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Association Internationale de la Mutualité

AIM

The Association Internationale de la Mutualité is an international umbrella organization for non-profit health mutuals and insurance funds.

Lobbying Activity

Meeting with Sonia Vila Nunez (Cabinet of Executive Vice-President Roxana Mînzatu)

9 Dec 2025 · To discuss the European Pillar of Social Rights and AIM's activities in the area of social protection.

Health mutuals urge EU to maintain dedicated public health funding

29 Oct 2025
Topic — This consultation addresses the Union prevention, preparedness, and response plan for health crises.
Message — AIM demands dedicated funding for health and an integrated policy approach. They seek EU-wide medicine stockpiling and support for not-for-profit mutuals.12
Why — Legal recognition would help mutuals avoid taxes that currently force higher membership fees.3
Impact — For-profit insurance companies may lose competitive advantages if mutuals gain specific legal recognition.4
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Meeting with Olivér Várhelyi (Commissioner) and

2 Oct 2025 · All pressing portfolio topics

Response to Mid-Term Review: Social Economy Action Plan

16 Jul 2025

The International Association of Mutual Benefit Societies (AIM) is a global network for equitable health and social care, which serves as the international umbrella organisation for federations of health mutuals and statutory and complementary health insurance bodies. According to mutuals active in healthcare, it is necessary to: 1. Ensure that all Member States develop national action plans for the social economy according to the Council Recommendation on developing social economy framework conditions (C/2023/1344). A strategic document is needed to drive and develop social economy entities, looking at the sector in a cross-cutting way, encompassing the diversity of activities they engage in, rather than in a sectoral manner. 2. Make National Action Plans for the Social Economy (NAPSEs) compulsory. Although we recognize that the European Commission cannot impose this through direct legislation, we believe there are effective and proportionate political instruments that should be encouraged and proposed in this public consultation. 3. Facilitating the development of existing mutuals, in particular through tax policies to compensate for the reduced access to capital; 4. Capacity-building for Social-Economy Entities: Many social-economy organisations lack the human and material resources to make full use of European instruments such as the Social Economy and Proximity Platform. We therefore suggest emphasising programmes for technical, digital and organisational capacity-building, together with support mechanisms for accessing EU funding and taking part in cooperation networks. 5. Dedicated financing is a cornerstone of the EAPSE, but for that investment to be ever more efficient it must be articulated with social-economy entities own strategic development plans. Deepening coordination between EU funds, national plans and local structures will be essential to consolidate a favourable ecosystem for the social economy. 6. Encourage the creation of the legal status of mutual in countries where it does not exist; 7. Develop a European Mutual Statute for better integrating mutualitys into the single market and a better recognition; 8. Allow (and not force) the creation of the European Mutual Insurance Group to permit cross-border cooperation while respecting national specificities; 9. Activate more stringent control and transparency procedures at all levels to verify the actual non-profit and solidarity nature of a mutual benefit society. There is the phenomenon of false mutuals, meaning mutual societies established and substantially directed by insurance companies, only for the purpose of taking advantage of the tax advantages which are related to real mutual benefit societies. These false mutual benefit societies are managed according to commercial logic and represent a real threat to the reputation of the mutual societies, and which determine unfair competition They must be unmasked and expelled from the social economy sector. 10. Programmes such as Erasmus+ should be reinforced regarding the mobility of social-economy professionals and leaders. Therefore, AIM calls for: Dedicated, sector-specific lines within existing mobility schemes; Simplified application procedures; Enhanced national promotion and technical support for organisations in the sector.
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Meeting with Aurelijus Veryga (Member of the European Parliament)

9 Jul 2025 · How to make medicine more available for everyone

Meeting with Tilly Metz (Member of the European Parliament, Shadow rapporteur) and Bureau Européen des Unions de Consommateurs and

13 Jun 2025 · Critical Medicines Act

Meeting with Patricia Reilly (Cabinet of President Ursula von der Leyen)

11 Jun 2025 · Meeting with AIM’s board

Health mutuals urge EU to prioritize healthcare in AI strategy

4 Jun 2025
Topic — The EU initiative seeks to accelerate industrial AI adoption and improve public services.
Message — The organization requests that healthcare be treated as a priority sector in the EU strategy. They call for removing legal hurdles and facilitating data access to speed up AI adoption. They also want all health stakeholders included in future EU policy work.12
Why — Mutuals would overcome technical expertise shortages and improve their internal processing workflows.34
Impact — Data privacy advocates and safety regulators might see standards weakened by removing legal hurdles.5
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Meeting with Pascal Arimont (Member of the European Parliament)

19 Feb 2025 · European Health and Social Policies

Meeting with Tilly Metz (Member of the European Parliament)

12 Nov 2024 · Access to medicines

Meeting with Marc Angel (Member of the European Parliament)

6 Nov 2024 · EU Health Policy

Meeting with Pierre Jouvet (Member of the European Parliament) and Fédération Nationale de la Mutualité Française

14 Oct 2024 · Enjeux de santé

Response to Health technology assessment – Procedural rules for the assessment and management of conflicts of interest in joint wo

26 Jun 2024

AIM is the International Association of Mutual Benefit Societies. AIM is an international umbrella organisation of federations of health mutuals and health insurance bodies in Europe, Latin America and Africa and the Middle East. Our members participate in decision-making bodies on the inclusion of pharmaceutical products in healthcare systems and are therefore key players in the provision of these products to populations. AIM would like to thank and congratulate the European Commission for drafting and opening the consultation on this implementing Regulation on conflicts of interest (CoI). It is only with a strong CoI policy that one can build the trust in a robust European Health Technology Assessment framework. We therefore call on building on the already strong elements contained in the draft implementing Regulation that the European Commission published. You can fing below our additional comments: 1. Not restrict expert investigation to pharmaceutical companies and extend them to pharmaceutical industry associations (national, regional and international) as high-risk organisations with which the expert shall not have links related to current or past employment, consultancy, strategic advisory role, or financial interests 2. Consider adding gifts or in-kind gifts to the list of payments/compensations that the considered expert has received as part of Q4.2 in the Annexes
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Meeting with Ana Carla Pereira (Cabinet of Commissioner Nicolas Schmit)

20 Mar 2024 · next Commission’ priorities

Meeting with Stella Kyriakides (Commissioner)

19 Jan 2024 · Exchange of views on ongoing EU actions relating to the European Health Data Space, the impact of climate change on healthcare systems and the reform of the EU pharmaceutical legislation

Response to Managing EU climate risks

12 Jan 2024

Health at the centre of response, mitigation and adaptation efforts AIM welcomes the opportunity to provide feedback on this initiative. Break silos To achieve societies that are truly resilient to climate risks we also need to simultaneously consider health, (other) environmental, and socio-economic risks. An important step to achieving this is to carry out climate, environmental and health risk assessment for all policies and to follow a One Health approach. Health should be a central consideration in all environmental policies. Ensure a fair and inclusive transition Climate change exacerbates vulnerabilities and inequities. Specific attention should therefore be given to vulnerable groups like citizens from lower socio-economic backgrounds, children, older people or people with chronic diseases. Societies can only become resilient if the transition to climate-neutrality is fair and inclusive. In this regard, we highlight importance of strong social protection systems to tackle inequities within Member States, but also mechanisms to support countries with less resources. Economies which strongly rely on fossil fuels should also be supported , to make the transition to climate-neutrality while ensuring no one is left behind. Improve climate and environmental health literacy Another important aspect is climate and environmental health literacy and citizen engagement. Populations should be aware and understand the health risks associated with climate change. Achieving climate neutrality requires changes in our ways of life and bold action that can only be accepted if people are aware of risks for their health and of the impact of current ways of life on climate and the environment in general. Our recommendations for the health sector The health sector plays a key role in climate mitigation, adaptation and preparedness. Contributing to climate change, not only is it a key player in climate mitigation but it will also need to adapt to changing needs and operating conditions. So will social protection systems, if they are to constitute an essential tool in ensuring that societies become more resilient to the effects of climate change. In the document enclosed, we provide a series of recommendations specifically for health and social protection systems.
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Meeting with Astrid Dentler (Cabinet of Commissioner Wopke Hoekstra)

10 Jan 2024 · Health aspects reflected in climate policy

Health mutuals demand more transparency in medicine variation rules

26 Sept 2023
Topic — The EU is reviewing rules for post-authorisation changes to medicines for human use.
Message — AIM calls for more transparency and proactive information on changes impacting medicine safety. They request a searchable database to track variations and history of product indications.12
Why — Better information helps members manage pricing committees and evaluate the benefit-risk profile of drugs.34
Impact — Drug manufacturers could see increased transparency requirements and more stringent evidence standards for updates.5
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Meeting with Sarah Wiener (Member of the European Parliament)

9 May 2023 · staff-only: marketing of unhealthy food to children

AIM Urges Comprehensive EU Mental Health Strategy Integration

15 Feb 2023
Topic — Public health initiative to integrate mental health promotion and prevention into all EU policies.
Message — AIM calls for embedding mental health across all policies and ensuring sustainable long-term funding. They advocate for community-based care and better protection for gig economy workers.123
Why — Sustainable prevention funding and community-based care would reduce long-term medical costs for mutuals.45
Impact — Gig economy platforms would face increased costs from new occupational health and safety requirements.6
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Response to New Agenda for Latin America and the Caribbean

8 Feb 2023

La pandemia ha puesto de relieve la dimensión mundial de la sanidad, tanto para la vida y el desarrollo de las comunidades y estados,subrayando al mismo tiempo la importancia de la colaboración transfronteriza. La cooperación entre naciones y regiones es necesaria para hacer frente a la crisis sanitaria y económica que atraviesa el mundo, así como a las crisis futuras de toda índole. Sin embargo, hasta ahora, la relación entre América Latina y la Unión Europea (UE) ha quedado a menudo relegada a un "segundo plano", centrada sobre todo en el comercio y basada en acuerdos bilaterales. Sin embargo, la colaboración entre ambas regiones es clave para alcanzar los Objetivos de Desarrollo Sostenible y afrontar los retos sanitarios, sociales y medioambientales del siglo XXI. La AIM anima a la Comisión Europea a adoptar un enfoque del comercio que tenga como objetivo reducir la pobreza, promover el desarrollo sostenible y garantizar el respeto de los derechos sociales, medioambientales y laborales. Los Objetivos de Desarrollo Sostenible deben convertirse en el timón de la cooperación política, comercial, de inversión y de desarrollo entre la UE y América Latina y el Caribe. La salud y el bienestar de los ciudadanos deben estar en el centro de la colaboración. Es necesario empoderar y actuar con las comunidades en su bienestar y su destino, así como centrarse en las personas, sus capacidades y necesidades y no en el lucro. La AIM pide a la UE que refuerce sus lazos con la región latinoamericana. Si bien la asociación entre América Latina y la UE podría verse afectada por las diferencias políticas existentes en la región y por la voluntad de los gobiernos de centrarse en la soberanía nacional, tal diversidad no debería constituir un obstáculo para la colaboración. La AIM anima a la UE a centrarse en los acuerdos bilaterales con los gobiernos nacionales y, al mismo tiempo, a intentar reforzar su relación con la Alianza del Pacífico. Recomendamos tanto a la UE como a los gobiernos nacionales que se esfuercen por ampliar dicha Alianza con el fin de incluir a más países de la región y centrarse en los ODS como base para la colaboración. Si el clima, el medio ambiente, la innovación, la integración económica, el desarrollo regional... son objetivos importantes, pedimos a la Comisión Europea que garantice que las preocupaciones sanitarias y sociales también representen una prioridad máxima del partenariado. La AIM insta a que se concluya un acuerdo de libre comercio UE-Mercosur sostenible, que tenga como núcleo los derechos humanos y la salud humana y medioambiental. Además de los acuerdos bilaterales con diferentes países de America latina, es fundamental concluir los acuerdos entre la UE y el MERCOSUR. Esos acuerdos comerciales deben hacer especial hincapié en lo que respecta el área social, sanitaria, cultural y medioambiental. Instamos a la Comisión Europea a que llegue a un acuerdo sobre un tratado de libre comercio sostenible, que defienda los valores democráticos y ponga en el centro los derechos humanos, la salud y el bienestar de las personas, así como el medio ambiente. Confiamos que las ambiciosas metas que proponemos, podrán hacerse más realistas y flexibles con la participación ciudadana de las organizaciones solidarias que integran la AIM, con asiento en la Unión Europea y América.
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Response to Vaccine-Preventable Cancers

6 Feb 2023

AIM welcomes the European Commissions ambition to increase vaccination rates against Human papillomaviruses (HPV) and Hepatitis B (HBV) viruses. AIM makes the following recommendations: Vaccination against HPV and HBV should be part of schedules and as such be fully reimbursed. HPV and HBV vaccines should be administered outside clinical settings, provided that the necessary expertise and equipment is available. EU guidelines and tools on communicating about vaccination should be provided. Tackling vaccine hesitancy should be a priority at Member State and European levels. An EU vaccination schedule should be developed and implemented. It should include vaccination against Human papillomaviruses (HPV) and against Hepatitis B virus (HBV). A more detailed explanation of our recommendations can be found in the document enclosed.
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Response to Proposal for a Directive on cross-border activities of associations

28 Oct 2022

AIM, the International Association of Mutual Benefit Societies (AIM,) is an international umbrella organisation of federations of health mutuals and health insurance bodies counting with 52 members from 28 countries around Europe, Latin America and Africa and the Middle East. We welcome the introduction of a European regulatory framework that strengthens the legal position of associations and NPOs operating across borders in the EU internal market. In addition, the different legal and administrative requirements in the EU member states should be adjusted and unjustified restrictions should be reduced. It will enable European associations and NPOs to make better use of the advantages of the EU internal market for their activities and enables associations and NPOs operating across borders to better engage in economic and social processes. A divergence of regulations between different forms of organisation, associations and companies as well as other actors of the Social Economy, would otherwise lead to more legal uncertainty and thus become an obstacle to the functioning of the EU internal market. AIM regrets deeply that mutuals benefit societies do not seem to be included in the proposal although they are part of the Social Economy. The same that counts for associations and NPOs should count for mutual benefit societies. They are an important actors in the healthcare sector and offer healthcare services at an affordable price at a high quality, they make no risk selection, and they are based on solidarity and democracy. Support for mutual benefit societies in accessing the freedoms of the EU internal market also counts for these social economy enterprises. Measures of the European Commission must be oriented towards the existing freedoms for not-for-profit-oriented enterprises such as social economy enterprises. But it should count for all social economy enterprises and not only some of them to avoid discrimination. This applies in particular to the free movement of services. We have sent legal alternatives on how to achieve a legal framework for mutual benefit societies as well. One is the enhanced cooperation. You will find it attached.
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Response to Developing social economy framework conditions

30 Sept 2022

The International Association of Mutual Benefit Societies (AIM) is an international umbrella organisation of federations of health mutuals and other not-for-profit healthcare payers. It has 52 members from 28 countries in Europe, Latin America and Africa and the Middle East. AIM members provide compulsory/and/or supplementary health coverage to around 230 million people around the world, including close to 200 million people in Europe. Some AIM members also manage health and social services. AIM Members are either mutual or health insurance funds. They are private or public legal entities; solidarity based; not-for-profit orientations: surpluses are used to benefit the members and improve services; democratically elected members play a role in the governance of the organisation. AIM’s priorities are the following: • Promote solidarity in re-shaping our welfare systems • Enabling universal access to health and long-term care • Affordability of and access to medicine • The power of data for better health • Promotion of mutual welfare models • Promotion of health in all policies Please find our detailed inout in the attachment,
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Response to Revision of the Union legislation on blood, tissues and cells

8 Sept 2022

AIM, the International Association of Mutual Benefit Societies, the leading international association of not-for-profit healthcare insurers, representing not-for- profit organisations providing health coverage to around 200 million people in Europe, welcomes the European Commission’s proposal to revise the framework for standards of quality and safety for substances of human origin. AIM will focus on aspects related to the definition, classification, evidence generation, as well as transparency and stakeholder collaboration as part of its feedback on the proposed legislation. Please find our points below. Definition We need a better definition of what a SoHO preparation is. At this stage, we understand that it designates a specific category of products, after they underwent a number of processing stages, but it is not clearly defined in the text. For the sake of clarity, we need to better differentiate between the definitions of a SoHO establishment and of a SoHO entity. Current definitions are too vague and can lead to confusion between the two types of bodies. Under the current definitions, a SoHO entity could be doing just as many as, or even less activities than a SoHO establishment (which role is to process and store SoHOs). It is problematic as the two bodies have very different roles in the EU framework for the safe use and application of substances of human origin, as well as regarding contacts with donors and recipients and competent authorities. We believe that a SoHO entity is a SoHO establishment that undertakes one or more activities in addition to SoHO processing and storage. (Art. 3) Classification It is good and encouraging that the proposal foresees that the decision on the classification of substances in this regulation is primarily in the hands of the Member States. We would recommend to restrict the opportunities for the European Commission to determine the status of a substance under this regulation to requested to do so by the Substances Coordination Board, or by at least three Member States. (Art 14) Evidence generation It is good that the European Commission introduces risk-based clinical outcome monitoring plans include evidence generation, as it will harmonise the collection of clinical data for SoHOs (Art 41). The European Commission should support the setting-up of registries on clinical outcome monitoring. They are key elements of the trust in the future framework. This support can be financial or under another form, under the form of trainings, for instance. Those registries on clinical outcome monitoring need to be “easily” consultable for interested stakeholders and be accessible to the users of the SoHO Platform. Lastly, one needs to better define low-, middle- and high-risk SoHO, as this will be critical for entities applying for SoHO preparations authorisation. Transparency and stakeholder collaboration In general, the public and a large part of relevant stakeholders risk not being involved and informed enough about key elements of the future framework: there is little in the proposed regulation on the transparency of decisions of competent authorities, of the decisions of the SoHO Coordination Board, or of potential Commission decisions. In addition, publicly accessible information is merely mentioned at the end of the proposal. The Regulation should at least specify that outcome of classification and outcome of assessments should be public as a rule. Stakeholders should also have access to some parts of the SoHO Platform, for instance SoHO rapid alerts, all provided that personal data is protected under the highest possible standards.
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Health mutuals demand realistic timelines for EU health data space

15 Jul 2022
Topic — This proposal creates a framework for cross-border health data exchange and research.
Message — AIM calls for delaying the 2025 implementation deadline and ensuring citizens have tools to manage data consent. They also propose reducing administrative burdens to prevent bottlenecks in data access permits.123
Why — Streamlined permit processes and extended timelines would lower administrative costs and organizational pressure.45
Impact — Individuals with limited digital skills may lose control over their private health data.6
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Health mutuals urge outdoor smoking and vaping bans

14 Jul 2022
Topic — Updating EU rules to include e-cigarettes and outdoor spaces in smoke-free environments.
Message — AIM requests including e-cigarettes in the recommendation and banning outdoor smoking. They emphasize protecting vulnerable groups like children from harmful chemical aerosols.123
Why — Lower healthcare costs would benefit health mutuals as public health improves.4
Impact — Tobacco and vaping industries lose revenue as smoking becomes less accessible.5
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Response to Evaluation of the rates and structures of excise duty on alcohol and alcoholic beverages

30 Jun 2022

AIM welcomes the opportunity to provide feedback on the on the evaluation of excise duty rates and tax structures. Increased Taxation as a best buy for Public Health Increasing the price of alcohol is one of the most cost-effective alcohol policies available. Pricing policies have also been identified by WHO as second “best buy” in the fight against non-communicable diseases. Regulating prices through increased taxation or the establishment of Minimum Unit Pricing has proved to reduce overall consumption and associated harm. Price control also has the potential to help reduce inequities and protect vulnerable populations, especially young people. It can influence preferences and discourage binge-drinking. Specific taxation on basis of alcohol content as a more powerful instrument As WHO underlines in its latest report, pricing policies are effective both in reducing harm and in delaying the age at which adolescents and young adults start drinking. The report encourages specific taxation (on basis of alcohol content) as a more powerful instrument. Other types of taxation (unitary or ad valorem) could encourage manufacturers to produce stronger products, which could result in increased consumption. Specific taxation is also likely to have the biggest effect on the reduction of health inequalities. Alcohol duties are also listed as an effective measure in that report. AIM agrees with WHO in asking Member States to levy duties on all forms of alcoholic beverages, including wine. Minimum Unit Pricing as a powerful tool to reduce alcohol-related harm “[By] requiring non-alcoholic beverages to be sold at a lower price, banning below-cost selling and volume discounts, and implementing an additional levy on specific alcoholic products (…)”, Minimum Unit Pricing (MUP) has the potential to reduce alcohol consumption among harmful drinkers and thus decrease alcohol-related mortality and hospitalisations. Indeed, it only increases the prices of the cheapest products, which are those most consumed by heavier drinkers. In countries like Australia, the introduction of the MUP has led to a decrease in alcohol-related assault offences, alcohol-related ambulance attendances, alcohol-related emergency department presentations and Alcohol-related road traffic crashes (to cite but a few). MUP therefore has the potential to improve public health by reducing alcohol-related harm while reducing the burden of that harm on healthcare systems.
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Health mutuals urge EU to expand compulsory licensing scope

29 Apr 2022
Topic — The EU is consulting on harmonising fragmented procedures for compulsory patent licensing.
Message — AIM calls for lifting data and market exclusivity to ensure product availability. They suggest harmonizing national laws while maintaining broad reasons for issuing licenses.12
Why — Broad licensing allows mutuals to provide more affordable medical countermeasures to patients.3
Impact — Pharmaceutical companies lose exclusive control over clinical data and manufacturing secrets.4
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Response to Proposal for a Council Recommendation on long-term care

25 Mar 2022

AIM welcomes the opportunity to provide input on the upcoming EU Care Strategy. According to AIM: 1. The EU Care Strategy should put solidarity at its core: - Supporting the development of solidarity-based social protection systems and actors, such as mutuals; - Fostering intergenerational solidarity and cohesion across all sectors of society; - Defining and promoting the concept of solidarity in a changing world. 2. The EU Care Strategy should follow a human-rights approach: - Ensuring fundamental rights and setting targets for formal long-term care; - Setting concrete and measurable goals to monitor progress on social ambitions. 3. The EU Care Strategy should contribute to guaranteeing access to high-quality long-term care across the EU: - Establishing EU indicators for LTC on accessibility, sustainability and quality; - Setting concrete and measurable goals to monitor progress on social ambitions; - adopting a quality framework for long-term care services; - establishing an EU Observatory for Care for Older People; - better integrating of LTC in the European Semester; - setting up a a Steering Group on LTC; - lead to the publication of EU guidelines on needs assessment and eligibility criteria for LTC. 4. The EU Care Strategy should help ensure the sufficiency, efficiency, and well-being of the care workforce; - Proposing an updated Action Plan for the EU Health and LTC Workforce - Establishing a new EU Joint Action (JA) on forecasting health and LTC workforce needs for effective planning. 5. The EU Care Strategy should aim at the better support and proper recognition of informal carers: - Ensuring a better recognition of carers and their rights across the EU; - Achieving more flexibility in the exercise of carers rights in cross-border situations. 6. The EU Care Strategy should integrate mental health as a key concern; - Taking into account the impact of all the measures it will propose on the mental health of carers (both formal and informal) and care recipients. 7. The EU Care Strategy should seek to unleash the potential of new technologies for care: - Developing innovative solutions in collaboration with formal and informal carers as well as care recipients and with the involvement of payers; - Improving levels of Digital literacy. 8. The EU Care Strategy should ensure better preparedness for future health crises: - Proposing guidance for professions at risk on how to ensure proper working conditions and high levels of health protection in times of crisis; - Promoting the identification and exchange of best practices at European level (that should feed into the guidance); - Establishing networks of professionals and use existing networks to step up collaboration on the development of such guidance and contribute to its implementation; - Providing financial and technical support to Member States on the implementation of that guidance.
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Response to Recommendation for strengthened actions against antimicrobial resistance

24 Mar 2022

AIM welcomes the opportunity to provide feedback on the EU initiative “Antimicrobial resistance – recommendation for greater action”. More information on our recommendations can be found in the attached statement, that we summarise as follows: New financing models for antibiotics are needed AMR is responsible for an estimated 33,000 deaths per year in the EU the healthcare costs and productivity losses related to it amount to approximately EUR 1.5 billion per year in healthcare costs and productivity losses. Yet, the level of investment in the development of antimicrobials is disappointing. Apart from scientific challenges, a reason for the lack of innovation often claimed by the pharmaceutical industry is the lack of profitability in this disease area. A new financing model is needed. Already more than 50 national and international initiatives were taken the last decade to incentivize antibiotic R&D but have not yet resulted in the antibiotic we need to tackle current resistance issues. AIM calls for a new incentives system, based on global coordination, the right mix between R&D (“push”) and marketing and access (“pull”) mechanisms. Patient access and sustainability requirements should also be a focus of such new incentive programmes. Prevention and rational use as essential elements of any strategy to fight AMR: low hanging fruit! In addition, it is key to ensure that the antibiotics that are available and future ones, are used in a responsible way in every sector so that their effectiveness can be safeguarded. We need comprehensive preventative measures and rational use, as it will take a while before new drugs come out of the pipeline. Governments, healthcare workers and citizens should work together as it is in the interest of all of us to prevent bacteria to develop further resistance to the existent antibiotics. Our recommendations - Strengthen the role of primary care in tackling AMR: Primary care doctors and other healthcare providers should be trained and advised by specialists on antimicrobial prescribing. When it comes to hospitals, “the continuous education of prescribers and specialists included in comprehensive hospital strategies, the development of evidence-based hospital antibiotic guidelines and policies, and a proper Monitoring of hospital antibiotic resistance” are necessary. (ECDC, Antibiotic Resistance – Facts and Figures, 2020) - Prevent the misuse of antibiotics through higher levels of health literacy: Member States and the European Commission should organise communication campaigns in collaboration with all stakeholders (healthcare payers, doctors, NGOs, patients, etc.) to raise awareness on proper antibiotic us and on the consequences of AMR. - Collect more and better data on AMR: Updated figures on AMR are necessary to ensure effective policy responses. Evidence is also needed on the outcomes of the actions which are being carried out. - Follow the One Health approach: Given that resistant micro-organisms exist in humans, animals and the environment, it is vital to follow a one health approach in tacking AMR, looking at the link between those areas and developing policies which target the whole scope of the problem - Implement innovative models to stimulate research into new antimicrobials: AIM is in favor of a model that delinks R&D costs and innovation from price and sales volumes. AIM suggests a concept where a pharmaceutical company can receive initially (minimum) incentives to cover some of the expenses for (efficient!) R&D and to set up a supply system. Later, annual payments may increase depending on the outcome of post-marketing data on effectiveness, resistance profiles and stewardship arrangements. - Think global: International collaboration on AMR should be intensified. Both European and International Organisations should provide support to developing countries.
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Meeting with Tove Ernst (Cabinet of Commissioner Stella Kyriakides)

24 Feb 2022 · Discussion on Europe's Beating Cancer Plan

Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion)

24 Feb 2022 · social economy, platform work, care strategy

Response to Cancer Screening Recommendation

22 Feb 2022

AIM welcomes the European Commission’s intention to update the Council Recommendations on Cancer Screening and the opportunity to be involved in the process. AIM thinks that this update is indeed timely and necessary given the recent advancements and latest available science, as well as the lessons learnt during the COVID-19 pandemic, which seriously disrupted EU screening programmes. According to AIM, the update should promote public health protection as a guiding principle. A cautious approach to the extension to other cancers The risk-benefit ratio of mass screening programmes for cancers such as breast cancer has been established. However, other cancers, such as prostate and lung cancers, are not yet in this category. We urge the European Commission to take a cautious approach when considering whether those cancers should be included in the Recommendations, until further scientific proof has been established. We also urge that ethical considerations be factored into screening decisions, as well as encouraging the use of tools like shared decision-making with patients. Tackling inequalities in access Within and across Member States, inequalities in access to existing screening programs persist. A major topic to consider, according to AIM, is how to better target vulnerable groups. AIM applauds the European Commission's determination to investigate success factors, namely the implementation of the Recommendations in resource-constrained settings. It is also critical to ensure that data on the implementation of present programs is comparable across the EU if we are to address those imbalances. A Task-Force of Experts for evidence-based recommendations AIM has established a Task Force of Screening Experts from several Member States. In the next months, they will convene to generate concrete recommendations for the upcoming update. The Experts will ensure that AIM's recommendations to the Commission are based on evidence and always seek the highest protection of public health. AIM will be in contact with the European Commission in the coming month to share that expert advice.
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Meeting with Ralf Kuhne (Cabinet of Commissioner Stella Kyriakides)

21 Feb 2022 · VTC meeting on European Health Data Space

Meeting with Sarah Wiener (Member of the European Parliament) and European Public Health Alliance

3 Feb 2022 · Marketing of nutrionally poor food to children

Meeting with Sergey Lagodinsky (Member of the European Parliament, Rapporteur)

13 Jan 2022 · Associations Statute

Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

17 Sept 2021 · Governance on the exchange of health data

Meeting with Sarah Wiener (Member of the European Parliament) and European Public Health Alliance

6 Sept 2021 · Marketing of nutrionally poor food to children

Meeting with Nicolas Schmit (Commissioner) and

13 Jul 2021 · Meeting on the Social Economy Action Plan and the future of welfare state.

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

9 Jul 2021 · Digital health policy and Artificial Intelligence

Response to Revision of Food Information to Consumers for what concerns labelling rules on alcoholic beverages

8 Jul 2021

AIM recommends revising the rules for all alcoholic beverages. The existing exemption to provide the list of ingredients and a nutrition declaration on label for alcoholic beverages containing more than 1.2% by volume of alcohol should be revoked. Mandatory indications should be required to be provided on label for all alcoholic beverages. (option 2 in the roadmap) Empowered consumers Consumers have the right to be informed on the content of the foods and drinks that they consume, including alcoholic beverages. The information allows them to better monitor their diet and adopt healthier habits if they wish, and to be aware of potentially problematic substances. List of ingredients and nutrition declaration on labels Providing the information on label is vital as most consumers “never or rarely” use off-label information sources to access information on nutrition values and ingredients of alcoholic beverages, as stated in the European Commission’s report on alcohol labels from 2017. The industry’s self-regulatory proposal to provide information online is therefore not sufficient, especially taking into account the digital divide which still remains to be bridged. Mandatory declaration for all alcoholic beverages AIM encourages the European Commission to review its Regulation 1169/2011 on the provision of food information to consumers so as to require: a mandatory nutrition declaration also for alcoholic beverages containing more than 1,2 % by volume of alcohol and the provision of information on the bottles in form of labels. Requirements should be the same for all types of alcohol (wine beer and spirits). Labels should also include health warnings, including (but not limited to) those targeting vulnerable groups (e.g. pregnant women and children).
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Health mutuals demand transparency to reduce high medicine costs

27 Apr 2021
Topic — The consultation reviews EU rules to ensure affordable medicines and supply security.
Message — AIM proposes creating an expert group to calculate fair price ranges for key medicines. They demand disclosure of public funding amounts and stricter rules for revoking market exclusivity.12
Why — Publicly sharing pricing elements would strengthen the negotiation power of health insurance funds.3
Impact — Pharmaceutical companies would lose high-profit margins and intellectual property protections for certain medicines.4
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Response to Social Economy Action Plan

26 Apr 2021

The European Commissioner for Jobs and Social Rights, Nicolas Schmit, announced in the communication for a “Strong Social Europe for Just Transitions” from 14 January 2020 that the European Commission will propose an Action Plan for the Social Economy in the fourth quarter of 2021 “(…) to enhance social investment, support social economy actors and social enterprises to start-up, scale-up, innovate and create jobs”. The ongoing Covid-19 crisis and its serious consequences has definitively shown, how important social economy enterprises with its main players associations, foundations, mutual benefit societies and cooperatives are. Suddenly, health, resilience and solidarity moved into the focus of policy making. Solidarity is the most important core value of mutual benefit societies. In the healthcare sector, they contribute to good, affordable, and universally accessible health care for all in the countries in which they operate. And, if there is one thing that the COVID-19 crisis is teaching us, is that good healthcare is an important pillar of a social society and of a social Europe. Mutual benefit societies contribute to the improvement of social policy and environmental topics. They play a role as ‘social movement’, based on a democratic participation of their members. They promote a democratic and social model by setting the example: their members are fully integrated in the governance of the mutual. As non-profit actors, they play a key role, often on behalf of public authorities, in providing innovative social services of general such as healthcare as well as general care services. They strive for an ambitious role in the debates on the implementation of the European Pillar of Social Rights, the UN sustainable development goals and the European Health Union. AIM, the international and European umbrella organisation of mutual benefit societies is therefore grateful to give feedback on the Commission proposal for a Social Economy Action Plan. AIM recommendations: 1. Promote mutuals as one of the main actors to implement the principles of the Pillar of Social rights by e.g. offering health- and long-term care services at a high quality and by guaranteeing access to these services for all at an affordable price. 2. Improve equal access to the Single market for the social economy including mutual benefit in the Single Market 3. Add a protocol on the diversity of forms of enterprises in the EU as an annex to the TFEU, including the social economy actors and their different legal forms such as mutual benefit societies. 4. Enhanced cooperation could be an option for Member States who are willing to have legal recognition for mutuals. 5. Develop an international Social Economy Action Plan to boost mutual benefit societies at global level as important actors for the implementation of the SDGs.
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Meeting with Astrid Dentler (Cabinet of Vice-President Dubravka Šuica)

19 Apr 2021 · Discussion on Green Paper on Ageing

Response to European Health Emergency Response Authority

24 Feb 2021

The pandemic has shown that “more Europe” is an opportunity. However, the prerequisite is that real solidarity between the states and their people is actually put into practice and not only vocalized. The EU with its institutions must succeed in communicating real joint action and its benefits to all European citizens. The EU should become proactive regarding the management of European global public health risks. Protecting citizens, including preparedness for epidemics is one of the major objectives of the current EU health policy and should be read in conjunction with other health-related legal basis, such as disaster protection (Article 195 TFEU). Health crises like Covid-19 are global in nature and require collaboration. This has been proven by various examples such as the help provided by the German state of Baden-Wuerttemberg to patients from Alsace in France. Such a collaboration and collective action can only work if certain powers are transferred to European level while respecting national competences. At the same time, it should be accompanied with local knowledge related to the management of health systems. There is a clear case for a stronger EU health policy that can ensure cooperative policy solutions across Member States. II. Proposals 1. A stronger EU health policy with regards to preparedness for epidemics is necessary in collaboration with the EU Member States Whether a stronger EU global public health policy with regards to preparedness for epidemics should be tackled by an “end-to-end-authority”, which takes a leading role among the EU agencies and acts as a unique principal coordinator and unique decision maker as suggested in policy option number 3 is questionable. For the moment, there is still not much hindsight on how the EU coped with the COVID-19 pandemic and it is still not possible to draw all the knowledge and experience from the pandemic. Even though a stronger cooperation at EU level is necessary, Member States have knowledge about their regions and their health system. Europe should especially act as a power, where the various member states are “powerless” compared to other major powers, such as multinationals. But it should also be possible that the outbreak of pandemics can be dealt with very quickly at local level, if necessary. It is therefore important to find a good balance between a European and a local approach. Therefore, an operational authority (and infrastructural authority) with participation of European Commission, industry-led associations and Member States as well as small and medium-sized enterprises, research organizations, academic and corporate members seems to be more worth a discussion (policy option 2, notably option 2.2). 2. The relationship to existing authorities and other EU mechanisms should be clarified With regards to already existing institutions like the European Centre for Disease Prevention and Control (ECDC), which plays a crucial role in identifying, assessing, and communicating threats to health from communicable diseases and the WHO, which coordinates the implementation, the relationship and tasks should be clarified. The collaboration with the World Health Organization and the research of synergies with the World Health Organization could feature more highly in the plan. 3. The EU should develop a) EU scenario book for pandemics should be developed describing competences and tasks of European/International institutions b) A mapping of national pandemic measures is necessary c) Affordability and availability of medicinal products d) A new tertium genus: Guidelines between existing recommendations and binding acts 4. Role of Member States: Resilience of healthcare systems as a political priority in the European Semester See more of our proposals in the paper attached.
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Response to Evaluation of patient rights in cross-border healthcare

11 Feb 2021

The not-for-profit health insurance funds and health mutuals of AIM have been deeply involved in the legislative process of the cross-border healthcare directive and in its implementation. They cooperate with their European neighbours when it comes to reimbursement of cross border healthcare. The pandemic has shown the crucial added value of the cooperation between hospitals and health professionals between EU countries, in particular at cross-border level (e.g. Germany and France). That has proven the importance of cross-border cooperation in healthcare and the need to maintain EU internal borders “open” during the crisis, to ensure access to health to cross-border populations. The legal framework on cross border healthcare is very complex because of different legislation at national and at European level. Not-for-profit health insurance funds and health mutuals are involved in numerous projects at national and euregional level, which serve to facilitate cross-border health care with the neighbouring countries in terms of patient and health professional mobility and cooperation with/between hospitals (e.g. ZOAST , GeKo SaarMoselle). In addition, contracts with hospitals in the neighbouring countries were concluded (e.g. in Belgium and the Netherlands). Nevertheless, health mutuals in charge of compulsory health insurance, have always favoured the application of Regulation 883/2004 in the context of cross-border healthcare because it provides the maximum price security for the patient, this should still be the case in the future. Crossing the border to access healthcare might be necessary for some patients (e.g. patients with ultra-rare diseases). AIM members point out that, especially for these patients but also for others, digitalisation will facilitate treatments by allowing patients to benefit from knowledge abroad without having them to travel. The expertise is centralised, and the treatment is as nearby and local as possible. However, this does bring on new challenges in reimbursement and the need to regulate telehealth and its reimbursement. With this paper, we point out some obstacles that still exist today: II. Recommendations 1. Access to cross-border healthcare can’t be seen separately anymore from telemedicine. We need regulation and the creation of a level playing field in Europe on providing digital consultations in which the digital provision of services by healthcare professionals should be bound to tariffication (and quality) of the country of a patient (not the location of the healthcare professional). 2. Pro-actively informing patients should consider the following: Healthcare professionals should inform patients in advance whether care takes place within a public or private healthcare facility/ context. Healthcare professionals should always provide patients from another member state with a cost-estimation before they cross the border to access healthcare. 3. Collaboration between public health bodies, healthcare providers and health insurance funds and their members is necessary to identify hurdles and develop solutions. 4. There is a need to secure that health insurance funds and health mutuals are more inclined to use the regulation and if not possible to get a minimum of reimbursement for the affiliates in private health hospitals using the Directive. 5. There is a need for comparable data based on international standards to help Member States to identify the national care needs. 6. There is a need to simplify the legal framework for patients and for professionals. 7. Information to patients needs to be continued and patients are advised to pro-actively consult and engage with their mutual/health insurance fund to examine their cross-border mobility. III. Main obstacles 1. Reimbursement of cross-border healthcare • Patients do not know about their reimbursement rights. • When going cross-border, there are sometimes substantial out-of-pocket expenses, patients find the administrative procedur
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Response to A European Health Data Space

3 Feb 2021

The health insurance funds and not-for-profit health insurers of AIM agree with the huge potential that a flexible use of health data has for patient centeredness as well as improving healthcare quality and outcome. A closer cooperation in the use of health data shall aim to improve patient’s access to healthcare and allow to predict the costs of the treatments (the amount to pay and the part reimbursed by the health system) more easily. The use of real-world data can drive research, cost-effectiveness analysis, treatment, and care, identify inefficient spending and empower patients through access to their own data and records. The outbreak of COVID-19 has made clear that access to health data, notably real-world data, for scientific research and a coordinated interpretation is of utmost importance. AIM members have the task of maintaining, restoring or improving the health of its insured persons. To be able to fulfil these tasks, they collect, process, store and use health and social data from their insured. These claims data, a form of administrative data, primarily collected for billing and reimbursement purposes, have the comprehensive potential for both, rational allocation of resources and for health services research to optimize healthcare provisions. Therefore, AIM welcomes the current and upcoming initiatives of the European Commission. The following recommendations focus mainly on billing data and contain proposals about which criteria should be followed in the collection, organization and sharing of health data . Read our full answer in our paper.
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Response to Setting of nutrient profiles

3 Feb 2021

AIM sees great potential in the Roadmap of the EC on the Revision of Information provided to Consumers. We welcome the initiative as we are convinced of the importance of properly informing consumers in order to empower them to make the right choice for their health and the environment. If the correct scenarios are chosen, the proposed measures would also encourage companies to produce healthier products in a more environmental-friendly way and thus allow both to reduce the impact of food systems on the environment and to improve public health, by contributing to tackle non-communicable diseases. Implementing the base-line scenarios would on the other side constitute a missed opportunity and an obstacle to reaching the high ambitions set by the European Commission in its Farm to Fork Strategy and its EU Green Deal. The enclosed document highlights the scenarios AIM recommends the European Commission to follow and the reasons supporting those recommendations.
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AIM calls for transparency and fair pricing in rare medicines

5 Jan 2021
Topic — The EU is revising legislation for medicines treating rare diseases and children.
Message — AIM demands reinforcing investment criteria to ensure medicines have fair compensation models. They seek yearly reporting to stop companies turning treatments into an overprofiteering opportunity. The group also advocates for transparency regarding the underlying costs of drug development.123
Why — Fairer pricing models would reduce the financial burden on health insurance funds.45
Impact — Drug manufacturers would face stricter monitoring and potential limits on their market exclusivity.67
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Response to Green Paper on Ageing

14 Dec 2020

AIM welcomes the roadmap published by the European Commission for the Green Paper on Healthy Ageing and looks forward to taking part to the upcoming consultation. The challenges entailed by demographic change, digitalisation and climate change are to be tackled together. The roadmap rightly mentions that demographic change is one of the mega-trends which are transforming European societies, the others being climate change and digitalisation. AIM believes none of these trends can be dealt with separately and that they should all be taken into account when working towards solutions to face future challenges. To cite but a few examples: climate change has an impact on the health of older generations but also on the types of jobs available in the labour market and thus on the life-long training to be made available to all; digitalisation has the potential to alleviate some types of heavy works enabling individuals to work for longer but it also entails risks and requires the digital skills of all, including older people, to be improved; etc. We encourage the European Commission to establish clear links between these three mega-trends and to take digitalisation and climate change into account in the upcoming proposals of its Green Paper. “Beyond purely economic issues” AIM welcomes that the European Commission announces that “the Green Paper could go beyond purely economic issues”. AIM is convinced that the Paper should have a strong social and health related focus. AIM calls on the European Commission to adopt the positive health model and a health in all policies approach in its Green Paper, breaking silos and encouraging cross-sectorial collaboration. The measures proposed should on the one hand contribute to empower individuals to stay healthy for longer and continue contributing actively to society. On the other hand, it should act on their environment by improving the quality an access to health and long-term care services, by creating age-friendly environments (including workplaces), by tackling risk factors to chronic diseases and creating environments which promote healthy lifestyles, by acting at societal level, redefining intergenerational solidarity and fighting stigma against old age. Our concrete recommendations can be found in attachment.
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Response to EU Strategic Framework on Health and Safety at Work [2021-2027]

25 Nov 2020

AIM welcomes the comprehensive roadmap published by the European Commission and underlines the importance of the attached series of key elements to ensure that the upcoming strategy is fit for purpose.
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Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen)

12 Oct 2020 · Mutual Benefit Societies in Latin American partner countries

Meeting with Karolina Herbout-Borczak (Cabinet of Commissioner Stella Kyriakides)

23 Sept 2020 · Meeting on the upcoming Pharmaceutical Strategy.

Meeting with Astrid Dentler (Cabinet of Vice-President Dubravka Šuica)

8 Sept 2020 · Green Paper on Ageing

Meeting with Anouk Faber (Cabinet of Commissioner Nicolas Schmit), Santina Bertulessi (Cabinet of Commissioner Nicolas Schmit)

8 Jul 2020 · Social Economy

International health mutuals urge fair pricing for affordable European medicines

7 Jul 2020
Topic — Consultation on ensuring Europe’s supply of safe and affordable medicines to meet patients’ needs.
Message — AIM proposes a pricing model for innovative drugs based on research and production costs. They also want public funding contracts to include strict affordability and transparency clauses.12
Why — This approach would reduce the financial pressure on national healthcare budgets and insurers.3
Impact — Pharmaceutical corporations would see reduced profits and lose special market exclusivity for certain drugs.4
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

3 Jul 2020 · AI in healthcare, health insurance (adequate legal framework, engine for healthcare modernisation + back office). Standards to govern safety, medical professionals to govern treatment. Standardisation issues. Health data spaces.

Meeting with Anne Bucher (Director-General Health and Food Safety)

25 Jun 2020 · discussion on AIM's European model for fair and transparent pharmaceuticals prices

Response to Chemicals strategy for sustainability

19 Jun 2020

Healthier citizens on a healthier planet as the guiding principle for an EU Chemical Strategy AIM, the leading international umbrella organisation of health mutuals and not-for-profit healthcare payers, welcomes the intentions described in the European Commission’s Roadmap on a chemical strategy for sustainability. The Strategy constitutes a key step towards the zero-pollution ambition for a toxic-free environment. AIM underlines that the ultimate objective of the strategy should be the achievement of higher levels of protection of human health and the environment and that these should not be bypassed for the sake of competitiveness. Achieve a more thorough control of chemicals. As the roadmap states, chemical consumption is expected to double by 2030. Eurostat data shows that two thirds of the chemicals produced in the EU are hazardous to health. It is therefore vital for the strategy to phase out the most hazardous substances and reach a more protective production, use and recycling for a safer circular economy. In the same vein, it is key to achieve high levels of protection for hazardous chemicals in imports. Produce Safer Chemicals. Encouraging and investing in innovation should above all mean properly stimulating the production of safe substitutes for chemicals of concern by using of economic incentives. Better implementation of existing regulation (e.g. REACH) would also ensure that innovation is at the service of public health. Limit exposure to endocrine disruptors and other chemicals of high concern. Policy action should aim to limit exposure to major groups of chemicals, starting with endocrine disruptors, PFAs, flame retardants and hazardous pesticides. Those chemicals require urgent action as their negative impact on citizens’ health has been demonstrated. By 2030 all hazardous chemicals should be removed from consumer products and food packaging. The strategy should also address gaps in chemicals-related legislation and intend to achieve a better identification of endocrine disruptors across regulations. Cautious on the relocation of chemicals back to Europe The relocation of some of the production of chemicals used in pharmaceuticals (e.g) in Europe has been considered by many as a solution to facilitate the transparency of the sourcing chain, increase production capacity as well as support the strategic independence of Europe. However, relocation decisions still remain the sole responsibility of companies themselves. A clear, well thought-out plan, looking into issues such as what kind of medicines we need to relocate, the needs at European level, and the costs of the incentives needed to reshore production, is a prerequisite, should the European Commission wish to go down this path. Consultation of stakeholders will of course be needed all across this process. Follow the precautionary approach. The process of “one substance – one assessment” proposed by the European Commission should not lead to lower levels of protection. Assessments should be based on sound scientific evidence and the precautionary principle should be applied in case of any uncertainty. The principle should not be used as an excuse to bypass or hasten existing regulation. On top of the concerns listed above, AIM hopes that the European Commission will also seek to eliminate chemical pollution in air, water and soil and to avoid the reuse of materials containing toxic chemicals. If those objectives are not included in the Chemicals Strategy, they should be part of the Commission’s zero pollution Action Plan. AIM’s answer endorses the briefing of the Health and Environment Alliance, of which it is a member: https://www.env-health.org/issues/toxic-chemicals/#briefings
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Response to Farm to Fork Strategy

16 Mar 2020

AIM, the leading international association of healthcare funds and mutuals, welcomes the initiative to launch a Farm to Fork Strategy as part of the European Green deal. We agree that the strategy is key in the implementation of the Sustainable Development Goals and hope that the European Commission (EC) will keep that objective in mind when developing it. AIM calls on the EC to put public health at the centre of its strategy. AIM believes the intentions described in the roadmap reflect the need for a holistic approach. The strategy should aim to achieve a more sustainable production of high quality food, with a smaller environmental footprint. It should look at the way food is processed while limiting the use of antibiotics and ensuring proper labelling and packaging. The EC should also contribute to raise awareness for healthier and more sustainable consumption. We call for an improvement of food quality and a ban on the use of pesticides with a negative impact on health. The strategy should be rooted on the promotion of a sustainable production of high-quality foods. To achieve it, the Common Agricultural Policy will be key in supporting farmers to shift to healthier and more sustainable farming practices while limiting the stress and financial burden such a shift can cause, and in developing innovative solutions. When it comes to those practices, AIM calls for the ban of pesticides or other chemicals that have a negative impact on consumers’ or farmers’ health. We call on the European Commission to establish clear limits of the amount of added-sugar or salt in the processing of food. The consumption of foods with high contents of sugar or salt has proven to have a negative impact on health. It is linked to diseases such as obesity or diabetes, to cite but a few. The EU has a clear role to ensure that the food which reaches citizens’ plates does not contain levels of salt or sugar that would have a harmful effect on their health. We call on the EU to adopt a more protective EU food contact material legislation. Chemicals used in packing can cause cancer, disrupt hormones, affect DNA or persist in the environment. Most materials currently used for food packaging are not covered by the current regulation and numerous chemicals harmful to human health are overlooked. AIM believes it is time that the EU reviews its food contact material legislation in order to guarantee a high level of protection of human health. We call on the EC to adopt a uniform proposal of labelling of food products. In order to properly monitor their diet, consumers should be provided with comprehensive and non-misleading information concerning the food and drinks they consume. Such information should include ingredients, nutritional value and environmental footprint and appear on label. We call on the EC to adopt the necessary measures to limit the exposure of children and adolescents to the marketing of unhealthy food. Marketing affects behaviours. Vulnerable groups, such as children or adolescents are particularly at risk of being negatively influenced. AIM is convinced that the EU has a clear role to play, for instance, in restricting the online marketing of unhealthy products and thus in limiting the exposure of those groups. The Strategy should support a much needed dietary shift. Current consumption patterns are far from healthy and sustainable. Europeans should be nudged to make healthier choices with a lesser impact on the environment: consuming more fruits and vegetables, less processed food and meat, for example. The Farm to Fork Strategy should contribute to ensure that production meets those wished consumption habits; that healthier foods are accessible and promoted over unhealthy options (marketing, healthier food in canteens, etc.); and that citizens are empowered to make the right choices both for their health and planet.
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Response to Europe’s Beating Cancer Plan

3 Mar 2020

AIM, the leading international association of healthcare funds and mutuals, welcomes the focus and intentions described in the European Commission’s roadmap. We call for a reallocation of healthcare budgets, so as to better finance prevention. A more efficient spending of the healthcare budget is necessary to improve prevention. More resources can also be raised through (higher) taxation of unhealthy products such as tobacco, alcohol or food high in salt, trans- fats and sugar. Prevention should be understood from a health in all policies point of view. When talking about prevention, the environment, in the broad sense of the term, is determinant. Health promotion, in the sense of positive health, should become the focus of all European and national policies. Some important concrete measures are not mentioned in the roadmap. AIM would like to underline that taxation of HFSS foods should also be implemented as an effective measure. We stress the importance of health literacy and information to consumers. The prevention of cancer at workplaces should also be a priority of the plan. We call for evidence-based indications to be used as basis of any screening programme. AIM believes existing EU-provisions on screening should be updated and their remit expanded to other types of cancers and NCDs, only if those provisions are evidence-based and the benefits outweigh the harms by scientifically proven effectiveness and a positive risk-benefit-ratio. Act now: Knowledge gaps should be filled but should not be used as an excuse to postpone action. A lot of research has indeed already been done. If the effect of a product or behaviour on health is negative, action should be taken. On the other hand, research should focus on preventive measures themselves and on how to successfully implement them. AIM calls for fairer prices for cancer treatment. The EU has a role to help with setting high standards for the assessment of the therapeutic added value of all medicines, including cancer medicines, while giving room for adaptation to national contexts. Robust action at national and European level is also needed to address the rising cost of drug prices. Enhanced health literacy should become a priority in the fight against health inequities. Promoting health literacy at schools can help overcome health inequities. Digital tools have a clear potential to achieve more efficient prevention and treatments. However, they also carry the risk of reinforcing health inequities. We call on the European Commission to pay attention to bridge the digital divide both by working on infrastructures and on populations’ digital health literacy. We subscribe to the call for more integrated care for patient and for increased teamwork with other sectors. New and better integrated models of care and a consequent update in healthcare professionals’ skills are necessary. Enhanced support should be made available to informal carers. We underline the importance of the mutual model in the fight against discrimination in access to social protection. When it comes to healthcare, some complementary insurances might exclude cancer survivors from coverage. AIM members, as healthcare mutuals, are based on the value of solidarity and do not exclude on basis of e.g. health status. AIM believes that the mutual model should be recognised as a best practice, properly supported and further developed. AIM also calls on other sectors to reflect on the issue and rethink insurance on basis of non-discrimination. Beating Cancer requires bold action at European level. A lot can be done at EU level to address health determinants e.g. when it comes to cross-border marketing, environmental issues, taxation etc. By regulating the internal market, the EU can have a clear impact on risk factors and thus on the health of EU citizens. We hope that the “European Beating Cancer Plan” will be ambitious enough to beat the growing scourge. See our full statement enclosed.
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Meeting with Astrid Dentler (Cabinet of Vice-President Dubravka Šuica)

20 Feb 2020 · Green Paper on Ageing, healthy ageing, long-term care, digital literacy of the elderly

Meeting with Eugenia Dumitriu-Segnana (Cabinet of Commissioner Nicolas Schmit)

20 Feb 2020 · Social Security Coordination

Meeting with Vytenis Andriukaitis (Commissioner) and

26 Nov 2018 · Future of EU health policy

Response to Establishing a legal limit for the industrial trans fats content in foods

29 Oct 2018

AIM welcomes the European Commission’s draft Regulation amending Annex III to Regulation (EC) No 1925/2006 as regards trans fat, other than trans fat naturally occurring in animal fat, in foods intended for the final consumer. As healthcare mutuals and health insurance funds, AIM members have a mission of general interest. We are to protect the health of European citizens while at the same time ensuring the economic sustainability of healthcare systems. Scientific evidence shows that TFAs uptake is harmful to health as it increases “bad cholesterol” and, consequently, the risk of coronary heart disease. The divergence in levels of TFAs intakes across the EU and across population sub-groups speaks, in our opinion, for the added value of an EU-wide action. As stated in our January 2018 position paper, we support the establishment of a limit to the presence of industrial trans fats in both pre-packed and non-pre-packed food by means of legally-binding measures. We therefore welcome the European Commission proposal to establish a limit of 2 grams per 100 grams of fat. However, we believe that allowing food which does not comply with the regulation to be placed on the market until 1 April 2021 would unnecessarily expose EU citizens to lower quality products for longer. We believe that the transition period should be shorted to one year maximum. We also believe that the European Commission should introduce the obligation to indicate trans fats contents in foods on labels in a clear, transparent and understandable way. We would encourage the European Commission to establish a consumer-friendly scheme (such as the so-called “traffic light” system), which would help consumers easily understand when levels of TFAs are unhealthy in a certain product and to which extent. Of course, such a scheme should be comprehensive and take other aspects into account (such as salt or sugar content).
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Meeting with Vytenis Andriukaitis (Commissioner) and

27 Apr 2018 · HTA

Meeting with Ruth Paserman (Cabinet of Commissioner Marianne Thyssen)

24 Nov 2016 · Pillar of Social rights

Meeting with Inge Bernaerts (Cabinet of Commissioner Marianne Thyssen)

11 May 2015 · Social enterpreneurship; the role of mutuals