HC 1048-III Health CommitteeWritten evidence from Sanofi Pasteur MSD (PH 179)


About Sanofi Pasteur MSD

Sanofi Pasteur MSD (SPMSD) is the only company in the UK totally dedicated to vaccines. It was founded in 1994 as a joint venture between Sanofi Pasteur and Merck & Co Inc. We have a heritage that includes pioneers in vaccination, such as Louis Pasteur (rabies vaccine) and Maurice Hilleman (measles vaccine), and have grown to become a leading supplier of vaccines. Using a combination of research and manufacturing expertise, our purpose is to bring innovative vaccines to the UK, protecting health and preserving quality of life for people of all ages.

Our main way of achieving this goal is to develop and make available innovative vaccines against a wide spectrum of diseases. We are also dedicated to increasing the understanding of the value of vaccines and vaccination by providing relevant and accurate information on their efficacy, quality and safety.

1. The Creation of Public Health England within the Department of Health

Sanofi Pasteur MSD welcomes the Government’s focus on public health and the emphasis on preventing ill health and encouraging healthy ageing. We look forward to the creation of Public Health England and believe it will enable greater emphasis being placed on tackling the underlying causes of ill-health, something that vaccination can help to achieve.

However, Sanofi Pasteur MSD believes that management and coordination are key to ensuring effective immunisation programmes. Fragmentation of delivery via different providers (GPs, Local Authorities, NHS and other providers) may have a negative impact on uptake rates. Different providers may also result in a fragmentation of record keeping with the associated potential for missed opportunities for vaccinating susceptible individuals. Immunisation delivery will need to continue to be well coordinated with a clearly identified lead who is responsible for immunisation across the various providers. Sanofi Pasteur MSD believes that this should include an identified lead within Public Health England, as well as at a local level.

2. The Abolition of the Health Protection Agency and the National Treatment Agency for Substance Misuse

Sanofi Pasteur MSD does not believe that the Health Protection Agency should be abolished. The Health Protection Agency provides an essential service, including the collection of data, surveillance of disease at a local and national level and modelling. The Health Protection Agency currently provides an extremely high level of expertise on a wide of range of issues and provides independent advice.

The Health Protection Agency’s disease surveillance on a local level is integral to effective disease management. Given concerns about the rise of some infectious diseases, such as the H1N1 Pandemic flu in 2010, Sanofi Pasteur MSD believes that it would not be prudent to disband the Health Protection Agency, particularly just before the London Olympics in 2012, given the low levels of immunisation in some European countries, in particular the recent outbreak of measles.

Currently the Health Protection Agency leads the monitoring of disease epidemiology and vaccine uptake through a network of local organisations and systems that report centrally. Steps must be taken to ensure that the functions and information provision role of the Health Protection Agency are not diluted or lost if it becomes part of Public Health England.

Another critical consideration when accounting for the role of the Health Protection Agency is that of its modelling unit, which in the current system has the important responsibility for undertaking cost-effectiveness analyses and economic modelling which is used to inform decisions by the Department of Health and the Joint Committee on Vaccination and Immunisation for UK vaccination policy. This is by no means a trivial set of responsibilities and therefore, something the Government must consider as part of any reform to the current structure of the Health Protection Agency. This is particularly important given the Government’s stated commitment to public health of which vaccination is a seminal component.

Under the new proposals for the Health Protection Agency to become part of Public Health England it will cease to be an independent organisation—something critical to the credibility of health protection both here in the UK and internationally.

Sanofi Pasteur MSD believes the Department of Health should actively consider making the Health Protection Agency an “executive agency”, instead of making it part of Public Health England, so as to ensure its critical functions are not lost.

3. The Public Health Role of the Secretary of State

Sanofi Pasteur MSD believes that strong leadership is essential to ensuring public health remains a priority and key focus of government health policy. Without strong national leadership for immunisation programmes there is a risk of fragmentation under the current proposed funding arrangements. This may impact on our ability to maintain high uptake levels, to respond effectively to disease outbreaks or vaccine confidence issues, and may have a detrimental impact on uptake of new vaccines.

As the UK Vaccine Industry Group (UVIG) stated “the evidence and experience shows that national leadership for vaccination programmes works well. This leadership must also include central co-ordination and national direction to respond to changes in disease epidemiology, to any fall in uptake rates and generally manage the UK wide situation.”

The Secretary of State for Health through Public Health England, should set out a clear national strategy for vaccination from which programmes can be structured and implemented. It is extremely important that the Secretary of State for Health indicates vaccine priorities to ensure the vaccine industry can successfully plan to meet these. In addition to this, strong public health indicators are necessary in regards to vaccination to ensure that uptake rates are high.

4. The Future Role of Local Government in Public Health (including Arrangements for the Appointment of Directors of Public Health, and the Role of Health and Wellbeing Boards, Joint Strategic Needs Assessments and Joint Health and Wellbeing Strategies)

Sanofi Pasteur MSD recognises the challenges involved in bringing health and social care together, however Sanofi Pasteur MSD welcomes the integration of public health into local government., It is vital that professionals from public health, the NHS, social care professionals and other providers all collaborate and share information where possible, to ensure they maximise vaccine uptake rates and coordinate and capture immunisation data and records.

Sanofi Pasteur MSD welcomes the introduction of Joint Strategic Needs Assessments, but believes that in relation to public health they should have a broader focus than the traditional “life-style” focus of public health.

Sanofi Pasteur MSD believes that Health and Wellbeing boards will provide an important forum to ensure that all agencies take a life course and co-ordinated approach to the delivery and implementation of immunisation programmes. Directors of Public Health should have an executive position and should be members of the cabinet to ensure immunisation policies are incorporated into the function of Health and Wellbeing Boards and their Joint Strategic Needs Assessments.

5. Arrangements for Public Health Involvement in the Commissioning of NHS Services


6. Arrangements for Commissioning Public Health Services

Sanofi Pasteur MSD is concerned that there is a serious risk of fragmentation and poor uptake rates for vaccination if Local Authorities are responsible for commissioning certain immunisation programmes. The system would need to be coordinated and managed to ensure that there was not an adverse affect on uptake rates. It is also essential that provision be made for the inclusion of new immunisation programmes in the future.

Both the NHS and Local Authorities should have a duty to commission or provide vaccination services for health and social care professionals. Local Authorities’ performance in this area should be subject to audit, as should the performance of the NHS. ,

Sanofi Pasteur MSD is concerned that commissioning for infectious diseases may be problematic as they do not respect geographical boundaries. If the UK is to continue to deliver exceptional outcomes in immunisation, the new Public Health England must have overall leadership for programme development and take on responsibility for co-ordination and implementation of all aspects of the immunisation programmes. Failure to do so will lead to fragmentation, a drop in uptake rates of vaccines and poor infectious disease control in the population, communities and individuals.

7. The Future of the Public Health Observatories


8. The Structure and Purpose of the Public Health Outcomes Framework

Sanofi Pasteur MSD welcomes the renewed focus on prevention rather than cure in the public heath outcomes framework and supports the overarching focus of the 5 domains and specifically the inclusion of vaccines and immunisation in domains 1 and 5. For the first time specific goals of the national immunisation programme are being reflected in measures of health outcomes. However, there are some concerns that the framework misses the opportunity to identify areas of immunisation policy where achieving consistently high uptake rates is historically challenging.

The outcomes framework needs to be explicit about the overall public health objectives as well as the specific goals and target rates for vaccination uptake. This will require robust systems to be in place to ensure a good flow of information, and clarity as to responsibilities. This should enable effective local implementation and monitoring, and ensure that individuals are clear as to their respective roles in the process.

Domain 1 must include specific reference to existing vaccination programme populations, in order for it to be an effective measure of outcomes and to support the implementation of immunisation programmes. This level of detail will support front line staff in focussing information campaigns and structuring services to maximise the benefit of the immunisation programme at a local level.

Explicit detail listed in domain 1 should also include uptake of occupational vaccines amongst healthcare professionals eg seasonal flu and hepatitis B, and uptake of vaccines in areas of socio economic deprivation.

9. Arrangements for Funding Public Health Services (including the Health Premium)

Sanofi Pasteur MSD believes that Public Health England should be responsible for funding all immunisation programmes and the proposed health premium should be applied to improving vaccine uptake rates in areas of low uptake and deprivation.

However, a concern is that the 4% ring-fenced budget allocated for public health may not be sufficient to achieve real results.

10. The Future of the Public Health Workforce (including the Regulation of Public Health Professionals)


11. How the Government is Responding to the Marmot Review on Health Inequalities


June 2011

Prepared 28th November 2011