Transcript of letter accompanying Review of COVID-19 Vaccine and Treatment Purchasing and Procurement report:
The Hon Mark Butler
Minister for Health and Aged Care
Parliament House
CANBERRA ACT 2600
Dear Minister
On 30 June 2022 you commissioned an independent review of the purchasing and procurement of COVID-19 vaccine and treatments to inform the next 12-24 months. This report provides the conclusions and recommendations of the review.
The review team engaged with a number of key stakeholders involved in Australia’s response to the
COVID-19 pandemic and rollout of vaccines and treatments. This included epidemiological experts
both nationally and internationally, Commonwealth, state and territory Health departments and bodies, health sector organisations, as well as manufacturers of the vaccines and treatments procured within Australia.
As principal reviewer I was assisted by Professor Peter Collignon AM who provided expert medical advice. I would also like to acknowledge the work of the review project team led by Georgie Fairhall, Department of Health and Aged Care.
Early procurement of vaccines and treatments occurred in a highly competitive global market. In this context Australia secured a portfolio of effective COVID-19 vaccines and treatments enabling high rates of primary course vaccination preventing serious illness and death relative to global peers.
However, Australia and the world are not yet ‘COVID-stable’, and we are unable to confidently predict the timing or impact of new waves and variants. This uncertainty presents particular challenges. The availability of efficacious vaccines and treatments will continue to play a key role in ensuring ongoing protection for lives and livelihoods.
The next two years are critical to supporting our economy, health and education systems to recover. Australia's approach to the procurement of vaccines and treatments needs to be responsive to the changing environment and should be guided by clear policy and understanding of risk appetite.
Consideration should be given to the decision-making structures and advice required, and whether new and existing pathways for procurement and distribution of vaccines and treatments should be retained or adapted. Finally, it is critical that Australia maintains surge capacity in the event of a serious new variant or another infectious disease.
Yours sincerely
Hon. Professor Jane Halton AO PSM
19 September 2022
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Review of COVID-19 Vaccine and Treatment Purchasing and Procurement aka the Halton Report by clarencegirl on Scribd
Note: This letter, executive summary & recommendations are the full extent of what the federal government was prepared to release for public consumption. The remainder of the Halton Report allegedly covers contractual arrangements with vaccine manufacturers and as such is commercial-in-confidence.
The Saturday Paper, 7 January 2023, excerpts:
A summary of the review by former senior health bureaucrat Professor Jane Halton was released in September last year. The full version of the report, obtained by The Saturday Paper under freedom of information laws, paints a disturbing picture of what could lie ahead as the virus mutates further and existing vaccines become less effective.....
Speaking to The Saturday Paper this week, Halton emphasised that the virus remains a serious threat that could worsen.
“The world is currently seeing the emergence of yet more new variants, including XBB1.5, which underscores that the pandemic and particularly the effects of SARS-CoV-2 are not yet completely behind us,” said Halton, who heads the global Centre for Epidemic Preparedness Innovations, or CEPI.
“It’s really important to take a step back and say, ‘What are we trying to achieve here?’ I’d love to see a narrative from the federal Health minister – the goals we want to achieve. I’m just not seeing that. It just seems to be a lot of Whac-A-Mole going on.”
“The entire world is looking forward to a day where we don’t have to worry about SARS-CoV-2. However, we continue to need to be prepared for all circumstances, including new and more dangerous variants.”
In her report, Halton writes that Australia signed advanced purchasing agreements (APAs) with vaccine manufacturers “later than other comparative countries which delayed the supply of vaccines and the speed of the rollout”.
Australia later overtook other countries, once a distribution plan was in place. However, Halton warns that those foundational APAs are now expiring. “As a consequence, new APAs giving effect to purchasing decisions will be needed.”
A spokesperson for Butler declined to comment specifically on new purchasing agreements but said the government “has ensured there is a portfolio of vaccines and supply available to Australians in 2023 and 2024”.
The report says the new government should rethink eligibility for both vaccines and the antiviral treatments that lessen the virus’s impact on individuals. It says optimising their uptake and investing in new versions will be “critical” in what will continue to be a highly competitive global market.
“In the short-term, wider eligibility for some treatments should be considered where there are stocks available, there is evidence of efficacy, safety and broader economic and societal benefits (such as workforce availability). This is particularly the case where there is no significant private market to help limit the burden of the disease.”
The absence of a “private market” highlights that the government’s approach to Covid-19 vaccines is different than for other vaccines.
For example, anyone in Australia can access the annual influenza vaccine. The government lists the vaccine on the Pharmaceutical Benefits Scheme (PBS) and identifies priority groups who can receive it free. Others who want to be vaccinated protectively can pay to obtain it through vaccination clinics or their local general practice. Some employers offer staff vaccinations to limit workdays lost to illness.
That is not the case for Covid-19 vaccines and was also not the case for Covid treatments when they first became available. The government is the only purchaser and distributor of these vaccines and it alone controls who can access them.
Unlike its American counterpart, the Australian government has only authorised a fifth vaccine dose for the most vulnerable. In the United States, a protective fifth shot is widely available.
Butler’s spokesperson did not respond directly to a question about the different approaches to eligibility. “New booster dose recommendations are anticipated in early 2023 in preparation for winter,” they said. “Future recommendations will aim to provide ongoing clear guidance across all groups including time since last dose and definitions of eligibility.”
The current, restrictive approach was adopted in the pandemic’s emergency phase to ensure access was not dictated by who could pay; but Halton notes circumstances have now changed, with most of the population protected by at least basic vaccination.
She suggests that widening access to vaccines – and treatments – could slow the spread of variants and lessen risk as immunity wanes. In other words, the cost-benefit equation around restricting access has shifted.
Halton writes that variants influence the effectiveness of both vaccines and treatments. “These changes are significant for decision-making,” she writes, “and the relative benefit of individual vaccines and treatments will continue to need to be assessed.”
The report also indicates a shift in the importance of antiviral treatments, which have not been a focus in Australia’s Covid policy. Halton notes that if vaccination or previous infection no longer offer significant protection against new variants, treatments may now be considered proportionally more beneficial than when protection from vaccines was higher.
Halton warns that the current broad distribution framework for vaccines “does not include a strategy for the distribution of treatments as they were not widely available in 2020”......
Halton’s report says strategies and frameworks drafted early in the pandemic are now out of date and don’t adequately consider developments in vaccines and especially treatments for the virus. She says government should rethink those restrictions put in place because of supply constraints.....
She also notes that because the previous government elected to adopt all advice from the Australian Technical Advisory Group on Immunisation (ATAGI), it effectively became the decision-maker. Its advice was not always interrogated and was portrayed as entirely clinical when it was sometimes based on judgement.
“The ATAGI advice, which is released publicly, is often treated as prescriptive and rules-based. The timeliness of this advice has also been questioned.”
Halton describes a “mismatch” between vaccine supply and demand, the latter having been restricted by the eligibility criteria ATAGI had applied, which were often narrower than those contained in the Therapeutic Goods Administration approvals. Halton says this has created confusion about their respective roles.
She writes that ATAGI’s advice “has changed over time and does not provide a firm foundation for procurement decisions”.
Halton’s report says there have also been delays in the booster stage.
“While Australia has had early success with managing the pandemic, further emergence of new variants and management of the vaccination rollout has seen waning performance in comparison to other countries,” the report says. “Australia currently has the second lowest rate of booster uptake among comparator countries.”
Halton says “inconsistent messaging from health authorities” has contributed to the slow booster uptake and urges the government to significantly improve public communications.
The government has accepted all of Halton’s recommendations “in principle”, Butler’s spokesperson said. A formal government response is expected soon.
