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To the moderator,

I had posted my comments on India's National Helath Policy 2001 about 8

weeks back. There was call for a discussion to be held on this policy on

this forum.

In the last few days I have received a number of e-mail, I presume,s

responding to my comments the National Health Policy 2001. These files

had a virus and our fire wall eliminates them (so it is not even clear

to me what the files contained, I am just guessing at the contents from

the subject header). My replies to the e-mail addresses from where the

comments came from bounced with user unknown! So I cannot get in touch

with the senders.

I am enclosing my comments again in case the original message somehow

got corrupted with a virus. Perhaps you can repost my note and send out

another call for comments? I feel it is very important to initiate a

debate about the NHP 2001 -- if the policy it self is so lacking, how

can we expect any credible intervention.

Best

rajan

=====================================================

The Ministry of Health & F. A. is in the process of formulating a new

Health Policy. The Draft National Health Policy has been put together as part

of a consultative process involving Civil Society, Specialists in various

disciplines, Various Govt departments, the Private Sector and others.

It has been suggested that The New Draft Document be put up on the web

site of the Ministry for a further consultative process. Those

interested can access the same on their site

http://mohfw.nic.in/np2001.htm you can also give in your valuable

input to Ms. Urvashi Sadhwani (Addl.Eco. Adviser) at email:

aeabop@...

==================================================================

COMMENTS ON THE National Health Policy 2001

BY RAJAN GUPTA (rajan@...)

The National Health Policy 2001 aims to be a comprehensive document that

sets out to provide a new policy framework for accelerated achievements

of Public Health goals. On reading the draft I find the following

deficiencies.

1) The document provides no information on the budget for various

categories of health services of the central government or of the states. I

feel that t is essential that a table showing past and anticipated future

budgets for all states and center be provided. Without such information it

is not possible to judge the feasibility of proposed goals.

2) The document provides no information on the number of primary,

secondary, and tertiary medical centers in both the public and

private sector. We request data for each state and UT.

3) The document speaks about opening more medical colleges in areas that

are under-represented. Unfortunately, it does not discuss adequately the

reality that more and more of even the established medical colleges

are failing -- loosing their best faculty members, are teaching

outdated procedures, do not have adequate funds for practical training, and

are not able to insure minimum standards of learning before

granting degrees. In such an environment, it would serve the nation

more to upgrade the existing institutions rather than create more

mediocre or failing ones.

4) The NHP-2001 does not establish clear priority for a vaccination

program for all citizens. The minimal acceptable is vaccination against MMR,

DPT, polio, and Hepatitis B using quality vaccines.

5) The document mentions HIV/AIDS in passing, while it has a separate

section on providing medical facilities to users from overseas. This

shows the clear misunderstanding of priorities for public financed

health. This jumbling of priorities suggests that the government,

in spite of its rhetoric, does not appreciate the threat posed by

HIV/AIDS. My interactions with many thousands of people show that proper

knowledge of HIV/AIDS is highly lacking even amongst the literate and denial is

very common. Furthermore, even those who have some information, they have

not understood how to use this information to change behavior -- due

to lack of money, empowerment, or simply fatalism. Also, along with

HIV/AIDS the growing threat of TB and especially MDR Tuberculosis has

to be addressed.

6) While HIV/AIDS is mentioned a couple of times, the document

completely ignores Hepatitis B and C crises. Current estimates suggest 4 million

cases of HIV/AIDS, 15-20 million of Hepatitis C, and 60-80 million of

Hepatitis B. Today many hospitals are seeing as many cases of

failing/failed livers in people in their late thirties and forties as they are

of HIV patients. The tragedy is that, except for select private blood banks,

the national blood supply in public institutions is still not being

tested for Hepatitis C. The NHP-2001 is completely silent on this

issue.

7) The document mentions better monitoring of private health

centers. It fails to specify how it intends to monitor them since

its record of monitoring public hospitals, roadside clinics,

alternate medicine centers, and pharmacists is abysmally poor.

8) The document attributes most of the blame for failing PHC on the lack

of a steady supply of drugs. The reality is that a large fraction of

PHC have failed because doctors assigned to them do not show up or

have set up private practices sometimes right next to the PHC. Also,

the nursing staff and doctors are profiting from the sale of drugs

on the black market and thus creating an artificial shortage.

Furthermore, they are also involved in kick-backs from

pharmaceutical companies, and in schemes where drugs are not

delivered even though money is paid. Thus, without effective monitoring and

accountability in the system, creating more PHC will just enlarge the

problem.

9) The government should, over time, consolidate their bloated PHC staff

into the functioning PHCs (Even though many states have prepared

lists of PHC that function and those that do not, they still keep pouring

money into the failed ones, i.e., into the pockets of the corrupt).

Turning over the failed PHC to NGOs and philanthropic institutions, along

with the funds earmarked for these PHCs, will lead to better services. If

outright handing over of the PHCs is not acceptable, then at least the running

and monitoring of the PHCs should be handed over to NGOs and philanthropic

institutions.

10) The document completely ignores the existing huge problem of alcohol

and drug addiction. Recognizing that de-addiction is a very costly,

lengthy, and failure ridden process, the NHP-2001 should have a very

clear plan on how to address this issue. The present policy of the

government -- of implicitly encouraging alcohol use in order to

collect taxes -- is shameful and will lead to a dis-functional labor force

in the near future. The growing menace of an already huge drug abuse

problem is being ignored. The silence of the NHP-2001 on this issue is

consistent with reports that those in power are often involved (directly or

indirectly) in the trafficking of drugs.

11) The need for mental health care is enormous. It is estimated that

there are 7 million people with severe psychiatric disability and 22

million more that need psychiatric care. To take care of these,

India has only 3500 mental health professionals! When one adds

the burden of alcohol and drug abusers to the psychiatric patients,

the scale of the problem becomes obvious. Little wonder that the

government turns a blind eye to the atrocities committed against

the mentally ill (including burning inmates chained to trees in

Erwadi, TN, a so called progressive state).

12) There is no mention of the growing epidemic of abortions as the

leading method of birth control because of the refusal of the government to

discuss safe methods of contraception in schools and colleges, and

making these methods (pills, IUDs, condoms) available. This is

presumably the responsibility of the non-existent Public Health system.

NHP-2001 needs to address this issue.

13) Lack of education on male and female reproductive health and

sexually transmitted diseases in schools and colleges has made

containment of HIV/AIDS, Hepatitis B and C, and other STDs

difficult. The NHP-2001 does not adequately address this issue

nor does it recommend the appropriate size of funds required to

implement this.

14) The division of responsibility between the state and central

governments is being used as a cover to deny responsibility

by both. The original intent was that such a division would provide

better coverage by making people closer to particular conditions

in charge. The reality is a non-existing system in many states.

The NHP-2001 does not adequately address this problem.

15) THE NHP-2001 is completely silent on the issue of emotional,

physical and sexual abuse of children. Given the magnitude of the problem,

the devastation it causes to the victims, and its connections to

addictions and risky behavior (leading to HIV and Hepatitis infections), this

issue has to be addressed.

CONCLUSION:

===========

It is with much sorrow that I conclude that NHP-2001 is an attempt at

writing an eloquent but empty paper document that fails to address

many issues that should be priorities. It reads like a " business as

usual " plan whereas the nation is faced by many simultaneous pandemics

and is totally lacking a publich health system. It does not address

the magnitude of the problem nor does it underscore the urgency for

massive intervention. In fact it essntially ignores the crisies --

HIV/AIDS and the growth in MDR TB, Hepatitis B and C, addictions to

alcohol and drugs, and mental health.

NHP2001 assumes that a system that has not delivered over the last 50

years will suddenly start working by miracle, nor does it provide any

believable implementation plans to counter the known failures. For

example, it is hard for me to believe that if potable water and

sanitation is not available to a significant fraction of the

population, one will be able to eradicate Malaria and other vector and

water borne diseases by 2010 -- one needs only to look at any slum in

any part of India to see the obvious lack of planning or facilities

for water and sanitation.

So, while NHP-2001 recognizes that India today has a failed public

health care system resulting in a health crisis and is faced with many

simultaneous unchecked pandemics, the new policy does not give any

confidence that health is finally a priority with the national

planners and leaders. The proposed public funding is too small, and

there are no new ideas that address the widespread corruption and

inefficiency -- the core reasons for inefficient utilization of

funding in the past.

Rajan Gupta

E-mail: <rajan@...>

_________________________

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