector
   – Corrupted –corruptor responsibility (AC bodies)
• Political will and commitment
   –   Regular monitoring –advocacy events
   –   Building local capacity to institutionalize the moral values
   –   Partnership between government and civil society
   –   Financial support to implement and sustain GGM framework.
Progress
• In January 2009 a Phase III training workshop was
held for the first time in Jordan. It focused on anti-
corruption & pharmaceutical sector legal frameworks,
implementation of the recommendations included in
the transparency assessment (Phase I) & moral
leadership capabilities.
• Among 26 countries globally including 5 countries in
EMR, 10 countries are in phase I, 11 countries in
phase II and 5 in phase III including Jordan.
• Jordan recently finalized the national GGM
framework, and is the 1st EMR country to enter the
implementation phase ( phase III). .
PHASE I   PHASE II
                            Implementation of
                       PHASE III




                     National GGM Programme
                                      • Strengthening systems by increasing
                                        transparency and accountability
                                      • Promoting awareness (general public &
                                        health professionals)
          Implementation                 – Dissemination of information
            national GGM                    (newsletter, website, etc.)
              programme
                                         – Social marketing (radio, TV jingles,
                                            posters, etc.)
                     GGM Strategic       – Critical thinking and discussions
                     Plan of Action
                                            (seminars, conferences)
                                      • Building capacity (managers and public
                                        policy makers)
                                         – Technical training programme
                                         – Leadership training programme
Suggested Activities in Jordan for
              Phase III
• Training of the national GGM team, briefing sessions
for government officials, production of advocacy
materials
• Implementing recommended changes in related laws
& procedures to increase transparency
• Adoption of a code of conduct for civil servants
working in the pharmaceutical sector
• Development of a COI guidelines
• Introducing the GGM concept into university
curricula.
Good governance for medicines in Jordan

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Good governance for medicines in Jordan

  • 1. Good Governance for Medicines in Jordan Dr. Lubna Qusous Rational Drug Use Department Jordan Food and Drug Administration
  • 2. JORDAN • Jordan is a low middle – income country • Population in millions: 5,894,960 • 10.4 % of the Jordanian GDP is spent on health with one third of this spent on medicinal drugs. • One quarter of the drug expenditure is spent in the public sector with the remaining three quarter spent in the private sector. • Medicines expenditure growth 17% per annum compared to GDP growth of 3.3%.
  • 3. Good Governance for Medicines programme: a model process Clearance MOH PHASE I PHASE II PHASE III National Development Implementation transparency national GGM national GGM assessment framework programme Assessment GGM framework GGM Strategic report officially Plan of Action adopted
  • 4. PHASE I PHASE II PHASE III Assessment of transparency and accountability October - November /2007 • Assesses vulnerability to corruption of systems in place • Looks at key functions of the pharmaceutical sector systems National assessment Regulation: registration, inspection, promotion Supply: selection, procurement, distribution •Elements evaluated: - Country's regulations and official documents Assessment report - Written procedures and decision-making processes - Committees, criteria for membership and conflict of interest policy - Appeals mechanisms and other monitoring systems
  • 5. General Findings Area Total Number of Score on 10 Degree of indicators Key point scale vulnerability to Informants corruption Registration 16 10 7.52 marginally Promotion 12 10 1.88 extremely Inspection 11 10 5.79 moderately Selection 12 10 7.71 marginally Procurement 15 11 8.59 minimally Distribution 15 10 8.41 minimally Total 66 61 6.65 marginally
  • 6. General Findings Area Strength Weakness Registration - Documented and standardized. - No written guidelines on COI - Fair access to information - For some committees: No clear criteria - Formal appeals process for selecting the members & no written - Specialized TC guidelines for the committees decision- making process Promotion Pre-approval of promotional and - Lack of legal coverage advertising materials for public is - No sanctions for breaching the law officially required - Pre-approval of promotional and advertising materials are not officially required. Inspection - Comprehensive provision in the - No written guidelines COI medicines legislation - No clear criteria for selection and - Written guidelines on recruitment of inspectors. classification of GMP - No written procedures to prevent - Written SOPs for inspectors on regulatory capture how to conduct inspection - No appeal system for companies.
  • 7. General Findings Area Strength Weakness Selection JRDL is available in a printed format- - No written guidelines on COI and in the website of the JFDA - Membership is not time-limited. Clear guidelines for addition-deletion- - The criteria for selecting drugs are not for medicines from the list publicly available - 17 selection committees is appointed to - Only includes experts from medicine and give technical advice on the revision and pharmacy field. updating of the RDL Procurement transparent procedures for procurement- - No written guidelines on COI of pharmaceutical products - Not all medicine procured are from a national Formal appeals process - rational drug list. - Clear and specific criteria for tender committee membership. Distribution Medicines can be identified by imprints- - There is no effective security management to on containers and external packaging. oversee storage and distribution There is systematic and orderly shelving- - There is no programme exist for monitoring of products in warehouses. and evaluating the performance of the medicine The warehouses are subjected to internal distribution system. and external auditing. - A computerized system
  • 8. Areas of Improvement Registration - Conflict of interest policy - Committee composition & TOR Promotion - Complete provisions to cover all Activities related to drug promotion Inspection - Conflict of interest policy - Clear criteria for selection of inspectors Selection - Conflict of interest policy - Selection criteria for members Procurement - Conflict of interest policy - Audit results publicly available
  • 9. General Recommendations • Revision of the laws and procedures • There should be written guidelines on COI • Publish all available regulations, guidelines, SOPs concerning each area to the public. • Develop and adopt a framework for good governance in the public pharmaceutical sector • Develop expertise-train Jordanian officials and staff on good governance and ethical practices in drug management
  • 10. PHASE I PHASE II PHASE III Assessment of transparency in Jordan • The results of the assessment and recommendations were disseminated to the stakeholders through a national workshop in February/2008 • Assessment report was published and disseminated in January 2009 • Improvements in the procedures of the pharmaceutical sector took place
  • 11. Activities to achieve phase II plan • Conducting a National Multi-Stakeholders workshop to disseminate results of the transparency assessment; • Nominating and selecting National GGM Team Steering Committee and the task force (TOR); • Committing to meet on weekly basis and the TF members prepared the GGM Framework over their regular duties • training and building capacity of a national core team • Finalization and getting consensus and approvals for the GGM Framework • Set a plan for Phase III, socialization and dissemination of the Framework.
  • 12. GGM Steering Committee • Members are high level policy makers • Responsible for the overall management, adoption and evaluation of the GGM programme • Ensure implementation of recommendations made in assessment report • Ensure that the national Framework for Good Governance in the public pharmaceutical sector is officially adopted • Ensure the establishment of policies and procedures for the control of reprehensible acts • Ensure the establishment of a whistle-blowing mechanism • Ensures the establishment and implementation of a GGM programme (phase III)
  • 13. GGM Task Force The GGM Task Force main tasks include: 1. Manage the national consultations process necessary to: a. Share the results of the national assessments of transparency and vulnerability to corruption in the public pharmaceutical sector and b. Develop and implement the national GGM framework that approved by the steering committee 2. Follow-up and act upon the recommendations made in the national assessments report and by the steering committee. 3. Coordinate the development, adoption, and socializing the national ethical framework and the code of conduct
  • 14. Jordan GGM Framework Partnership • Ministry of Health. • Ministry of Public Sector Development. • Jordan Food & Drug Administration. • Anti Corruption Commission. • Royal Medical Services. • High Health Council. • Joint Procurement Department. • Jordan University Hospital. • World Health Organization.
  • 15. Jordan GGM Framework Sequence of the document 1. Introduction to GGM Framework 1. GGM Framework purpose, guiding principles and requirements 2. Scope and mandate to improve transparency and accountability 3. Mechanisms and approaches (desk review, national GGM team dynamics, authority gained by SC high level representation) 4. Output and expected impact (deliverables: document, competent team, better access to quality affordable medicines, more efficiency in the public sector resources and to have a good model in the region)
  • 16. Jordan GGM Framework Sequence of the document 2. Governance and AC • definition, requirements, local and global initiatives International, regional, bilateral and UN agreements and treaties in addition to AC work in Jordan to date: – Law of litigation No 16 of 1960 – Jordan Constitution in 1952 – The Inspection and Control Bureau in 1992. – The Economic criminals law in 1993. – Anti Corruption Department in the Intelligence department in 1996. – Higher Committee for transparency and accountability in 2002. – The national committee against corruption , nepotism & favoritism to implement Jordan First Initiative in 2002. – The Anti-corruption Commission in 2006 – The Ombudsmen Bureau in 2008 (harmful actions and inactions)
  • 17. Jordan GGM Framework Sequence of the document 3. Good Governance in the Ph. Sector • medicine chain cycle and management functions – R&D – Clinical research – Production, registration and pricing – Licensing and certification to individuals and institutions – Inspection – Selection, procurement & distribution – Prescription and dispensing practices – Pharmacovigilance – Promotion • expected types of corruption; conflict of interest, bribery, promotion, tenders and distribution. • impact of corruption on health systems and health outcomes, directions and actions for future protection • Directions for strengthening and protection
  • 18. Jordan GGM Framework Sequence of the document 4. Integrity system in Jordan and in the Ph. Sector. • National integrity system components (leadership, restructuring, rule of law, public awareness and AC bodies) • GGM Framework in the Ph. Sector approach in Jordan – Elements of GGMF 1. Ethical framework of moral values & ethical principles – Justice/fairness – Truth – Service to common good – trusteeship 2. Code of conduct developed in Jordan in 2002 1. Duties & responsibilities of the Public servant 2. Respect and equity consideration in providing services 3. Confidentiality and disclosure 4. Acceptance of gifts, privileges and other benefits 5. Conflict of interest
  • 19. Jordan GGM Framework Sequence of the document 5. Socialization of the programme Raising awareness, dissemination of TA results, encourage critical thinking and discussions, situation analysis and setting targets and promote individual responsibility and moral values practices Transformation of dysfunctional mental models and supporting the culture for good practices and moral values (awards ceremonies and incentive linked to performance and moral practices 6. Promotion of Moral Leadership 1. basic elements of the conceptual framework 2. Capabilities grouped in categories that facilitate personal transformation in a healthy relationships and team work in addition to the capabilities needed for social transformation 3. Activities to be taken
  • 20. Jordan GGM Framework Sequence of the document 7. Enforcement of existing Anti-corruption laws - UN Treaty for Anti corruption in 2004 - Related legislations in Jordan - AC Law No 62 in 2006 - JFDA Law No 41 in 2008 - Public health Law No 47 in 2008 - Medicine and Pharmacy law No 80 in 2001 - Criminal Law - Pharmacy licensing law No 43 in 1972 - Bureau of Audit Law - Administration inspection court law in 1992 - Ombudsmen law No. 11 year 2008 - General procurement law No 32 in 1993 and its amendments - Civil Service Bylaws No 30 year 2007 - Joint Procurement Law No 91 year 2002 Strengthening institutions and departments working on Anti-corruption in Jordan
  • 21. Jordan GGM Framework Sequence of the document • Whistle Blowing – Strict criteria for WB – Clear mechanisms – Protection & security for reporter • Sanctions on reprehensible acts – Internal sanctions by the government entity – Sanctions by the AC agencies and legislative courts
  • 22. Jordan GGM Framework Sequence of the document 8. Improving management system Criteria for selecting committee members GGM Framework implementation Policies and mechanisms to ensure implementation of SC recommendations Monitoring plan for enforcement of GGM SC resolutions
  • 23. Jordan GGM Framework Sequence of the document 9. Inter-institutional Collaboration Audit department in MOH,JFDA Ministry of Public Sector Development AC Commission Audit Bureau Ombudsmen Bureau 10. Management & evaluation of GGM programme full time staff Setting targets and indicators
  • 24. Jordan GGM Framework Sequence of the document • Role of Media and Civil Society – Empowerment, involvement and building their capacity to act as a watch dog and pressure groups – Involvement in raising awareness and education of the public • Role of private sector – Corrupted –corruptor responsibility (AC bodies) • Political will and commitment – Regular monitoring –advocacy events – Building local capacity to institutionalize the moral values – Partnership between government and civil society – Financial support to implement and sustain GGM framework.
  • 25. Progress • In January 2009 a Phase III training workshop was held for the first time in Jordan. It focused on anti- corruption & pharmaceutical sector legal frameworks, implementation of the recommendations included in the transparency assessment (Phase I) & moral leadership capabilities. • Among 26 countries globally including 5 countries in EMR, 10 countries are in phase I, 11 countries in phase II and 5 in phase III including Jordan. • Jordan recently finalized the national GGM framework, and is the 1st EMR country to enter the implementation phase ( phase III). .
  • 26. PHASE I PHASE II Implementation of PHASE III National GGM Programme • Strengthening systems by increasing transparency and accountability • Promoting awareness (general public & health professionals) Implementation – Dissemination of information national GGM (newsletter, website, etc.) programme – Social marketing (radio, TV jingles, posters, etc.) GGM Strategic – Critical thinking and discussions Plan of Action (seminars, conferences) • Building capacity (managers and public policy makers) – Technical training programme – Leadership training programme
  • 27. Suggested Activities in Jordan for Phase III • Training of the national GGM team, briefing sessions for government officials, production of advocacy materials • Implementing recommended changes in related laws & procedures to increase transparency • Adoption of a code of conduct for civil servants working in the pharmaceutical sector • Development of a COI guidelines • Introducing the GGM concept into university curricula.