The Independent Panel for Pandemic Preparedness and Response’s (IPPR) final report, released on Wednesday, May 12 2021, identifies severe failures in pandemic preparedness at every level in the COVID-19 response, from governments to World Health Organization (WHO). Widespread unpreparedness occurred despite years of unheeded warnings on increased zoonosis and the power of globalization to quickly spread novel pathogens.

Procedures under the International Health Regulations (IHR) for threat notification and declaration of emergency were much too slow to control a fast-moving, highly pathogenic threat in our interconnected world. Even after an emergency was declared, states stalled in response and when they did act, it was in isolation without global coordination. While powerfully elaborating on these shortcomings and failures, the report does not single out any government, agency, or actor for their actions or inactions in impeding the response—hurting the ability of WHO to adapt for the future. In particular, despite marked delays in China’s reporting of a novel outbreak in Wuhan and its impeding WHO in finding the pandemic’s origins, the IPPR did not seek to hold the government accountable.

The panel’s report presents numerous recommendations, covering both the immediate response to ending the COVID-19 pandemic, and ensuring that COVID-19 is “the last pandemic.” But if these recommendations were implemented, would it truly achieve those aims? For each of the many bold recommendations, the absence of enforcement and compliance measures will enable threats to persist.

Immediate Recommendations for Ending the COVID-19 Pandemic

The panel recommends that high income countries commit at least 1 billion vaccine doses by September 1, 2021, and 2 billion by mid-2022. It recommends WHO and the World Trade Organization (WTO) establish agreements for voluntary licensing and technology transfers for vaccines or waive rights under TRIPS, and calls for wealthier countries to fund the Act Accelerator through 2021. All of these measures are necessary, yet they fall short of what is needed to combat vaccine inequities. The number of doses is in addition to those already promised to COVAX, but still are not sufficient to get high population coverage worldwide, not for several years. Aside from more doses, there is no mention of the resources needed to actually get vaccines administered (supply chains, health workers, transportation, etc), and low- and middle-income countries are struggling to distribute even their current paltry supplies. Vaccine hesitancy presents another persistent challenge that the report does not address. It also fails to acknowledge the hurdles of ensuring increased manufacturing capacity upon the technology transfers—which will take significant time and planning.

Long-term, Transformative Recommendations

The panel makes seven overarching recommendations to fill the shortcomings of the COVID-19 response, to create system-level change to prevent the next pandemic:

Elevated leadership to prepare and respond to health threats. The panel recommends establishing a Global Health Threats Council, led by heads of state and government, and endorsed through a resolution at the UN General Assembly in September 2021. The panel also recommends adoption of a Pandemic Framework Convention within six months. Raising global pandemic preparedness to the level of high politics is long overdue. Governments must capitalize on the momentum from COVID-19 to truly transform pandemic preparedness. A Pandemic Framework Convention can help fill the gaps in the IHR if it contains real mechanisms for obligating states to comprehensive preparedness and response measures. Importantly, the panel’s report does not say what would be in the new pandemic treaty or how to enforce it, nor how the new treaty would relate to the International Health Regulations. It does promote civil society engagement, which is vital. It would do even better by demanding an equity-based approach grounded in the right to health.

Strengthening the independence, authority, and financing of WHO. The panel recommends increasing member state fees to cover 2/3 of WHO’s base budget, ensuring greater flexibility of funds. Yet it makes no mention of increasing that budget, which would remain an enormous constraint on WHO capacity, especially in the aftermath of the pandemic when so much global health progress has been lost. WHO member states should commit to at least doubling current mandatory assessments. The panel also recommends requiring that the Director-General serve a single term without option for re-election, and depoliticizing staffing and recruitment. Yet this doesn’t actually solve the WHO’s political challenges. Instead, what WHO direly needs is greater enforcement authority of IHR provisions, the power to ensuring state compliance and independent verification of state reports, and less reliance on states’ good political will. Overall, WHO needs ample and sustainable funding, surge funding and authority when it declares a public health emergency of international concern, and political backing, especially by strong geopolitical powers like the United States and the European Union.

Invest in preparedness to create functional capacities at all levels. The panel’s recommendation that governments update national preparedness plans in line with new WHO benchmarks aims to incorporate whole-of-society and whole-of-government planning. Yet under recommended peer review process, states’ capacity and willingness to comply would likely remain low—and high levels of under-preparedness could persist. The recommendation that the International Monetary Fund include a pandemic preparedness assessment as part of Article IV consultation with member states could prove a stronger mechanism for connecting existing assessment instruments into pandemic preparedness.

A new system for surveillance, validation, and alert. The panel’s recommendation for a One Health surveillance approach—connecting with animal and environmental reporting systems—will be critical to detecting constantly evolving threats. More contentious is the recommendations that WHO be authorized to publish outbreak information without prior approval from governments, investigate pathogens with short-notice access to relevant sites, and base PHEIC declarations and recommendations on the precautionary principle. States may oppose adoption of these measures on sovereignty grounds, yet COVID-19 has illuminated the need for WHO to act rapidly at the onset of an outbreak. Further, these measures should be coupled with mechanisms to ensure states’ compliance with these norms during a pandemic.

Establish a pre-negotiated platform for tools and supplies. The Act-Accelerator was an important achievement for collaborative partnerships during the pandemic, and the recommendation to shift it to deliver actual vaccines, diagnostics, and other essential supplies is strong. Also important are the recommendations for voluntary licensing agreements where public funding is invested in R&D, and building regional manufacturing capacities so that in a future pandemic, the worlds poorest countries need not rely so heavily on wealthier states for provision of countermeasures and other supplies.

Raise new international financing for pandemic response. The panel’s recommendation for an International Pandemic Financing Facility to raise $5-10 billion annually for each of the next 10-15 years to enable rapidly funding pandemic response of up to $50-100 billion is badly needed—and possibly even far more. Despite the obvious need, it remains unclear how these funds would be raised, or spent. The funds should be authorized to fill broad gaps in governments’ needs, from controlling an outbreak, to related increases in poverty, hunger, homelessness, and suffering.

National coordination for pandemic response. To combat the inequities exacerbated by COVID-19, the panel recommends a multi-sectoral, all-of-society approach that incorporates annual simulation exercises, strengthening of local communities, more resilient health systems, and risk communication policies geared to gain public trust. While this recommendation merely mentions universal health coverage, it should be a central aspect: from building society more resilient to health threats, to caring for persons during an emergency, to the recovery of public health, economies, and livelihoods.

Lawrence Gostin is the Director of the O’Neill Institute for National and Global Health Law and the Founding O’Neill Chair in Global Health Law. 


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