A new tender put out by The National Advisory Committee of Canada seeks to hire someone to provide “Guidelines for the Economic Evaluation of Vaccines.” The tender aims to follow the recommendations outlined in the National Advisory Committee on Immunization (NACI) Guidelines for the Economic Evaluation of Vaccines in Canada (“NACI Economic Guidelines”).
The NACI is run by the Public Health Agency of Canada (PHAC). The agency has expanded the mandate of the NACI to include “systematic consideration of programmatic factors in developing evidence-based recommendations to facilitate timely decision-making for publicly funded vaccine programs at provincial and territorial levels. The additional factors to be systematically considered by NACI include: economics, ethics, equity, feasibility, and acceptability.”
An economic process is outlined to an economic evaluation and budget impact analysis. Part of that process includes a “skeleton” flow chart reference where Question 1 starts off with simply “Is there a need?” One would think this would have occurred before rolling out over 80 million doses of COVID-19 vaccines to Canadians.
This tender also comes at a time when regulatory initiatives are being undertaken to develop COVID-19 vaccination requirements under the Canada Labour Code. The initiative is to “develop new, standalone Regulations under Part II of the Labour Code, where the Government will require vaccination of federally regulated employees, except under very limited circumstances… This developing regulation would impact all federally regulated employees and as a result they are expected to benefit from the protection afforded by increased COVID-19 vaccination rates, reduced transmission of COVID-19 in the workplace and, by extension, in their communities. When transmission does occur, those who are vaccinated are expected to benefit from reduced negative health outcomes.”
But there’s no guarantee. And their semantics proves it. They are expected to benefit, that doesn’t mean that they necessarily will.
Apparently, consultations with stakeholders on this regulatory proposal took place in December of 2021 and regulations could be published in Gazette II.
For reference, the Canada Gazette is the official newspaper of the Government of Canada. The Government is supposed to “publish proposed changes to regulations to solicit comments from Canadians.” It’s supposed to be “the vehicle that allows you to send comments or concerns to the appropriate department or agency so that you can actively participate in Canada’s regulatory process which is our democratic right so that you may comment on proposed regulations.
Yet the federal vaccine mandate was first announced in a News Release on December 7, 2021 by the Minister of Labour. It notes that the Government will consult with key stakeholders, including representatives of small and medium-sized employers, as it works expeditiously to finalize the new regulations, which would come into force in early 2022.”
And the proposed changes to the Canada Labour Code don’t appear to have shown up in the Gazette I. Searching through every Gazette published in December, there was nothing about proposals to change Part II of the Labour Code, about Occupational Health and Safety or mandating COVID-19 vaccines across all federal employment sectors.
And when questioned about who the stakeholders were, what their feedback was and why there is no mention of this in Gazette I, the media contacts replied with all of the links and information I’ve already sifted through above. So we filed an Access to Information Request to find out. You can support this effort here.
This is especially timely if these regulations are supposed to come into effect sometime early 2022. We’re already halfway through March.