Environmental scan HTA Institutions: World Health Organization (WHO), United Kingdom, Thailand, Ghana, Ethiopia and South Africa
The institutional contexts of HTA agencies are highly variable, presenting differences in the organization of the HTA process “chain of assessment” stages (prioritization, evaluation, appreciation, dissemination, and implementation of results/recommendations) [
7]. The literature review aimed to conduct an environmental scan to retrieve sample HTA structures in various countries to understand various HTA themes and values and how institutionalization is conducted in varying contexts [
8]. The diversity of the organization of HTA in different countries with regard to mission, structure, financing, priority setting and impact on decision-making was assessed using examples of known HTA agencies. While the focus was the WHO guidelines for effective HTA institutionalization, the UK NICE, Thailand, Ghana, Ethiopia,and South Africa structures also informed this assessment.
Current decision making structures for health technology adoption in Malawi
The FGD and KIIs indicated that apart from the policymakers at the Ministry of Health, there are other players in adopting new health technologies namely PMRA, Civil society, Malawi Medical council and non-governmental health care providers such as CHAM. The study participants indicated that health technology adoption in Malawi is primarily reliant on the funding source for corresponding health technology. The funding source may be in the form of:
The qualitative inquiry further found that to implement the adoption decision from SMT, the user department initiates a procurement request which goes through the Internal Procurement and Disposal Committee (IPDC) for scrutiny. The main task of the IPDC is to ensure that the acquisition of the technology complies with the Public Procurement Act of 2017. Based on feedback from the FGD, some of the key considerations include “the functionality of the product or the equipment or the service in the country, availability of capital sale services and financial capacity of the bidder… […]; if given a contract [they] should be able to bring the product into the country” (FGD Res.07_Policy Maker).
For these Government-funded technologies, the implementation of the decision by SMT is generally executed by the Department of Health Technical Support Services (DHTSS) but there are others involved such as the Diagnostics Unit, Clinical department and the Public Health Institute of Malawi. The DHTSS has three Divisions: (1) Physical Asset Management (PAM) Unit, which coordinates the procurement of technologies that focus on medical devices; (2) Pharmaceuticals Division, which coordinates the procurement of medicines and medical supplies; and (3) Laboratory Unit which coordinates the procurement of laboratory supplies and reagents. The PMRA provides regulatory oversight over medicines. However, its mandate has recently been expanded to cover diagnostics and monitor the safety and efficacy of medicines and enforce compliance with standards. A respondent for instance indicated that “… when we see that the government would like to deal with that supplier, we write them that can you submit the dossiers, and an application to us so that we (can) assess your product” (KII 10_Regulatory Authority).
To register pharmaceuticals, a company makes an application to PMRA expressing intent to sell products on the Malawian market. PMRA then inspects the company to check its compliance with WHO Good Manufacturing Practice as required by the law and issues a compliance certificate if standards are met. The registration process involves the following steps: application for registration of the product; undertaking a bioequivalent study or laboratory proxy; presentation of the assessment report to the medicines committee of the PMRA board for endorsement; submission of the endorsed report to the PMRA board for final approval. One respondent described the process as follows: “… there are product assessment procedures, clinical trial reviews, and pharmacovigilance safety surveillance of medicines… the (PMRA) team makes a report on every product found in retail pharmacies. They produce a report and submit it to the medicines committee of the board to consider the findings of the report… This committee escalates this process to the level of the board. Now the board ratifies that these products… have now been registered, they can be found on the Malawi market.” (KII 10).
Values and principles guiding HTA practices in Malawi
Technology adoption for Government and donor-funded technologies is guided by existing national priorities in key policy and strategic documents. These policies and guidelines include the recently revised Essential Health Package (EHP) [
18], National Health Policy, HSSP II [
19], Essential Medicines List [
20], Standard Treatment Guidelines [
20], Malawi laboratory services and supply chain assessment [
21], Public Procurement and Disposal of Assets Act − 2017 [
22] and WHO guidelines. Other normative values that were mentioned by some include appropriateness, affordability, accessibility, maintenance cost and functionality of the products. An assessment of the policy documents revealed that these values are included as guiding principles without interventions and indicators for ensuring the relevant organizations build the relevant culture in their decision-making, including HTA.
The key observation provided on the use of values and principles is that they are not always adhered to leading to the misalignment of normative and actual values that are practiced as one respondent from the FGD reported: “…although there are value sets which define the EHP processthat informs the treatment guidelines or essential medicines list that process isn’t in existence now. So, it’s one way the values are therebut I am not sure that they are being translated into the process thatinforms what’s procured.” (FGD Res.005).
Strengths and challenges of partial HTA mechanisms in current decision-making structures
To determine whether institutionalizing HTA is feasible, it is important to understand the strengths, weaknesses, opportunities and threats posed within each of the informal HTA mechanisms that have been identified within the decision-making structures. The respondents reported various challenges affecting the current decision-making processes of assessing health technologies for adoption in the Malawian health system. These include limited use of evidence, lack of a standardized framework, political interference, lack of resources, pressure from donors, difficulties in implementing cost-effective interventions due to conflicting policies, and lack of transparency and accountability. Table
1 below summarizes the Strengths, Weaknesses, Opportunities and Threats of informal HTA Mechanisms in Malawi.
Table 1
Strengths, Weaknesses, Opportunities and Threats of informal HTA Mechanisms
Strengths
| •Greater alignment of policy questions to health system goals •Senior management composition could mitigate any risks in decision-making arising from a weak evidence base including cost-effectiveness •The multi-stakeholder composition of TWG members provides scope for transparency and accountability. | •Available capacity for handling issues of efficacy and effectiveness •Has legal Mandate-Act of Parliament •Has a significant level of independence •Is already funded by the public, donor and private funding streams •Its mandate already stretches across government, donor, and privately funded technologies •Minimal political interference as oversight is through a Board of Trustees •Has robust internal research capacity for pharmacovigilance |
Weaknesses
| •SMT can be pressured by donors •Political economy interests of top decision makers could prevail over value and evidenced-based decision making •Weak institutional mechanism for evidence synthesis | •Its statutory corporation status could limit the scope for its execution in the event of interference by MOH and other central government institutions •It does not have the capacity for cost-effectiveness analysis •Poor coordination with health technology procurement institutions •Lack of WHO prequalification of the laboratory limits the assessment of some pharmaceuticals •Globally, it is not a standard practice that HTA is placed in the medicines board. |
Opportunities
| •It is an existing decision-making structure of MOH •Any identified institutional and funding gaps can be reasonably addressed •TWG structure is acceptable by donors and wider stakeholders •TWG structure provides access to top researchers who can contribute to the evidence process at no cost to the Government | •New regulations extend its mandate to cover all health technologies rather than medicines only •Has the trust of all stakeholders in health technology |
Threats
| •Political interference •Could be influenced by political economy considerations | •Funding for HTA could be diverted for other regulatory activities •Staff establishment restrictions could limit the potential for in-house capacity in health economics |
Institutionalizing HTA in Malawi: demand and options for institutionalization
For the institutionalization of HTA, there must be demand for it. This was ascertained by asking FGD and KII informants whether or not HTA would improve decision-making in the health sector. From this question, we further inquired what form HTA institutionalization could take. Based on interviewee responses, the need for HTA was extensively highlighted and deemed necessary. The participants expressed that an institutionalized HTA would fill a regulatory gap for HTA adoption across multiple channels. The participants further iterated that an institutionalized HTA will facilitate cost-effectiveness considerations in decision-making for both medical devices and medicines including donations. A participant suggested that HTA “will serve as a guiding tool to make sure that there is competition on the market” and ensure objectivity when … “selecting these manufacturers or suppliers” (KII_06). The participants further proffered that, the institutionalization of HTA would provide coordination among stakeholders involved and improve relationships across institutions. Additionally, institutionalizing HTA in Malawi would improve decision-making regarding technology adoption, and contribute to efficiency, equity and transparency in health financing, thereby leading to improved service delivery and results.
Several options for institutionalizing HTA in Malawi were proposed by participants. Based on the functions already undertaken by PMRA, most respondents who were conversant with HTA processes or practices suggested that efforts towards institutionalizing HTA should constitute empowering the PMRA. PMRA has a new regulatory framework that was drafted and has “expanded the scope to include all aspects of technology such as medical devices and traditional medicine currently excluded in the PMRA Act”. (KII_06). Therefore, the respondents suggested exploring the feasibility of capacitating PMRA to perform HTA functions. Another suggested option for institutionalization was that HTA should be established as a standalone institution independent of MoH. A third option that respondents proposed was setting up an HTA body within an appropriate academic institution considering the strong research culture that exists in academia, upon which the evidence base for HTA could be harnessed. A fourth option was establishing a unit specializing in HTA within the department of planning in the MoH, PMRA or possibly under the Public Health Institute of Malawi (PHIM) in the department of research. The respondents highlighted that this would ensure that HTA is “housed within the ministry as this is where the majority of the decisions are made in regards to health technology” (KII_08). A final option mentioned was to set up HTA as a “committee and eventually develop that into a full department within one of the government functions” (KII_08), once the value of HTA has been established.
The participants proposed multiple ways in which HTA could be funded in Malawi. These options included but were not limited to funding from the government and international development partners. Another proposition was to have a subscription-based system for all partners that would have a role in the HTAframework.