Response of WHO to KEI letter regarding McKinsey, vaccine policy and competing interests

On 20 February 2011, Dr. Keiji Fukuda, Assistant Director-General – Health Security and Environment, World Health Organization, responded to KEI’s letter (16 February 2011) regarding McKinsey, vaccine policy and competing interests. Here is the response in full (email contacts have been redacted).

From: “Fukuda, Keiji”
Date: February 20, 2011 4:14:05 PM GMT+01:00
To: “Thiru Balasubramaniam”
Cc: jgomezc, , “Solomon, Steven Alan” “Burci, Gian Luca” , “Bowman, Anna”, “Huvos, Anne Marie” , “Meloni, Jill A.”, “Smith, Ian Michael”, “Pfitzer Iii, James”
Subject: RE: Letter to WHO on conflicts of interest concerning McKinsey as an advisor on vaccine policies

Dear Mr Balasubramaniam,

Thank you for your letter expressing concern over the “general WHO practice of using consulting firms, and the specific case of using McKinsey & Company as an advisor on vaccine policies”. At the outset, allow me to state quite categorically that WHO has never retained McKinsey & Company to provide advice on, or develop, its vaccine policy.

The document you refer to, “Preliminary findings for the technical studies under resolution WHA63.1”, was a technical study requested by the May 2010 World Health Assembly in the context of the Open-ended working group (OEWG) on Pandemic Influenza Preparedness. The specific request to the WHO Director-General was to provide Member States working on the “Framework for sharing influenza viruses and access to vaccines and other benefits”, necessary information, inter alia, in three technical areas: laboratory and surveillance capacity building; expanding global influenza vaccine production capacity; and increasing access to certain pandemic supplies. Preliminary findings of these studies were requested to be provided to the OEWG session of December 2010. As such, the time available to undertake the technical studies was very limited.

Terms of reference for the studies were developed with the OEWG Bureau and consultations with WHO Member States. They were issued in July 2010. At that time, the technical needs and gaps to complete the studies became clear to the Organization. The area where WHO required substantial assistance was in the costing of options to improve global preparedness in the three technical areas cited above, most notably that for expanding global vaccine product capacity. The Bill & Melinda Gates Foundation offered to provide in-kind assistance to WHO in the form of the services of McKinsey & Company. WHO Member States were informed of this assistance from its inception. WHO was not party to the contract between the Bill & Melinda Gates Foundation and McKinsey & Company, and does not have the financial information for the arrangement between them.

The study is and remains the work of the WHO Secretariat: neither the Bill & Melinda Gates Foundation nor McKinsey & Company provided advice to the WHO Secretariat about vaccine policy for or in relation to it. Furthermore, WHO neither sought nor received from them views on or policy assessments of the options in the study. With respect to the costing data itself, the fact that it was developed by McKinsey & Company, and the process for doing so, was communicated to all WHO Member States. WHO continues to welcome comments regarding that data, as well as any other aspect of the study.

More generally, WHO’s formal policy on Declarations of Interest seeks to elicit from experts who are hired by the Organization to provide their own expert views and advice, any interest that may affect, or reasonably be perceived to affect, their objectivity and independence in providing such advice to WHO. As stated above, none of the work requested of, or provided by, McKinsey & Company was of an advisory nature and none affected any policies of the Organization.

Finally, as was explained in the civil society consultation by the co-chairs, the practice of the Organization in its dealings with consulting firms is to treat them in the same manner as companies. Thus, full disclosure of the participation of the company is made (as was done for the Study) as a matter of practice, and no formal Declaration of Interest is required. However, WHO can still can still assess whether previous work performed or previous positions taken publicly by the entity may affect (or be perceived to affect) the services rendered by that entity to WHO. I hope this explanation clarifies that WHO vaccine policy was never the subject of the work carried out by McKinsey & Company and that strict compliance with our policy on Declarations of Interest remains of utmost importance to the Organization.

Thank you.

Keiji Fukuda