Evaluation of WHO’s Framework of Engagement with Non-State Actors (FENSA), November 2019.
WHO Evaluation Office
We have been calling on WHO to carry out a thorough, open and transparent evaluation of FENSA ever since this Framework was adopted in 2016. IBFAN believes that FENSA threatens WHO’s unique role as the coordinating authority in setting global health norms. We fear that it will lead to misplaced trust, image transfer, confusion and a weakening of the WHA resolutions that IBFAN has advocated for the last 40 years.
We know that the decision to adopt FENSA was very much linked to the failure of Member States to fund WHO properly, and also to the pressure from powerful nations and corporations (the same entities that threaten human and planetary health) that WHO should be part of a “global stakeholder governance” system. WHO has alsobeen under pressure to be less ‘risk averse’ and to use FENSA as an enabling framework for yet more public-private entanglements/ hybridisation. WHO is now in an institutional conflict of interest situation and it is hard to see how it can escape without a fundamental rethink.
One major problem is that despite many requests from Civil Society, WHO has, so far, failed to correct its own Conflict of Interest definition. This is a major fault-line that runs through FENSA .
In our response to this consultation, we call for a thorough and transparent evaluation. We disagree with the statement in report 145/4 that WHO’s constitution ‘forsees’ the participation of NSAs in WHO’s governing bodies. WHO’s basic documents have always been clear that NGOs must be “free from concerns that are primarily of a commercial or profit-making nature.” In allowing Businesses and Philanthropies to enjoy Official Status, WHO has taken a huge leap into the dark. WHO has a constitutional duty to consult with civil society as rights holders. Businesses do not have these rights. The term “non-State actors” makes it impossible to see what’s really happening and who is really working for the public good. We even all wear the same colour badges. FENSA also places a huge strain on WHO’s due diligence process.
1) WHO definitions confuse conflicts of interest within an institution or person with conflicts between actors who have diverging or fiduciary duties (which in the case of corporations is to maximise profits).
The results of the Evaluation will be posted on WHO’s website before the end of December.
Below is the invitation we received and our response to a very complicated consultation procedure.
Dear representative of a non-State actor in official relations with WHO,
Further to resolution WHA69.10 (2016) of the World Health Assembly, WHO has been mandated to conduct an Initial Evaluation of the Implementation of the Framework of Engagement with Non-State Actors (FENSA). The objective of the initial evaluation is to assess the status of implementation of the Framework of Engagement with Non-State Actors and its impact on the work of the Organization, not the Framework itself. Accordingly, the evaluation will: (a) document key achievements, best practices, challenges, gaps, and areas for improvement in the implementation of the Framework since its adoption in May 2016; and (b) make recommendations as appropriate on the way forward to enable the full, coherent and consistent implementation of the Framework.
As a representative of a non-State actor in official relations with WHO, your views on the implementation of FENSA to date – and any changes that may have occurred as a result of this relationship – are crucial in this evaluation. The evaluation team contracted to conduct this exercise is therefore seeking your views through an online survey, deployed and administered by the WHO Evaluation Office and available (in English, French and Spanish) through the following link:
All data collected through this survey will be treated confidentially and presented in a way that ensures non-disclosure of individual responses, and responses will not be used or shared for any purpose other than the evaluation.
Completion of the survey may require wider consultation. However, please note that only one consolidated questionnaire can be accepted per organization.
The deadline for completion of the survey is Thursday, 31 October 2019. Should you have any questions between now and this deadline, please do not hesitate to contact us at email@example.com.
Thank you in advance for your participation in this important evaluation.
Dr Elil Renganathan
DG Representative for Evaluation and Organizational Learning I Evaluation Office I World Health Organization
Tel: +41-22-791 5508 www.who.int/evaluation