EuroHealthNet
EHNet
EuroHealthNet is a not-for-profit partnership working on public health, disease prevention, health promotion, and reducing health inequalities within and between European states.
Lobbying Activity
EuroHealthNet urges health equity focus in EU competitiveness fund
11 Nov 2025
Message — The organization requests keeping EU4Health standalone while embedding health-equity safeguards into the fund. They advocate for a "Do-No-Harm-to-Health" rule and reporting that shows social impacts. Grants should remain the primary funding instrument for essential public health services.123
Why — These measures ensure that capital investments translate into service access and prevention.4
Impact — Manufacturers of health-harming products would face restricted access to grants and advisory roles.5
EuroHealthNet urges EU to prioritize health equity in next budget
2 Nov 2025
Message — EuroHealthNet requests embedding health equity as a design requirement in national plans. They also seek to link payments to prevention results like reduced avoidable hospitalizations.12
Why — These proposals would ensure long-term financial support and institutional recognition for public health networks.34
Meeting with Olivér Várhelyi (Commissioner) and
2 Oct 2025 · All pressing portfolio topics
Response to Gender Equality Strategy 2026-2030
11 Aug 2025
EuroHealthNet applauds the European Commission and welcomes the opportunity to shape the forthcoming EU Gender Equality Strategy 20262030. As the European partnership for health, equity and wellbeing, uniting public health authorities, research institutes and civil society, we recommend the following priority outcomes for women, men and all genders; fuller proposals are in the attached document. Priority outcomes for 20262030 (across all domains of life) 1. Increase healthy life years for women and men by improving social, economic, environmental and digital determinants: quality, secure work and fair pay/pensions; affordable childcare and long-term care; decent housing and transport; safe green spaces; digital inclusion; freedom from violence; and participation. Address womens gaps (multimorbidity, care penalties, VAWG/DV) and mens gaps (premature mortality, mental health, occupational risks). 2. Reduce poverty, material deprivation and gender gaps in participation and protection across life stages. Raise labour-market participation and skills (especially STEM/digital), close pay and pension gaps, strengthen adequate minimum income and social protection, and ensure online/offline safety. 3. Make the digital and green transitions inclusive and gender-responsive. Guarantee affordable connectivity and skills, audit algorithms for bias and safety, and ensure climate change adaptation/mitigation measures benefit households equitably. 4. Health-specific outcomes via achieving Gender Equality a. Reduce access gaps in prevention, diagnosis, treatment and follow-up by income, geography, disability, migration status and age for women and men, including gender-diverse people. Scale low-threshold, community-based services; rural-proof delivery; and pair digital tools with human support and accessibility-by-design. b. Fix the data-to-policy and action pipeline. Require sex/gender/age-disaggregated and intersectional variables (incl. disability, migrant and carer status, and gender identity where law enables) across surveillance and the EHDS; implement SGBA in EU-funded research, HTAs and AI tools; prioritise under-researched needs (e.g., endometriosis, (peri)menopause, chronic pain, long COVID, womens and mens mental health). c. Embed gender-sensitive, trauma-informed care pathways in primary and community care (diabetes, CVD, cancer, depression/anxiety, chronic pain, dementia, perinatal mental health), and strengthen health-system prevention/response to VAWG/DV. d. Value and redistribute care. Improve pay, safe staffing, training and psychosocial protection for the predominantly female care workforce; design family leaves and flexible work for mens uptake; recognise informal carers and introduce portable care credits. 5. EU delivery, finance and metrics a. Align the next Multiannual Financial Framework (post-2027) and a proposed EU Competitiveness Fund with gender-equality and health-equity outcomes; include social/public-health investment windows and outcome-based budgeting. b. Mobilise EU4Health, ESF+, ERDF/cohesion, Horizon Europe, Digital Europe/EHDS, Social Climate Fund, RRF/TSI and InvestEU under the next MFF for health promotion/disease prevention, workforce, community infrastructure and digital inclusion; enable civil-society co-delivery and funding. c. Ensure coherence with the new EU Anti-Poverty Strategy, the EU Civil Society Strategy, EPSR action plan, and the EU CVD Action Plan. Publish annual dashboards disaggregated by sex, gender, age and intersectional variables, linked to the European Semester/CSRs and the EPSR Social Scoreboard tracking healthy life years; access (coverage, waits) and affordability (OOP); continuity; digital safety/use; workforce stability; VAWG/DV response. Outcome: a Strategy that moves from parity of access to equity of outcomes delivering measurable gains in well-being and real-world access to high-quality prevention and care across the life course for women, men and all genders.
Read full responseEuroHealthNet urges EU to improve healthcare access for LGBTI+ people
20 Jun 2025
Message — The group calls for improved resources and training for professionals who often overlook LGBTI health. They also seek better access to trans-specific care adapted to unique identity needs.12
Why — This would enable their partner organizations to provide proper support and improve outcomes.3
Meeting with Anna Strolenberg (Member of the European Parliament)
5 Mar 2025 · Sustainable and healthy foods
Meeting with Christine Singer (Member of the European Parliament)
20 Feb 2025 · ultra-processed food
Meeting with Kristian Vigenin (Member of the European Parliament)
2 Oct 2024 · Health inequalities across Europe
Meeting with Vytenis Povilas Andriukaitis (Member of the European Parliament)
2 Sept 2024 · Health policy
Response to Review of the Health Emergency Preparedness and Response Authority (HERA)
19 Feb 2024
In summary, in EuroHealthNet's opinion HERA needs to: 1. Strengthen capacities of national public health systems, including protection, prevention and health promotion; 2. Not be too narrow-focused and include broader, non-medical, more psychosocial countermeasures and approaches as part of its preparedness framework; and 3. Operate with high levels of transparency, clearly involve civil society organisations and implementing bodies such as public health institutes. (1) Stressing the fact that public health systems are underfunded in all countries, this means that Member States' public health authorities and systems cannot adequately contribute to or even benefit from the activities of HERA. If HERA wants to be effective, it should design measures to strengthen public health systems in Member States. It needs to help build the national and regional capacities for protection, disease prevention and health promotion - which are all part of future crisis preparedness, including boosting competencies for modelling and foresight analysis. Building such capacities requires strong cooperation with national institutes of public health (NIPHs) as well as through financial means to strengthen their activities. Currently, investments in public health capacities are sub-optimal, as most funds go to hospital and medical infrastructures. The EU can facilitate this process, through HERA, building on the existing expertise in countries, consulting with local authorities in planning and design, and with support of other bodies such as the WHO. (2) Furthermore, HERA's mandate of work/Terms of References is too focused on medical counter-measures, thereby missing other crisis preparedness elements. What we recommend for HERA is to: a. better coordinate communication campaigns related to the prevention and response to health emergencies. This certainly is challenging within the new media landscape and within increasingly connected yet divided societies. Taking note of the digital transition, it also means that information and digital solutions must be easy to access, understand and apply, at varying literacy levels b. enable and link up with the ongoing establishment of behavioural and cultural insights units at Member State level, to collect data on the key barriers and enablers to crisis management and to feed such information into decision-making processes. In some Member States such units proved to be very useful during the COVID-19 pandemic, climate emergency events, gathering intelligence on public acceptance and behaviour, and to improve on the effectiveness of solutions c. synergise responses related to physical health threats with mental health consequences of the crises or emergency. There is no preparedness and crisis management without mental health and psychosocial wellbeing. HERA should include this in its framework and provide a truly coordinated and comprehensive approach that encounters for physical and mental wellbeing of the affected populations and people with lived experience. This also requires cooperation with other sectors, such as social sector and long-term care sector. d. monitor impacts on vulnerable groups, across the socio-economic gradient, including collecting disaggregated data, but also conducting separate studies, as often surveys do not sufficiently reach specific groups, such as young people, people with vocational backgrounds, or people with migration backgrounds. Specific strategies are needed to get their voices heard. HERA needs to do that and ensure equitable responses to crisis and be vigilant not to widen inequalities in our societies not only in the short-term, during the crisis, but also for the long term, to see impacts of counter-measures and 'justify' a case for social return on investments. (3) Simplify HERA's setup. Its flexibility is appreciated, but the transparent involvement of CSOs and a much broader approach to what constitutes a crisis and an emergency should be applied.
Read full responseResponse to ESF+ mid-term evaluation
8 Feb 2024
EuroHealthNet welcomes the opportunity to provide input toward the mid-term evaluation of the European Social Fund Plus (ESF+). In our contribution, we will provide evidence on what works and what does not, feeding to the European Commissions assessment of the effectiveness, efficiency, relevance, coherence and EU added value of the ESF+. EuroHealthNet welcomes that the content of ESF+ is based on the European Pillar of Social Rights (EPSR) and contributes to supporting social and health rights in all EU Member States. We very much supports the decision that EU Member States with an average of EU child poverty higher than the EU average now have to allocate at least 5% of their ESF+ financial resources to tackle child poverty and that all EU Member States are called to allocate ESF+ financial resources to targeted actions to combat child poverty. We underscore the effectiveness, efficiency, relevance, coherence and EU added value of the ESF+ by highlighting its benefits for public health by: - Addressing social determinants of health through integrated approaches and contributing to inclusive social policies across the EU - Targeting health initiatives for vulnerable populations and communities with higher health and social needs - Building individual capacity and skills, and social capital - Community empowerment - Collaboration and partnership - Measurable impacts and evaluation While the ESF+ plays a crucial role in reducing health inequalities and promoting health, equity and wellbeing, there are challenges that need to be addressed, such as: - Fragmentation and coordination - Monitoring and evaluation gaps - Administrative simplification needed - Resource allocation and flexibility in responding to emerging health, equity and wellbeing challenges - Sufficient co-funding rates Please find a more detailed explanation of our feedback in the attached file.
Read full responseMeeting with Maria Luisa Llano Cardenal (Cabinet of Vice-President Margaritis Schinas)
14 Mar 2023 · Eu action on Mental Health
Meeting with Daphne Von Buxhoeveden (Cabinet of Commissioner Stella Kyriakides)
14 Mar 2023 · VTC meeting on mental health
Response to Key performance indicators for the Digital Decade policy programme 2030
13 Mar 2023
Please find feedback enclosed.
Read full responseEuroHealthNet urges full alignment with WHO air quality guidelines
9 Mar 2023
Message — EuroHealthNet calls for full alignment with WHO guidelines and legally binding obligations. They advocate for targeted support for vulnerable groups and socioeconomically disadvantaged areas.123
Why — This would lower long-term health expenditures and reduce socio-economic health inequalities.4
Impact — Member States lose the flexibility to set voluntary national air quality reduction targets.5
EuroHealthNet Urges Ambitious EU-Wide Strategy for Mental Health
15 Feb 2023
Response to European Year of Skills 2023
14 Dec 2022
Major trends such as demographic changes and the rising prevalence of non-communicable diseases have created pressures on health and social systems, which were further exacerbated by the aftermath of the pandemic and the current geopolitical context. This polycrisis has spotlighted the need to build resilient health systems and explore the potential of the digital and green transition. More resilient health systems should also be more equitable health systems, which prioritise primary prevention and community-centred approaches to promoting health and wellbeing. Whilst acknowledging the complexity in transforming health systems, a key starting point to combat present challenges is addressing the urgent need for health workforce upskilling and reskilling. With the forthcoming EU Year of Skills, we have a critical window of opportunity to bring this urgent need into focus, forecast the skills needs in light of the digital and green transition, and ensure that such work promotes health equality. By way of example, it is essential that digital skills frameworks ensure appropriate use of digital tools and technologies and enhance digital health literacy, as digital tools may otherwise exacerbate the digital divide in health inequalities. Green skills should capture the critical impacts of environmental determinants of health, such as climate change, air pollution and the lack of access to green and blue spaces, in efforts to also reduce the health inequalities gap. Accompanying training in core skills including communication, cross-sectoral collaboration, and leadership is also essential to provide the wider health workforce with the appropriate tools to handle an evolving and increasingly interdisciplinary health ecosystem. As a partner of Blueprint alliance for a future health workforce strategy on digital and green skills (BeWell), funded under the Erasmus+ programme, EuroHealthNet is committed to promote increased opportunities for up- and reskilling the European health workforce for a more resilient future in health ecosystems at all levels - with health equity, health promotion and disease prevention at the core of our work. More information about the BeWell project here: https://bewell-project.eu/
Read full responseResponse to Mid-term evaluation of the Recovery and Resilience Facility (2020 – 2024)
6 Dec 2022
Please find EuroHealthNet's response attached.
Read full responseResponse to Improving the provision of digital skills in education and training
16 Sept 2022
EuroHealthNet welcomes the European Commission’s initiative to set up a strategic outlook to digital skills development and promote a high quality, inclusive, coherent and coordinated approach to the provision of digital skills for all.
On many occasions before, EuroHealthNet has systematically stressed the importance of digital literacy, for example, through consultations and publications regarding Digital Health Literacy, the European Health Data Space and EU Digital Targets 2030 as well as dedicated workshops and seminars (see useful links in the document attached). The digital transformation of our societies is happening at a fast pace, whilst being further accelerated by the course of the COVID-19 pandemic. To truly take advantage of the benefits of digital technologies, notably in the health sector, it is crucial that the digitisation process goes hand in hand with programmes that boost people’s digital literacy skills. This is certainly the case when considering the field of digital health .
Limited by the space available for this feedback, EuroHealthNet places its focus and input on four top priorities to guide the development of a long-term plan for Digital Skills.
1. Ensure strong equity principles in the provision of digital skills. EuroHealthNet welcomes the Roadmap which brings attention to the principle of inclusivity of digitalisation. We further recommend putting more emphasis on rights-based approaches and actions that should be implemented to ensure equity. This includes agreeing on specific objectives, addressing vulnerable and socially excluded groups and that budgetary allocations for this purpose are made.
2. Embed data literacy in digital skills programmes. Digital transformation will entail a widespread use of digital data. The successful enrolment of initiatives such as the European Health Data Space will imply a more frequent use of digital portfolios, electronic health records, and associated services. People will need to adapt their habits to benefit from such technologies. Improving data literacy across the population will therefore be fundamental to ensure the use of associated digital health technologies and their dissemination. It would allow people to better handle new digital technologies, but also to increase their understanding of the quality and suitability of apps (including mHealth apps), their marketing, what their data is being used for, how they can control it and other relevant issues. Improved data/digital health literacy would also increase trust in digital innovation in health, care, and related sectors.
3. Need for more disaggregated data. The future outlook should put forward further mechanisms to evaluate and monitor the level of digital (health) skills across the EU population. Data should be integrated with health-related specific indicators, namely, to measure, monitor and assess levels of digital health literacy and health data literacy across diverse population groups and health workforce. This would allow to set out quantifiable targets and develop tools to act in this sphere at EU level.
4. More ambitious targets: Although the Digital Targets 2030 and the European Skills Agenda 2025 already set out overall objectives to increase basic digital skills across the population (up to 80%), the new framework should put forward more realistic and defined targets, with specific ones for different groups (e.g.: per age, socioeconomic status, education levels, etc.). Specific targets regarding investments should also be clearly mentioned. The digital skills programmes should include specific goals for up- and re-skilling of health and social workforce to stimulate the development training and capacity building programmes for professionals. Public health and social care professionals should not be neglected in this process.
The European Year for Education, Skills and Training could offer an important opportunity set out such competitive and ambitious targets.
Read full responseEuroHealthNet Urges Digital Literacy Focus for Health Data Space
27 Jul 2022
Message — The organization calls for digital health literacy programs for citizens and professionals. They also seek clearer definitions for the secondary use of health data to ensure inclusivity.12
Why — Enhanced health surveillance capabilities would allow their member organizations to perform duties more efficiently.3
Impact — Tech companies lose operational flexibility under stricter requirements for data standardization and regulation.4
EuroHealthNet Urges Smoke-Free Rules for E-Cigarettes and Outdoors
15 Jul 2022
Message — The organization calls for the extension of the smoke-free environments legislation to cover e-cigarettes and HTPs. They advocate for the inclusion of well-defined outdoor spaces such as schools, playgrounds and outdoor terraces.12
Why — These measures would increase equitable public health protection and support a tobacco-free generation.34
Response to Proposal for a Council Recommendation on long-term care
29 Mar 2022
EuroHealthNet is a not-for-profit European partnership of organisations, agencies and statutory bodies working on public health, health promotion, disease prevention, and reducing inequalities. With a long-term commitment to health, equity, and wellbeing EuroHealthNet recognises the importance of integrated, enabling, people and communities-centered care settings that boost good health and wellbeing in early years, continuing well into older years with healthy and active ageing across European Member States.
People need to access quality services that provide care when they need it, how they need it and where they need it, and be able to afford it regardless their socio-economic status – and yet large inequalities in access to for example healthcare exist. Acknowledged as social rights (as per the European Pillar of Social Rights’ principles), a set of comprehensive care services spanning across domains has been considered for long by public health as key determinants of health. It is also what has defined the European Social Model to-date – access to affordable quality healthcare, early years development, education and care, housing, long-term care.
We recommend that the EU institutions’ strategic approach to care spans as a continuum along one’s life-course, ‘kicking off’ in early years by boosting children, adolescents and young people with skills and competences needed for future healthy lives. Further it would support families and working adults well into their older years enabling them to age healthy and actively would be a good vision to start with.
We applaud the proposal for the long-term care to include interventions on healthy and active ageing, as keeping people healthy, delaying their need for curative care and treatment will be good for society and communities. The proposed European Care Strategy fits well with a Wellbeing Economy model (also promoted by EuroHealthNet) where care is seen as an investment and where enabling and protective policy and intervention frameworks are central. The Wellbeing Economy model offers many potential entry points for valuing care and improving lives of European citizens.
As elaborated in detail in the attached contribution which represents a collated input towards all three parallel public consultations run by the European Commission, EuroHealthNet recommends that the European Care Strategy considers:
- Prevention-based approaches
- Person- and community-centered care and co-creation process
- Innovation for integrated approaches to provision of and governance for care
- Actions across the social gradient
- Improving access to and quality of care for children
- Reinforcing access to and investments in healthy and active ageing
- Strengthening primary care
- Addressing under-investments and public expenditures on care
- Gender equality and the informal carers
- Monitoring frameworks, and quality integrated statistics
EuroHealthNet, as part of the EU Alliance for Investing in Children, further contributed to two specific child-focused consultation response on the revision of the Barcelona targets, and the European Care Strategy.
Read full responseResponse to Recommendation on minimum income
29 Mar 2022
EuroHealthNet, a European not-for-profit partnership of organisations, agencies, and statutory bodies working on public health, disease prevention, promoting health, and reducing inequalities, welcomes the Commission’s proposal for a Council Recommendation on adequate minimum income schemes in the EU. With a long-term commitment to promoting health equity, we recognise the significant impact of financial and income arrangements on people’s health and wellbeing. Social protection programmes, including minimum income schemes, have been long linked with better health not just for those benefiting, but for the whole population.
EuroHealthNet commends the Commission’s efforts to target the root causes of poverty, inequality, and social exclusion via an integrated active inclusion approach and a set of policies designed to ensure that no one falls below a set income level. We hope these efforts will contribute to meeting the EU’s collective commitment to reduce the poverty figures by 15 million people by 2030. This must include actions with a particular focus on enabling, needs-based social services, including health. Since such proposals are less effective when applied in isolation, they must form a part of an EU-wide and national level contextualised structural and a systemic approach to poverty and economic vulnerability reduction. Wherever appropriate, we believe room for flexibility should be left to complement a minimum income scheme with a basic-like income measure extending it beyond more traditional social protection benefits.
Furthermore, EuroHealthNet recommends to (rationale and evidence included in the attached document):
• Take much stronger action to overcome structural challenges behind the introduction of the adequate minimum income schemes in the EU; address increasing in-work poverty and insecurities related to non-standard forms of employment
• Align the adequacy of the minimum income schemes to the real cost of living, with particular attention to people’s ability to afford healthy and sustainable living; address the structural underlying causes of health inequalities such as access to key services - housing, education, food, and energy security; promote a Minimum Income for Healthy Living (MIHL) concept
• Consider adding a public health objective and a social rights-based rationale for the introduction and assessing the adequacy of the minimum income schemes; implement a MIHL, guided by health (equity) impact assessments as part of the methodology for the setting of the schemes at national, regional, or local levels, as appropriate
• Integrate the enabling social services with access to health promotion and disease prevention interventions, with a focus on supporting people’s capability, skills, (digital) health literacy and competencies to choose and maintain healthy and sustainable lifestyles; expand the active inclusion services with psychosocial support, including for dependant members of the families of the minimum income schemes’ beneficiaries
• Measure access to minimum income schemes and access to integrated enabling services as part of activation measures, and when measuring impacts of the schemes on poverty reduction (as indicated in the revised Social Scoreboard) consider more qualitative measures of impacts on people’s health and wellbeing (self-perceived health, ability to afford a healthy living, etc.)
• Align the adequacy of minimum income schemes with the annual cycle of the European Semester and the assessment of the national Recovery and Resilience Plans’ implementation as a progress indicator towards reducing the number of people living in or – as seems more relevant - at risk of poverty and social exclusion (AROPE)
• Move the emphasis away from conditionalities, disqualifications and sanction based regimes to positive and assets-oriented narratives and self-motivation, and link it with other ongoing debates on poverty and inequalities, especially in the area of health
Read full responseResponse to Social and labour aspects of the climate transition
18 Nov 2021
EuroHealthNet is a not-for-profit partnership of organisations, agencies and statutory bodies working on public health, disease prevention, promoting health, and reducing inequalities. With a long-term commitment to promoting health equity in sustainable development, EuroHealthNet recognises the significant impact the climate crisis has on wellbeing and commends the effort to bring various instruments together to ensure a just and socially fair transition towards climate neutrality. EuroHealthNet therefore welcomes the published initiative to provide feedback on the Council Recommendation on addressing social and labour aspects of the just transition towards climate neutrality and would like to take the opportunity to provide insight into how to achieve social upward convergence as well as a green transition.
Whilst the transition to more sustainable measures substantially improves population-wide benefits, communities living in sub-optimal conditions tend to benefit least, or last, from initiatives to ‘green’ the economy. In fact, those who are socio-economically deprived are often negatively impacted in the transitional process, resulting in a loss or deteriorating quality of livelihoods and the inability to afford or access subsidies for cleaner alternatives. Therefore, a key challenge to achieving a just transition lies in the implementation of a “proportionally universal” green transition along a social gradient, to avoid widening the health inequalities gap and ensure that those with greatest needs benefit first and the most.
In light of the above, EuroHealthNet strongly recommends the following:
-Whilst the Council Recommendation has rightly noted the social co-benefits to achieving climate neutrality, we would like to further recommend the inclusion of health co-benefits to a green transition, to further strengthen public support in reaching the EU climate and energy targets.
- In addition to this, we feel that the transformation of sustainable food systems should be referred to more explicitly, to complement the recommendations made in the important areas of energy and mobility.
- Policy package (c) on designing fair tax-benefit and social protection systems should not only address the progressive taxation of environmentally harmful products but also encourage subsidies for green and sustainable products, making them affordable for all.
- Whilst it is important to target essential services towards vulnerable and marginalised communities, policy package (d) should also advocate affordable access along a social gradient and through proportionate universalism, to capture the larger population group which lives in sub-optimal conditions but is not considered vulnerable.
- We strongly advocate the establishment of “behavioural and cultural insights units” at Member State level, to collect data on the key barriers and enablers to behavioural change in different communities and feed such information into the decision-making processes.
- In order to strengthen the monitoring and adaptation of policy actions, it is important to integrate a foresight analysis of the impact of climate change and perform economic assessments of the social and health co-benefits aimed at reducing such an impact. These tools would support the long-term and intergenerational understanding of the issues at all levels, reducing the pronounced inequalities gap.
- Taking note of the concurrent digital transition, achieving climate neutrality also means that information and digital solutions must be easy to access, understand and apply, at varying literacy levels.
EuroHealthNet applauds the emphasis made on the inclusive participation of civil society organisations, additionally stressing that in order to co-create a climate-neutral era, efforts need to be just and socially fair for all citizens and further consolidated through national and EU tools.
Read full responseResponse to Update of the Better Internet for Children Strategy (BIK Strategy)
28 Oct 2021
EuroHealthNet - not-for-profit European partnership for health, equity, and wellbeing - welcomes the roadmap on a New European Strategy for a Better Internet for Children, and its aim to strengthen the protection and empowerment of children online in the EU. Along with accelerated digital transformation in the past years and because of the COVID-19 pandemic, children’s use of new digital technologies has increased, and so have the associated challenges and opportunities. An update of the Strategy is welcome as it offers opportunities to take both on the advantages as the challenges to help children thrive and protect their rights, including their right to health and psychosocial wellbeing in digital environments.
Through focused input on key elements of the updated Strategy, EuroHealthNet calls for a renewed approach to how children and adolescents' rights to healthy, commercial, and digital interest-free childhoods should be taken forward, and that it is within the EU and national governments' remit to act.
EuroHealthNet suggests the new Strategy to:
1. Ensure equity, co-creation with children and attend to disadvantage with intensity according to the need (‘proportionate universalism principle’)
2. Respect children’s rights in a world fit for the digital age;
3. Promote digital (health) literacy;
4. Reinforce and institutionalise protection against commercial determinants of health in childhood;
5. Define policies based on the level of maturity and reflective of the socio-economic backgrounds.
EuroHealthNet's full contribution is attached.
Read full responseResponse to Sustainable food system – setting up an EU framework
25 Oct 2021
In laying out the vision for sustainable EU food system fit for the current and future realities, EuroHealthNet aims to bring to the attention the importance of addressing the societal roots of nutritional health inequalities, related to food choices within a remit of the EU food, health and social policies. Since the current legislative frameworks are not comprehensive, strategic and ambitious enough, we stress out that changing food behaviours equitably will only be possible through tackling the systemic factors that determine people’s food choices along a social gradient – poverty and income deprivation, social exclusion and the level of disadvantage. Unhealthy behaviours are not ‘just’ the result of individual choices, but they are influenced by societal factors. With 11% of the EU citizens unable to afford a quality meal every second day, healthy and sustainable food choices unaffordable (up to 75% of disposable income), time and energy poverty among lower SES groups, the healthy choice must be the easy and default choice for all.
For this reason, we focus on implementing evidence-based policies and good practices that promote good nutrition for all with an intensity according to the need and the level of disadvantage, and in key stages of life – early years, adolescence, older years. Such action on healthy and sustainable EU food system contributes to the promotion of Social Rights, building a strong Social Europe and European Health Union in the climate of recovery and resilience-building.
Critically, the following points of concern must be addressed:
1. Rebalance the narrow focus on down-stream nutritional and environmental education and information provision to change people’s food behaviours, with support to health, equity and sustainability-enhancing food system.
2. Regulatory actions are the most effective interventions, while voluntary commitments should be seen only as complementary drivers. Policy option 4 is thus preferred.
3. EU legislative framework offers important measures to tackle challenges common to all diet-related Non-Communicable Diseases. Yet, there is the need for furthering systemic policies to tackle social deprivation related to food environments. EuroHealthNet’s experience gained through INHERIT, and in the Joint Action Best Re-Map: Healthy Food for a Healthy Future, pinpoint three particular aspects:
a. Food advertisement and marketing
b. Public procurement
c. Food reformulation
Read our full contribution in the attachment to this entry.
Read full responseResponse to Draft Delegated Act defining a methodology for reporting social expenditure
24 Aug 2021
Please find detailed feedback from EuroHealthNet included in the attached file.
Read full responseResponse to Europe’s digital decade: 2030 digital targets
9 Mar 2021
EuroHealthNet welcomes the European Commission’s initiative to set out goals, targets and pathways for a long-term vision to guide the European Union in its digital transition over the next decade.
The digital transformation of our societies is on its way and the years to come are crucial to define how this process will be steered. Health and social inequalities are prevalent in most European societies, and the digital transformation offers an opportunity to tackle them. On the other hand, should challenges and barriers to inclusion not be addressed today, the digitisation process could exacerbate pre-existing inequalities and their manifestations among various population groups.
The limited space available for this feedback does not allow to touch upon all relevant issues for the development of a long-term plan. We therefore focus our input on elements we consider key and remit further detailed comments to a later opportunity.
1. Ensure that nobody and no territory is left behind. EuroHealthNet welcomes the attention that the Roadmap has given to an equity principle/rights-based approach to digitalisation. In this regard, we would like to stress the importance to fully embed digital (health) literacy programmes (including data literacy) in every stage of the digital transformation. Improving digital literacy would allow more people to better access and benefit from new and existing digital tools and services. It would facilitate the effectiveness and efficiency of apps. It would help understand how we are using the collected data, and how it can be controlled. It would increase trust in digital innovation in health, care and related sectors, both among individuals and healthcare workforce
2. Digital targets 2030 should build on and reinforce basic digital skills targets set out in the European Skills Agenda 2025. Specific digital targets should be foreseen to ensure that vulnerable and socially excluded groups are reached and that budgetary allocations for this purpose are made. The European Skills Agenda 2025 envisage reaching 70% share of people having at least basic digital skills (vs 56% in 2019)
4. The Digital Economy and Society Index (DESI) should provide adequate attention to socio-economic differences with regard to digital skills, their acquisition and application. We highly recommend ensuring proper monitoring and measurements of digital skills across different population groups to support actions against the formation highly “digitally illiterate” pockets of populations
5. The DESI should also be integrated with health-related specific indicators, namely, to measure, monitor and assess levels of digital health literacy and health data literacy across the population and health workforce. This would allow to set out quantifiable targets and develop tools to act on in this sphere at EU level
6. The Digital Targets 2030 should include specific goals for up- and re-skilling of health and social workforce to stimulate the development training and capacity building programmes for professionals. Public health and social care professionals should not be neglected in this process. In addition, on this regard, specific indicators should be included under the DESI
7. The digital transformation of public administration, in particular of the health and social sectors, should include the use of indicators to assess the change in accessibility during this process. Targets on access should therefore be set to ensure that everyone will benefit from this transformation
EuroHealthNet is a not-for-profit partnership of organisations, agencies and statutory bodies working on public health, disease prevention, promoting health, and reducing inequalities. Its core mission is to tackle health inequalities and to improve and sustain health between and within European States through action on the social determinants of health.
Read full responseResponse to 8th Report on economic, social and territorial cohesion
8 Mar 2021
EuroHealthNet is the European Partnership of national public health institutes, health promotion agencies, regional health authorities and related organisations. Our core mission is to tackle health inequalities and to improve and sustain health between and within European States through action on the underlying socio-economic determinants of health. We believe that the 8th report on economic, social and territorial disparities should include a greater focus on health inequalities, as a key indicator of whether the investments being made to improve cohesion are truly benefiting the health of people and generating more well-being across societies.
Since the publication of the 7th progress report on economic, social and regional cohesion, the situation across the EU and the world has dramatically changed. The COVID-19 syndemic, which can be seen as symptom of the chronic environmental crisis we face, has made all too clear the inter-relationship between health and the economy. The health related and economic effects of the COVID-19 and non-communicable diseases (NCDs) “are clustering within social groups according to patterns of inequality deeply embedded in our societies.” An unprecedented level of funds have been made available to help Member States ‘build-back-better’. At this critical juncture in human history, these provide an opportunity to reassess our values and invest in initiatives that strengthen the EU’s social foundations, while re-orienting economic activities to respect planetary boundaries.
Given the considerable evidence that ‘more equitable societies are better for everyone’, also when it comes to job creation and growth, EuroHealthNet recommends the following to strengthen cohesion and to deliver on the EU’s priorities in relation to achieving a fair green and digital transition:
• Systematically include health and health equity in assessments of regional disparities. We recommend ensuring that data linked to key indicators like life expectancy by age, self-reported health status, preventable mortality and morbidity, and access to quality child-care are disaggregated by socio-economic status, also at the regional and local levels. EuroHealthNet in this respect welcomes the Committee of the Region’s efforts to add a regional dimension to the Social Scoreboard linked to the EU Social Pillar.
• Assess the extent to which a wide range of sectors, including the health and social sectors, are collaborating to define and implement funding priorities. Since many of the key determinants of health and health inequity lie beyond the health sector, improving the impact of cohesion funds requires better governance and administrative mechanisms around cross-sectoral collaboration. All too often key sectors like health and social sectors are unaware of and uninvolved in national approaches to establish priorities areas for EU-level fund allocation, including the new National Recovery and Resilience Plans. Many relevant actors are also unaware of and uninvolved in European Semester processes, that are increasingly influencing EU MS’s spending priorities (see also attached report).
• Encourage EU Member States to develop pan-governmental strategies and set targets to reduce health inequalities, with consistent approaches across governance, and apply cohesion funds to “do something, do more, or do better” to achieve their targets.
• Finally, tools like Health Equity Impact Assessments and Health Equity Audits must be strengthened and applied in a more systematic fashion to understand the distributional impacts of planned investments. Post-facto impact evaluations are also crucial to improve the evidence base of how to invest in ways that simultaneously benefit the environment, health and equity, to maximise the impacts of investments.
The feedback with references and EuroHealthNet European Semester analysis are attached. Further information can be found on the EuroHealthNet website and our Health Inequalities Portal.
Read full response8 Mar 2021
EuroHealthNet welcomes the EC’s commitment to review the EU promotion policy for agricultural products. We strongly support a comprehensive, ambitious, and truly transformative transition to European food systems that put public and planetary health, sustainability, and social equity at the centre. EU’s policy for the promotion of agricultural products should be no exception.
Today's food systems are perpetuating and driving up health inequalities. Unhealthy diets and alcohol consumption – a major contributor to a Non-Communicable Diseases (NCDs) pandemic - are already responsible for more than 950,000 deaths and 16 million DALYs lost in the EU. It is positive that the new EU food systems framework – the EU Farm to Fork Strategy and its Action Plan - aims to advance a comprehensive sustainable food systems transition meant to “bring environmental, health and social benefits, offer economic gains and ensure that the recovery from the crisis puts us onto a sustainable path.”
To this end, a pivotal role for a modern, fit-for-purpose EU promotion policy for agricultural products will be in supporting food environments where “a healthy and sustainable choice is an easy choice” for all, and where the agricultural sector is sufficiently geared towards this transition in line with the EU Green Deal’s ambitions. ‘Business as usual’ of focusing on the sector’s competitiveness is not an option, not compatible with the EU’s public health obligations under the TFEU, UN Agenda for Sustainable Development and its Goals, as well as several new EU’s flagship initiatives, such as Europe’s Beating Cancer Plan and the European Pillar of Social Rights.
Public money distributed via EU funds should not pay for activities that undermine the advancement of EU public health objectives, such as NCDs prevention or environmental health. International evidence links consumption of red and processed meat and alcohol with a heightened risk of NCDs, cancers notably. While sugar and tobacco have been systematically phased out from agricultural support measures, meat and alcohol production are still eligible for EU-sponsored ‘promotion’ on external/European markets.
Given the above, we recommend to:
• re-focus the policy scope on promotion and information measures in support of sustainable agricultural production and consumption, in line with the Farm to Fork Strategy and Europe’s Beating Cancer Plan, supporting consumers to choose and adopt healthier diets.
• investigate using promotion funds to support ‘alternative’ modes of agricultural production via local, rural, (peri)urban, and/or short supply or organic models.
• review the conditionality and eligibility criteria to incentivise applicants to demonstrate concrete support to the Farm to Fork Strategy’s relevant objectives (especially healthy diets and climate change ones). We would be in favour of dedicating the promotion funds to health-promoting yet under-consumed (ideally minimally processed) products such as “whole-grain, cereals, fruit and vegetables, legumes and nuts”.
• consider excluding certain sectors from promotional funds, notably those with scientifically demonstrated incompatibility with the NCD prevention logic (red meat, alcoholic drinks). Of course, adverse impacts can be expected in rural communities or areas resulting from the possible ineligibility of some products from promotion programmes. We call for further impact assessment of such eventuality, including how other EU funds could be used to mitigate potential income losses and incentivise the transition to ‘eligible’ production.
See also: EuroHealthNet 2019 Policy Precis "Towards healthy, sustainable and inclusive European food systems" https://tinyurl.com/5eukrtup
Read full responseResponse to Setting of nutrient profiles
2 Feb 2021
EuroHealthNet welcomes the EC’s commitment to establishing harmonised mandatory front-of-pack (FOP) nutrition labelling and nutrient profiles in the context of the EU Farm to Fork Strategy. While recognising the complexity involved in of doing so, we strongly support both initiatives as part of a comprehensive, ambitious, and truly transformative transition to European food systems. EuroHealthNet counsels however against a disproportionate focus on ‘downstream’ behaviour-change and lifestyle-oriented measures alone without a genuine appreciation of the underlying causes of poor nutritional choices, the socio-economic determinants. Issues of social fairness and deprivation, affordability, health- and digital literacy will be key in this transition.
The challenge of food insecurity and affordability risks growing during economic crises, making it a central theme in both the pandemic and economic recession recovery strategy. Any review of the regulatory actions needs to be carefully conceived against a set of health and social equity-linked indicators.
Please see our detailed input in the attached document.
Read full responseResponse to A European Health Data Space
2 Feb 2021
EuroHealthNet welcomes the European Commission’s initiative to establish a European Health Data Space with the purpose of promoting access to health data for research and innovation on new preventive strategies, as well as on diagnosis and treatment of diseases to improve health outcomes, while ensuring that citizens have control over their own personal data.
In line with its mission, EuroHealthNet monitors and advises on digital health strategies from a health equity perspective. Digital innovation in the field of health, when developed together with programmes enhancing inclusion, literacy and protection, can have significant positive effects on the efficiency and sustainability of health systems and improve health outcomes across the population, especially among people in fast changing vulnerable groups.
The European Health Data Space aims for “making the most of the potential of digital health to provide high-quality healthcare and reduce inequalities”. Improved safe health data collection and use could certainly improve monitoring and prevention systems, as well as enhance the ability of people to better understand and engage in their own wellbeing via multiple applications and tools. However, there are significant challenges to be addressed and safeguards to be ensured:
Standardisation of data is a key for the deployment of the EHDS and use of health data across the EU. Regulators should take an active role in ensuring that standardisation includes high levels of data protection and anti-discrimination principles. Digital tools collecting these data should also be standardised and regulated to ensure they are safe, comprehensible, easy to use and (therefore) accessible to everyone. The ISO/IEC effectivity and reliability criteria for health and wellness can be considered in developing European standards
The development of sound digital infrastructures should ensure the collection of high-quality data that add value to health systems in a non-discriminatory way. This includes ensuring that AI algorithms are designed reflecting the needs, preferences and expectations of people in vulnerable circumstances and priority needs. This means that people with lower digital or health literacy, less education, low income, migrants, disadvantaged older people, people with physical or mental disabilities etc., are systematically and well included in the underpinning research and planning. Health equity impact assessments are also vital processes
Data/Digital Health Literacy programmes should be an integral part of the EU actions on the European Health Data Space. Improving data literacy across the population would allow people to not only actively manage their personal health and care, but also to increase their understanding of the quality and suitability of apps (including mHealth apps), their marketing, what their data is being used for, how they can control it and other relevant issues. Improved data/digital health literacy would also increase trust in digital innovation in health, care and related sectors as well as general media, which is an essential component as the COVID-19 syndemic has demonstrated
The deployment of the European Health Data Space should go hand in hand with training and capacity building programmes for professionals (including through up- and re-skilling) . This would help them deliver better quality of care and also create a safer environment. For instance, a large part of cyber threats to health systems start off with phishing events at workstations, which could be prevented with better data and digital literacy
EuroHealthNet is a not-for-profit partnership of organisations, agencies and statutory bodies working on public health, disease prevention, promoting health, and reducing inequalities. Its core mission is to tackle health inequalities and to improve and sustain health between and within European States through action on the social determinants of health.
Read full responseResponse to Tobacco taxation – revision of EU rules
18 Dec 2020
EuroHealthNet supports comprehensive and effective regulatory and taxation measures that reduce the consumption of manufactured tobacco and novel tobacco products as a matter of health equity in Europe.
EuroHealthNet broadly welcomes the European Commission’s follow-up on the Directive 2011/64/EU’s evaluation and the Council of the European Union’s conclusions related to the structure and rates of excise duty applied to manufactured tobacco. We are particularly encouraged by the reference to keeping up with the recent market developments and the emergence of new tobacco products, such as e-cigarettes and heated tobacco to be included in the scope of the updated legal framework. This is in line with the recommendations that EuroHealthNet brought forward in recent years, namely to:
- Strongly support the further closure of the tax gap and increase of tobacco taxes, as well as the EU wide harmonisation of fiscal policy with regard to novel tobacco products, to bring their internal market treatment into line with that of conventional tobacco products;
- Promote an effective and comprehensive regulation at the European level, including agreement on a common fiscal definition and the establishment of distinct category for e-cigarettes in EU excise legislation;
- Adopt an intelligent and contextual approach to regulation to mitigate the risk of e-cigarettes becoming a ‘gateway’ product to tobacco, particularly amongst those who are young and/or vulnerable; invest in (digital) health literacy and health education;
- Strengthen existing legislation to curb tobacco industry influence, especially in the (digital) advertising and marketing and digital tax sphere;
- Cautiously endorse the use of e-cigarettes as one element of properly planned and supervised smoking cessation programmes, while further research into health effects of the novel tobacco products should continue.
The EuroHealthNet partnership strongly supports the continued increase of excise duties and taxation on traditional tobacco products and the consistent excise treatment of e-cigarettes as an equivalent product to tobacco. Supporting national member agencies, partners, and the EU institutions to tackle tobacco use and smoking has been among EuroHealthNet’s priorities since its establishment.
In this context, we urge a cautious approach encompassing moderate to high taxation of novel products and the continued increase of taxation levied on ‘traditional’ tobacco products, in conjunction with comprehensive and easily accessible tobacco cessation services. This approach is best placed to optimise switching from tobacco products whilst deterring (youth) initiation and dual-use and raising public revenues, which could then be diverted to further support prevention and cessation programmes.
Read full responseResponse to Green Paper on Ageing
14 Dec 2020
EuroHealthNet welcomes the European Commission's plans brought forward through this Roadmap. In the context of demographic and socio-economic changes, particularly those related to ageing, key functions of public health - health promotion and prevention – should be central to European and national efforts to assess, prepare and act in a timely way to keep people healthy. To ensure the sustainability and affordability of health and social protection systems, it will be increasingly important that people are able to stay active and contribute to society for longer.
The European Commission report on the impact of demographic change correctly highlights regional inequalities in health outcomes and abilities to absorb the impact of demographic change. Future work on demographics must also address social and economic inequalities within countries and regions. We do not all age equally; people with lower levels of education and low-status jobs suffer more from the negative aspects of aging more than others, and experience those aspects earlier. Europe will need a highly skilled and adaptable workforce in the future, however, the needs of those who cannot or have more difficulties up- or re-skill cannot be ignored if the EU does not wish to exacerbate existing inequalities and social instability.
As a matter of priority for the EC Roadmap on Ageing, EuroHealthNet recommends to:
1. Adopt a holistic, people-centered, and inter-sectoral community-based approach to healthy and active ageing across the life-course.
2. Recognise that human and financial investments in healthy and active ageing constitute a vital asset, not a burden to health and social costs in Europe.
3. Bring forward attention to the workforce for ageing populations especially in the long-term care, employment/productivity of older population with a particular focus on the psychosocial dimension of occupational health and safety strategies, closing the digital skills divide.
4. Prioritise preventative measures within primary health care, focus on chronic and non-communicable diseases, including mental health and cognitive functioning.
5. Recognise large inequalities in ageing not only between regions but importantly between people with different social and economic statuses. An assessment of the effects on equity and on different groups of people should be central to all future actions and proposals.
EuroHealthNet will follow up on these recommendations throughout 2021 and beyond, with our members and partner organisations. We will seek to contribute to detailed consultative dialogues and strategic planning, specifically from a health equity and prevention-focused perspective. Within our 2021 thematic area, EuroHealthNet will step up its work on digital, skills and capacities in rights-based and life-course approaches to health. We will help the implementation of the European Pillar of Social Rights Action Plan, the Digital Education Action Plan and the Educational Area, the EU Pact for Skills, as well as effectively engage within various European strategies on e-health, healthy lifestyles and health systems’ organisation/financing reforms.
Read full responseResponse to EU Strategic Framework on Health and Safety at Work [2021-2027]
24 Nov 2020
The EU Mental Health Alliance for Work and Employment welcomes the European Commission’s proposal for the new EU Strategic Framework on Health and Safety at Work (OHS) (2021-2027) as a necessary step in improving the working conditions across the EU.
While we understand that this Roadmap is a first step of a broader consultation, we regret seeing no reference made to psychosocial factors behind work-related illnesses. Mental health of workers across different categories requires protection especially in realities of the changing world of work (e.g. platform workers, gig economy). Good mental health and wellbeing at work is fundamental to ensure quality of life for every worker – and their family – as well as positive economic outcomes for society as a whole.
In a world where costs related to occupational mental health challenges are substantial and constantly increasing, a vision for a Stronger Social Europe calls for constant improvements towards safer and healthier work for all, and this must include progress in the psychosocial dimension.
The costs speak for themselves: more than a third of work-related morbidity and mortality is attributed to mental illness, 6% of EU GDP (240 billion EUR/year) are lost in labour market costs (lower employment and productivity), with further 57 billion EUR/year spent on sick leaves and unemployment insurance. Only by firmly placing psychosocial aspects of work at heart of the new EU OHS Framework for the years to come, real and tangible benefits would be felt by workers across Europe.
Such orientations are particularly relevant in light of the current pandemic, which has added new risks due to changed ways of working, rapid uptake of new (digital) technologies, to the more traditional ones, such as exposure to dangerous substances and risk of accidents at work. The COVID-19 context is likely to increase mental strain on current and future workforce. Yet, the groups who will face particularly severe consequences will be the low-paid and low-quality jobs workers, as well as disadvantaged groups such as women, youth, migrants, older workers, people with chronic diseases or disabilities. Moreover, we can expect mental health problems among essential and frontline worker categories key to the fight against the crisis, such as teachers, health and social care workers.
We recommend the new EU OSH Framework to:
1. Steer Member States to address mental health and psychosocial risks in their national OSH strategies, including adequate resource allocation for preventative actions with specific focus on the high risk groups
2. Lay out an explicit role for the EU Steering Group on Health Promotion and Disease Prevention to offer additional support towards ensuring high protection of mental health due to the changing nature of work
3. Embed the new EU OHS Framework into the rights-based approach (guided by the Action Plan for the implementation of the EPSR) to reforms of national occupational health policies with the support from the Recovery and Resilience plans
4. Include occupational psychosocial health and safety indicators in the Social Scoreboard
5. Promote a more integrated approach to address occupational mental health challenges through various sectors, services and settings, including community-based
6. Encourage trade unions and employers to increase their efforts and understanding of mental health and workplace links to prevent and provide people with mental health problems with the right support to enter or remain in employment
7. Support European companies addressing psychosocial risks in their operational guidelines
8. Support addressing psychosocial risks in collective bargaining and in debates on ethics in digital transition and artificial intelligence
9. Explore options to further elaborate on the introduction of relevant legal instruments (e.g. EU Directive) on addressing psychosocial risks at workplaces
See: www.eumhalliance.com
Read full responseResponse to Union of Equality: European Disability Rights Strategy
12 Nov 2020
EuroHealthNet welcomes the European Commission’s plans to develop the EU Strategy on the Rights of Persons with Disabilities for 2021-2030, as a contributing enabling framework for public health actors to address disability-linked health and social inequalities. The strategy also offers opportunities to strengthen the imminent Action Plan for implementation of the European Pillar of Social Rights, the EU’s contribution to the UN Agenda 2030, the EU Green, Skills and Digital agendas.
Persons with disabilities are at a heightened risk of disadvantage and vulnerability, what significantly contributes to direct and indirect impact of their ‘condition’ on health, social and economic outcomes at multiple population levels. Persons with disabilities are often of older age and poor; 28.6% of them live in poverty and social exclusion, as compared to 19.1% of those without disabilities. Severe disability further increases the poverty risk to more than a third.
Poor living conditions constitute a powerful socio-economic determinant of health and inequalities in health outcomes. As highlighted briefly in this Roadmap, persons with disabilities face many challenges as concerns their health status and equal access to healthcare. Disabled people in all EU countries and in different regions in Europe are at a higher risk from most of the ‘common’ chronic and noncommunicable diseases (NCDs) due to a combination of higher exposure to risk factors, older age, poorer access to preventive measures and health services in general, and less capacity to deal with the social, employment, and financial consequences of the disease as confirmed by data from OECD, WHO Europe and Eurofound. Further disparities may occur in terms of informal care and peer-support required, capacity to find or return to work arrangements or need for long-term care. They may be living in institutions, being deprived of independent living. Due to their health, social and economic fragility they are more exposed to exploitation and violence, especially children and women as confirmed by the Fundamental Rights Agency studies. They also face limited accessibility to the environment, green spaces and active transport and mobility options.
Often, people with physical, mental and learning disabilities enter and stay within ‘linear’ and silo health and social systems which fail to address disabilities holistically considering people’s complex needs and abilities. Furthermore, people living with disabilities are often defined by their impairments and disabled condition, that their other health needs don’t receive timely attention. The already mentioned NCDs are an example of that, but also mental health, sexual and reproductive needs slip through the gaps.
Plans for the post-pandemic recovery and resilience of health and social care systems in Europe should furthermore fully include the rights of people with disabilities. This can be linked with the EU investments and technical support within the EU Recovery and Resilience Facility, the European Semester process, and plans for the European Health Union in the making.
Last but not least, considering the recent speed of transition and transformation of the delivery of health and care towards one that’s increasingly digital and commercial, we urge stepping up investments in digital and health literacy, skills and competences needed for healthy lives.
Read full responseResponse to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil
29 Oct 2020
EuroHealthNet is a not-for-profit partnership of organisations, agencies and statutory bodies working on public health, disease prevention, promoting health, and reducing inequalities. EuroHealthNet has long been committed to sustainable development in Europe and globally. We welcome the European Green Deal and EU Action Plan Towards a Zero Pollution Ambition for air, water and soil in principle as crucial steps towards ensuring a transition to a more sustainable future.
In the Zero Pollution Action Plan Roadmap, we particularly welcome the Commission’s recognition of the inextricable links between a healthy planet and healthy people, and the fact that “pollution often affects the most vulnerable people most seriously”. The recent H2020 INHERIT initiative, which EuroHealthNet coordinated, highlighted exactly this issue, and drew attention to the need to enact policies and processes that jointly benefit the environment, health and equity – “triple-wins”. The INHERIT Policy Brief attached to this feedback provides a few indications on how this can be done, and further responses to the Commission’s Roadmap are included below.
EuroHealthNet agrees with the need for binding health and environmental standards, to ensure that the public and private sector implement EU rules on air, water and soil pollution, and we also welcome the inclusion of the much-needed polluter pays principle. Legislation should aim to ensure a just transition, in which those who are more vulnerable are not disproportionately harmed by new measures. Shifting to intersectoral governance will ensure that all potential impacts of legislative initiatives are considered; not just environmental but also health and social (equity) impacts. INHERIT’s findings include recommendations for how to create institutional cultures that value and foster collaboration.
In order to successfully achieve the zero pollution ambitions, it is critical that citizens are enabled and encouraged to make sustainable changes through effective policies, which identify barriers and build a social and physical environment that facilitates these changes. We also know that people can be motivated to take action through concern for their health. Providing more information on how pollution is affecting health – including through citizen science approaches – can be a powerful lever for change. INHERIT research demonstrated that involving all communities in policies that affect them helps to ensure policies address real needs, is empowering and gives them a vested interest in their success. We urge the Commission to encourage such approaches, in particular initiatives that involve citizens and communities who are most affected by pollution and the green transition, and whose voices are not always heard in public debates.
EuroHealthNet notes the Commission’s reference to digital solutions as a driver of societal change, and would like to highlight that this should be accompanied by investments in improving digital literacy and enabling infrastructures across population groups, while always safeguarding individual privacy. Information and solutions must be easy to access, understand and apply by all; the more complex the information the harder it is for the general population to act on.
Finally, the Roadmap mentions the need to “further decouple economic growth from the increase of pollution”. EuroHealthNet would like to suggest a focus away from economic growth, and towards a regenerative and redistributive economy of “wellbeing”, which is good for people and good for the planet. Kate Raworth’s Doughnut Economy is an essential model in this respect, which the Commission could use to further build on the Finnish Presidency’s Council Conclusions on the Economy of Wellbeing.
Further INHERIT recommendations and tools applicable to the Zero Pollution ambition and European Green Deal as a whole can be found in a policy toolkit: https://inherit.eu/policy-toolkit/.
Read full responseResponse to European Child Guarantee
7 Oct 2020
EuroHealthNet welcomes the EU's reinforced measures to improve basic services for children through the Child Guarantee. The need for this is stronger than ever. A quarter of children in the EU are born and grow up at risk of poverty and social exclusion, with big implications for the life-course of these children and their ability to contribute to society. The negative secondary effects of COVID-19 are affecting children and families that are already vulnerable, most.
Specifically, but not exhaustively, we would like to suggest that a proposed Council Recommendation on a EU Child Guarantee address the following issues:
- Improve links between the 2013 Council Recommendation for Investing in Children (wider policy framework) and the current proposal for EU Child Guarantee.
- Ensure that the recommendations in the progress report on the implementation of the 2017 Recommendation for Investing in children are being implemented. These called for e.g., the need to focus on children and families at high risk, which can be very hard to reach, and for a more comprehensive, multi-dimensional and coordinated approach to investing in children.
- Most EU states make healthcare services for children free of charge, but the definition of ‘free’ differs greatly with e.g., pre-payments constituting a real barrier for free care. Although unmet medical and dental needs among children are relatively low, current approaches to identify this may not reflect real need and regional and income-related differences are substantial. Poor children in Belgium are 5 times more likely not to access dental care they need than their wealthier peers. Access to mental health care for children in many EU states is suboptimal as well.
- Like other medical interventions, access to health promoting and preventative measures like childhood vaccination and immunisation are subject to a social gradient. A recent drop in measles immunisation rates in rich-economies is most likely to have occurred amongst vulnerable families, as factors like income, maternal education, place of residence, the sex of the child, and poverty are all linked to access to levels of vaccination coverage (UNICEF data). Those further down the socio-economic gradient may also be less likely to access mental health services or positive parenting programmes, which studies have identified as effective to reduce inequalities in childhood (DRIVERS project).
- Taking a multidimensional, coordinated approach to investing in children also means ensuring that children facing vulnerability can live, learn and play in environments that promote their health. It means that they can breathe clean air (indoors, outdoors), have access to green and safe public spaces that support physical and mental health and that these environments are not obesogenic.
- Cost can be a key factor inhibiting families on low incomes from enjoying healthy diets. Fiscal measures as well as targeted interventions are needed to ensure families have access to foods that promote rather than undermine health. Education settings should also be involved in ensuring this, as well as other approaches to improve the health and wellbeing of children in need, as health and educational attainment are inextricably linked. Such support must be provided in non-stigmatising ways.
- Efforts to address gaps in educational attainment must also focus on the digital divide. The pandemic has clearly reflected the inequitable access to devices and in skills.
- Finally, there is a real need to improve and harmonise the collection of disaggregated data on child health, wellbeing and social inclusion to help monitor, compare and assess progress towards reducing child health inequalities, child poverty and vulnerability. EU states should also identify and learn from the most effective, evidence-based approaches across the EU, to apply resources better.
Our response complements our input to a joint response by the EU Alliance for Investing in Children.
Read full responseResponse to Empowering the consumer for the green transition
1 Sept 2020
EuroHealthNet is a not-for-profit partnership of organisations, agencies and statutory bodies working on public health, disease prevention, promoting health, and reducing inequalities. Between 2016-2019, it coordinated the Horizon 2020 INHERIT project, which looked at initiatives and policies that simultaneously improve health, the environment, and health equity – a “triple-win”. The green transition is an area in which we need to strive for and can deliver a triple-win, promoting not just environmental sustainability but also health and health equity. It is also crucial that all stakeholders are involved in the transition, including policymakers and the private sector, but also citizens.
Individual (un)sustainable behaviours impact not only the health of our planet, but also our own health. Changes in how we live and consume are key aspects of the green transition. Policymakers can facilitate these changes by making them easy, given that initiatives that require a high level of personal agency are less likely to be adopted at scale. A crucial element here concerns guidelines and labelling.
Although in many cases healthy food is also sustainable food, trade-offs do exist, and there is little consensus internationally on what constitutes sustainable and healthy foods. There is a need for clear scientifically sound guidelines at EU level and for mandatory standardised EU-wide labelling on food products, which highlights health, social and environmental sustainability aspects, to support people’s capability to make positive changes. Criteria established by the “Question Mark” tool, which scores products on the basis of health, environment, human rights and animal welfare considerations, can provide guidance.
Information must be easy to understand and apply by all; the more complex the information the harder it is for the general population to act on. Given that information and misinformation is increasingly transmitted digitally, this also calls for investments in improving digital literacy. Policymakers must also ensure responsible (digital) marketing to all consumers, including vulnerable consumers such as children. Finally, sustainable and healthy food, as well as other products and services, needs to be affordable, as cost is a key factor driving consumer behaviour, and this can increase health inequalities.
The “triple-win” transition cannot happen without the private sector. Policymakers have a duty to facilitate the efforts of front-runners, and to hold accountable those that harm the environment and public health. In this respect, legislation should help to foster a level-playing field amongst companies and make sure that externalities are included in the ultimate pricing. Tax incentives could also be provided to encourage companies to produce sustainable products and services, particularly those that have yet to prove economically sustainable. Enshrining the “right to repair” in legislation and banning the practice of obsolescence would help to further embed sustainable practices within companies. “Business as usual” is not an option, and EuroHealthNet highlights the urgent need to enforce existing and amended legislations, rather than relying on self-regulation.
Foresight activities carried out within INHERIT help to further this reflection. Based on research about demographics, health, social inequalities and the environment, INHERIT set out four positive scenarios of what Europe could look like in 2040. In focus groups carried out in five European countries, the “circular economy” scenario was well received, mainly due to its inclusion of citizens insights into the planning of societal processes and the promotion of resource efficient and circular models of production and consumption, highlighting that these are elements which are highly valued amongst European citizens.
Read full responseResponse to Delivering for children: an EU strategy on the rights of the child
3 Aug 2020
UN Convention on the Rights of the Child sets out the political, economic, social and cultural rights that every child is entitled to, including the “right of the child to the enjoyment of the highest attainable standard of health” (Art. 24); the “right of every child to a standard of living adequate for the child’s physical, mental, spiritual, moral and social development” (Art. 27). Ensuring them is not only in line with our European values, it is essential for strong societal foundations. There is a myriad of data on how the ‘First 1,000 days’ are a critical period for health and cognitive progress, while problems in early life are compounded across the life-course. The EU Strategy on the Rights of the Child is therefore integral to all of the EU’s political priorities of guidelines, and in line with efforts to meet the UN 2030 Agenda and the SDGs.
EU-funded research projects coordinated by EuroHealthNet (GRADIENT, 2010-2013 & DRIVERS, 2011-2014) highlighted that for every step down the socio-economic ladder (social gradient), children and young people all across Europe experience a higher level of physical and mental health problems that will affect their future health and life opportunities. This reflects how not all children and adolescents have equal access to the opportunities to lead healthy, happy and prosperous lives. Such avoidable inequities are likely to grow in the context of the COVID-19 crisis; a more substantial and ambitious focus and investments in children and their living conditions is urgently needed. Our research projects showed that improving in particular mothers’ educational levels and employment status, as well as targeted programmes offering intensive support to develop parenting skills have led to the best outcomes for children. The European Pillar of Social Rights (EPSR), its implementation Action Plan, and this Child Right’s Strategy are therefore key vehicles to ensuring the rights of the child to health, freedom from poverty and inequality.
Specifically, but not exhaustively, we urge the EU’s Strategy on the Rights of the Child to address the following issues:
- A focus on reducing child poverty (25% of the EU’s children) and health inequalities, by investing in family support policies, early interventions, and prevention and health-promoting services. Such approach should be guided by the EPSR, the Council Recommendation on Investing in Children (2013), on High-Quality Early Childhood Education and Care Systems (2019), the EC proposal for Child Guarantee (2019), and the Council Conclusions on the Economy of Well-being (2019).
- Ensuring environments that encourage and easily enable children and adolescents to adopt healthy lifestyles and behaviours, by putting a firm focus on the implementation of Art. 168 of TFEU on ‘health in all policies’. Physical activity levels in children and adolescents are persistently declining, while consumption of highly processed foods and sugary drinks is high, contributing to growing levels of overweight and obesity in the EU. In addition, increasing numbers of adolescents are reporting issues that affect their mental health (sleep difficulties, stress and anxiety). Such issues are linked to societal trends and pressures, incl. digital and technological, and can only be addressed through comprehensive, integrated approaches, supported by regulatory action, to create environments that support children and adolescent’s health and well-being.
- Tackling persistent inequalities in childhood vaccination and immunisation: like other medical interventions, vaccination is subject to the social gradient. Wealth distribution, maternal education, place of residence, the sex of the child, and poverty are linked to access to, and levels of vaccination coverage;
- Improving the collection of disaggregated data on child health, well-being and social inclusion to help monitor and assess progress towards reducing child health inequalities, child poverty and vulnerability
Read full responseResponse to Communication on the future of research and innovation and the European Research Area
1 Aug 2020
The ERA 2015-2020 Roadmap raised the importance of “jointly addressing grand challenges.” The gravity of these challenges, like climate change and the COVID-19 pandemic, the risk of digital divides and growing levels of socio-economic - and closely related - health inequalities have in recent years and months become all the more apparent. The EU must act as a role model globally of how democratic societies can work together to overcome these challenges and achieve ecological, social and economic transition; this hinges on bringing together Europe’s best researchers to design, develop and test new approaches. EuroHealthNet strongly supports efforts to bolster progress towards an ERA that helps meet those needs. COVID-19 has demonstrated all to clearly the central role that public health plays in our societies, and of how economic growth depends on good health and wellbeing. The ERA should therefore also include and coordinate research in the area of public health, prevention and health promotion as a crucial factor in and indicator of the effectiveness of measures to transition to more sustainable and inclusive societies.
EuroHealthNet is pleased that the new roadmap recognises the EU Green Deal as a ‘new paradigm in strategic thinking’. This paradigm change should also be reflected in the ERA in the way joint research questions are formulated and research is conducted. Since many of the challenges afflicting societies are inter-related, it is important that issues are framed and addressed with reference to all the factors which bear upon them, and that researchers are encouraged and able to apply holistic, transdisciplinary approaches when seeking solutions. It can be all too easy for policy agendas to fall back into traditional ‘siloed’, ‘downstream’ approaches and for Research and Innovation (R&I) agendas to follow suit, limiting their potential to help deliver transformative change.
Public health is an important case in point. Strong public health outcomes are achieved when societies provide conditions for good health, particularly as chronic diseases now account for the largest share of morbidity and mortality across Europe and globally. R&I based on social models of health are more likely to contribute to improved public health outcomes across society rather than bio-medical models that focus too often on addressing the symptoms of unhealthy conditions and environments. While developing a vaccine against, and drugs to treat COVID-19 are now a top public health priority, it is also important to address the underlying causes of the pandemic and its spread, to avoid and mitigate the impacts of future crises. ‘Equity’ is also a key consideration: the inequalities in COVID-19 mortality rates reflect existing unequal experiences of chronic diseases and the social determinants of health. Investing in R&I to identify what can be done to reduce such inequities will generate significant returns across society through improved public health outcomes. A persistent emphasis on bio-medical approaches is likely to exacerbate inequities, particularly in the short term, generating further social costs.
EuroHealthNet recently coordinated and concluded INHERIT, an EC funded research project, that investigated promising inter-sectoral policies and practices that simultaneously reduce environmental degradation, protect and promote health and contribute to health equity. Further investments in such multisectoral research, to investigate what can be done to encourage and enable people to live, move and consume more sustainably is consistent with the paradigm change envisioned, and can lead to the positive feedback loops needed to achieve transformational change. EuroHealthNet urges that ERA be designed to encourage such approaches and that it mainstreams diversity to empower those that have not, traditionally, been able shape existing research frameworks and agendas to do so in ways that are more reflective of their values and concerns.
Read full responseResponse to Climate Law
29 Apr 2020
EuroHealthNet is a not-for-profit partnership of organisations, agencies and statutory bodies working on public health, disease prevention, promoting health, and reducing inequalities. EuroHealthNet has long been committed to sustainable development in Europe and globally. We welcome the European Green Deal and proposed European Climate Law in principle as crucial steps towards ensuring a transition to a more sustainable future.
We particularly welcome the Commission’s emphasis on the need for the transition to be “just and socially fair”, and its acknowledgement of the impact of the climate crisis on wellbeing. We would like to take this opportunity to highlight the strong links between the environment, health, and inequalities, and urge the Commission to take these links into account in all aspects of the proposed climate law, building environmental policy whilst looking through health and equity lenses. Environmental determinants of health – such as clean air, green space and sustainable transport – have a critical impact on people’s health, and transitioning to a more sustainable, cleaner environment, could thus have important long-lasting health benefits. In parallel, those who are less well-off suffer most from the negative impacts of the climate crisis and environmental degradation, and benefit least from measures taken to address them, contributing to widening health inequalities.
The recent Horizon 2020 INHERIT initiative, which EuroHealthNet coordinated, drew attention to the need to jointly consider opportunities for a “triple-win” between the environment, health and equity. The INHERIT Policy Brief attached to this feedback, “Putting health equity at the heart of sustainable transitions”, presents some relevant recommendations for the proposed Climate Law. Specifically, EuroHealthNet recommends that the foreseen studies and assessments take into account inequalities and the distributional impacts of policies or interventions on people across socio-economic gradients.
Further INHERIT recommendations and tools applicable to the Climate Law and European Green Deal as a whole can be found in a policy toolkit, which sets out how policymakers can invest in measures that simultaneously protect and promote health, address growing inequities and improve environmental sustainability: https://inherit.eu/policy-toolkit/. The toolkit provides details on the INHERIT conceptual model, which we recommend environmental policymakers use as a tool for screening climate policies for their potential unintended health and wellbeing consequences. EuroHealthNet was pleased to note the Climate Law includes a reference to the need to work across sectors – the INHERIT toolkit provides further guidance on how to foster integrated governance and align policies to achieve the triple-win.
The COVID-19 pandemic has demonstrated the perils of not addressing the grave challenges we face in relation to the environment, health and social inequities, and of not addressing these issues in integrated ways. The need to mitigate the economic damage resulting from the pandemic provides an opportunity to do so now, in more systematic ways, and to build an economy fit for the 21st century.
EuroHealthNet recognises that EU Institutions have limited competencies to ensure Member States’ compliance with the law, but wonders if stronger measures could not be included that lie within the scope of their powers to hold EU Member States accountable. Measures that encourage and enable Member States to monitor implementation as well as effects on health and distributional effects, and benchmarking of Member States performance will in this respect be crucial.
Read full responseResponse to Farm to Fork Strategy
13 Mar 2020
EuroHealthNet welcomes the EC’s commitment to develop a Farm to Fork Strategy for sustainable food systems. We strongly support a comprehensive, ambitious and truly transformative transition to European food systems that put people and planetary health, sustainability and social equity at the centre. In a framework of the European Green Deal, this strategy offers an important opportunity to design and deliver a coherent response to current - and future, if business as usual prevails - health, social and environmental challenges related to unsustainable food production and consumption patterns.
Unhealthy diets – major contributor to a NCDs pandemic - are already responsible for over 950,000 deaths and 16 million DALYs lost in the EU (the 2017 Global Burden of Disease). Today's food systems are perpetuating and driving up health inequalities - which is conspicuously missing from this proposed strategic thinking. There is an abundance of evidence to show that sedentary and unhealthy lifestyles of people are heavily influenced by their social, economic, and environmental circumstances and cultural contexts. Therefore, a pivotal role for a modern, fit-for-purpose strategy will be in creating food environments where “a healthy choice is an easy choice” for all. EuroHealthNet counsels against disproportionate focus on ‘downstream’, ‘personalised’ lifestyle-oriented measures (information, education) without real appreciation of the underlying causes of ill-health and disease, the social determinants. They are part of a solution, but not enough to drive the transformative changes needed.
To this end, many effective, evidence-based and innovative policy solutions exist. In particular, EuroHealthNet advises the EU to enable healthy, inclusive and sustainable food environments through:
Production:
- Reform agriculture and food policies in line with public health and other public good priorities (social fairness, environment);
- Put public health promotion and protection upfront in trade and investment policies;
Added-value field:
- Establish nutritional standards for healthy diets in educational settings, hospitals, and public institutions; supporting shorter food supply chains in (peri)urban settings;
- Roll out harmonised, understandable and reliable consumer nutrition information (front-of-pack);
- Support healthy and sustainable public food procurement;
- Lead food reformulation in line with public health and social fairness principles;
Consumption:
- Enforce/review gaps in regulatory actions on marketing/advertising of unhealthy foods (esp. to vulnerable consumers, children);
- Explore better use of EU competences in fiscal, budgetary and economic policies in support of stronger health protection against commercial determinants of health; advancing coherence across various policy areas;
- Improve (digital) health literacy and skills for healthy lifestyles/diets with due attention to health equity and digital divide;
- Quantify societal (incl. health) and environmental costs of unsustainable production/consumption, along a social gradient;
- Address food and nutritional poverty/insecurity that lead to diet-related health inequalities through EU anti-poverty and social policy schemes (Child Guarantee, FEAMD);
The above considerations should feature in a proposal for an Action Plan and its regulatory/supporting measures. Beyond ensuring coherence between this strategy and other initiatives under the European Green Deal (notably the Cancer Plan), it should outline transparent and inclusive food governing processes, prioritising binding measures over voluntary mechanisms which have so far been largely ineffective in addressing NCDs.
EuroHealthNet has been calling for sustainability, health and equity indicators to be better integrated within the EU flagship processes and tools (the European Semester, the EPSR, the MFF). These would then align with the UN Agenda 2030 and its goals, and aspirations towards the Economy of Wellbeing.
Read full responseResponse to Europe’s Beating Cancer Plan
3 Mar 2020
EuroHealthNet welcomes the European Commission’s prioritisation of, and plans to implement, Europe’s Beating Cancer Plan. To be successful, however, ambitious commitment must be to urgently address the large scale of social and economic inequalities in cancer-related health outcomes and in population-wide opportunities for prevention.
Disadvantaged groups in all EU countries and in different regions in Europe are at a higher risk from most of the ‘common’ cancers due to a combination of higher exposure to risk factors, poorer access to cancer preventive measures and health services in general, and less capacity to deal with the social, employment, and financial consequences of the disease. Further disparities may occur in terms of informal care and peer-support required, return to work arrangements or need for long-term care.
On a population level, the only way to significantly bring down both incidence and mortality for any ill-health condition is through primary prevention. Unfortunately, we have made far less progress preventing cancers than preventing other NCDs. While many breakthrough modern targeted treatments and early detection interventions are (to a degree) responsible for a small decrease in cancer-related mortality rates (WHO EHIC 2018), these advances alone will never be enough to successfully and significantly reduce the burden of the disease. While acknowledging the ‘moderate’ 40% cancer prevention rate quoted by this Roadmap, EuroHealthNet points out that broader systemic and health-enabling approaches promise a much bigger ‘return on investment’. Current long-term epidemiological research suggests that between 30-70% of cancer cases “could be prevented by applying what we already know” (Harvard Public Health, 2019).
In modern public health science “promotion and prevention” is considered more important than ever and has led to the rise in new concepts, and new actors in the field. However, we should also be careful with embarking on a downstream “lifestyle drift” of health promotion, without real appreciation of the underlying causes of ill health and disease, the social determinants. There is an abundance of evidence to show that sedentary and unhealthy lifestyles of people are heavily influenced by their social, economic, and environmental circumstances and cultural contexts. Unfortunately, these factors seem to get less political and policy attention nowadays and are not adequately taken on board. Prevention works best when there is collaboration, cohesion, and consistency between actions on socioeconomic conditions, the built environment, and between public health, medical, and social systems to achieve the best health and social equity outcomes. To reduce the steep social gradient in cancer and other NCD-related health outcomes, a proportionate universalism approach is recommended. Actions must be universal, but with a scale and intensity that is proportionate to the level of disadvantage.
Action on primary prevention by addressing common causes of major NCDs, promoting enabling environments and multi-sectoral health protecting policies and legislation, along with due recognition of wider socio-economic determinants of health such as social fairness and environmental conditions have already led to substantial gains. But more can and should be done to encourage health systems reforms towards a more health-promoting and preventative approach than to-date, as well as to spend more (and better) than an average of 3% of health budgets on health promotion and disease prevention. As indicated, alignment across other European Commission's initiatives is key. Improvements can be made in terms of the indicators used to measure progress. Furthermore, the EU could consider exploring how its competences in fiscal, budgetary and economic policies could lend support to stronger health protection against commercial determinants of health.
Read full responseResponse to Final Evaluation Employment and Social Innovation programme (EaSI) 2014 - 2020
5 Nov 2019
EuroHealthNet is a not-for-profit partnership of organisations, agencies and statutory bodies working on public health, disease prevention, promoting health, and reducing inequalities. Our mission is to improve and sustain health between and within European States through action on the social determinants of health, and to tackle health inequalities.
EuroHealthNet and its members have directly benefitted from Employment and Social Innovation (EaSI) funding to promote social and health equity in Europe. Promoting social inclusion and protection, combating poverty and improving living and working conditions across Europe are central to our actions addressing health inequalities in Europe. Overall, EuroHealthNet has used EaSI support to act as a catalyst to spark and facilitate discussions within and between member states to translate recommendations from EU policy and EU-funded projects to national and regional level and to develop more concrete outcomes.
Thanks to EaSI funding, members and partners of EuroHealthNet have improved their knowledge of EU structures and mechanisms and increased their involvement in EU policy processes. This includes by providing input on the European Semester process and the implementation of the European Pillar of Social Rights as well as responding to public consultations on issues impacting health and social equity. EuroHealthNet has also provided assistance to its members on the matter of accessing EU funds. Thanks to EaSI support, EuroHealthNet could also carry out capacity building activities, enabling members to learn about projects in other countries and connect with people to develop new partnerships and exchange best practices.
While EaSI funding has proved essential to support our work on health inequalities to date, we believe that the EaSI funding has even greater potential to prioritise issues of social and health inequalities within and between EU Member States, in order to improve cohesion and wellbeing across the EU.
Although the EU as a whole is performing well in terms of growth and employability, there are still significant differences between countries, regions and population groups in who benefits from economic growth and employment. These uneven living and working conditions and unequal opportunities to access social and health services are major determinants of health and are resulting in increasing social and health inequalities. This represents a high cost for the society as a whole and undermines the productivity of EU citizens and the resilience of EU labour markets in times of crisis. So far, neither the Europe 2020 strategy target of lifting 20 million people out of poverty by 2020, nor significant reductions of inequalities in health have been achieved or maintained in Europe. With 70% of Europeans wanting the EU to do more on health, there is room for improvement and various EU funds, including the EaSI can help.
While there were some challenges around the disbursement of funds for 2019, EuroHealthNet is broadly satisfied with the Commission’s direct management of the programme. This ensures the proper use of the EaSI fund and close alignment with the Commission’s political priorities while facilitating access for recipients to speak with relevant Commission officials.
Read full responseResponse to European Partnership for innovative health
27 Aug 2019
EuroHealthNet is a European Partnership that aims to improve health, equity and wellbeing through action on the social determinants of health and health inequalities, disease prevention and health promotion. It is therefore a reference to these aspects of public health that we miss in the “Description of the problem the initiative aims to tackle”.
While it is true that the EU must deal with an ageing population and an increasing burden of disease, it is also highly important that a problem of health inequalities within and between EU Member States is addressed and prevented. By considering equity and social fairness, innovative health interventions can make a significant contribution to addressing the challenges identified in the proposal. If left unchecked, the transformative potential of digitalisation or innovations in the field of health may remain inaccessible or too costly to benefit all population groups. Better digital health literacy, broader R&I understanding of the structural causes of disease and paths that lead to better health and wellbeing, the continuum of care and life-course approach may offer a much needed change of R&I narrative. Preventative, people-centered and integrated care, addressing key determinants of health, should always constitute an integral part of the European Partnership on Innovative Health.
Health inequalities reduce economic and social productivity and lead to higher healthcare and welfare costs, a point we recommend recognising in the “Expected economic and social impacts” in part C. Evidence shows that in the EU, inequalities in health are estimated to cost €980 billion per year, or 9.4% of European GDP. A 50% reduction of gaps in life expectancy would provide monetised benefits to countries ranging from 0.3% to 4.3% of GDP. Furthermore, for every 1 EUR spent on health promotion, on average, 14 EUR is returned to the economy. Action on health inequalities and the promotion of health-enhancing environments in which people are born, live, work and age represent a good return on investment, can unlock untapped sustainable growth potential, and have strong public support.
The Horizon Europe programme, a basis of the proposed European Partnership, acknowledges that the health challenges faced by the EU cannot be addressed by health systems alone and that they are fundamentally interlinked, global in nature and require multidisciplinary, cross-sectoral and transnational collaboration. Yet, a “health in all policies” principle (Art. 168 TFEU) is clearly lacking from the legal basis of the Partnership proposal, as well as from its expected contribution towards the implementation of the UN SDGs Agenda.
Finally, since the Partnership would include support to public-private collaborations, it should address issues of privatisation, ethics, and commodification of health research results, services and products – potentially undermining efforts towards the Health for All and contributing to widening health inequalities in the EU and globally. Establishing good governance and transparency, cohesion and coordination needs careful consideration. It is essential to ensure a balanced approach towards use of public funds to address issues that concern the public, respond to wider societal needs, and promote scientific collaboration beyond 'traditional' top-down disease-oriented R&I. True partnership for innovative health would mean being non-exclusive of cross-sector and smaller public health stakeholders both at EU and Member State level.
Read full responseResponse to Proposal amending Regulation (EU) No 1303/2013
16 Apr 2019
EuroHealthNet’s contribution focuses on the impact of youth unemployment and exclusion on health outcomes. It highlights the need to address significant societal and economic costs for EU governments through prioritising long-term life-course investments, such as the Youth Employment Initiative. Health inequalities erode the professional development of young generations and their ability to contribute to society, undermine economic growth and prosperity, and increase health, social care and wider public expenditures.
The 2019 Joint Employment Report shows positive progress across the EU regarding the young NEETs, including the long-term unemployed or those not registered as job-seekers. However, very high rates of NEETs and considerable regional differences persist. Inactivity rates are particularly high in Bulgaria, Romania and Italy, while unemployment is predominant in Spain, Croatia and Greece. Having only low-level education has been identified as the main risk factor for being NEET.
The European Pillar of Social Rights highlights and strengthens the importance of youth inclusion, along with health, well-being, equity and sustainability, through a holistic approach towards the issue.
The exclusion of the young people from the labour market and the subsequent social exclusion are a concern, especially considering its major economic impact. This is likely to worsen when considering the increase of Europe’s ageing population. Moreover, even when NEETs do find jobs, these are more likely to be precarious and low-quality, therefore, being unable to fully contribute to society, hindering the ‘social fabric’ and long-term economic growth .
Youth unemployment and inactivity are not only an issue of public expenditure, but also of public health. All NEETs are at risk of marginalisation, exclusion and lower physical and psychological well-being. Unemployed people suffer from more from anxiety, depression, and psychosomatic symptoms, lower self-esteem, and poorer life satisfaction; moreover, they make significantly more visits to their physicians, take more medications, and spend more days in bed sick compared to those who are employed . The link between unemployment and poorer health is worsened by macroeconomic crises and weakened by inappropriate or insufficient governmental action and social interventions, as evidenced by the work of the WHO Commission on Social Determinants of Health.
Being NEET is associated with negative effects on health, especially on the longer term. Young NEETs are more likely to embrace bad lifestyles, with higher chances to have poor health later in life. Inequalities in the prevalence of being NEET are also considerably high, with higher chance of becoming NEET in relatively disadvantaged, from poor backgrounds, or lower education.
The additional amount of money allocated to YEI is a valuable opportunity to give tailored support to young NEETs from across Europe. EuroHealthNet welcomes the increase of funding as it would not only support the overall inclusion of young people in the labour market but also support the sustainability of healthcare systems and reduction of inequalities.
When designing and implementing programmes, applying a holistic integrated approach is key. Youth policies should be complementary to fields such as employment, education, training, health, culture, digital media, sustainable development, citizenship, and physical activities. In doing so, it is important to comprehend the diversities of young NEETs. General youth employment data is insufficient; it should be disaggregated and integrated to include health and social indicators. The EU Labour Force Survey offers restricted number of socio-demographic variables when calculating the NEET indicator. However, improving the data sample at European and national levels could create the missing link in understanding young NEET behaviours and vulnerabilities, helping to design more effective policy intervention.
Read full responseResponse to Evaluation of the support to social inclusion by the European Social Fund
16 Jan 2019
The European Social Fund (ESF) is a major financial instrument to help pursue the Europe 2020 strategy’s objectives for smart, sustainable and inclusive growth, building up a more social Europe, guided by the European Pillar of Social Rights, and in line with the European Semester. Well-functioning health systems across Europe are central to meeting the headline targets of this strategic vision, particularly those relating to employment, education and social inclusion performance. For EuroHealthNet, ESF represents a valuable instrument to reduce health inequalities between and within EU Member States and further boost investments in structural determinants of health, health promotion and disease prevention measures.
Income and wealth inequality, and the associated levels of health inequalities are persistent and growing in many EU countries. Most EU Member States systematically allocate more than the required 20% of the ESF national resources to promote “social inclusion, combating poverty and any discrimination”(1), showing more ambitious investments are needed to address common social challenges. Evidence from EU funded initiatives that EuroHealthNet has been involved in (ESIF for Health(2), Equity Action(3)) and feedback from our members reflect how ESF can be used to make an impact on social inclusion and the reduction of poverty through action in the areas of health and wellbeing. They reflect that ESF is applied across the EU on a range of initiatives that e.g. improve the provision and quality of health and social care, incl. health promoting services, and strengthen capacities within these systems to provide accessible and quality services, particularly for socially vulnerable people. In many cases, these measures also boost cooperation between health and other key sectors.
Only a fraction of ESF funds are however currently being spent on such actions, and more can be done to maximise the impact of ESF in these areas, and to society at large. More can for example be done to raise awareness amongst professionals in other keys sectors like health about the funds, and to build capacities to enable them to engage, both strategically and practically. Furthermore, the administrative burden of obtaining and administering the funds should be reduced, including for smaller (civil society) organisations that are nevertheless crucial service providers and economic actors. In addition, projects cannot just of themselves deliver systemic change; they must be part of a broader strategy that aims to do this. The EU and its MS must in this respect acknowledge that social policy, health policy, environmental policy and economic outcomes are tightly inter-related, and encourage the implementation of strategies and programmes that deliver co-benefits across sectors. MS must therefore be encouraged to combine the use of EU funds for greater impact, and to invest as much in people (services, capacity building, learning exchange, awareness) as in hard infrastructure projects, as Slovenia and Latvia (4) have done by combining EDRF and ESF to achieve national strategic objectives.
Looking to the future EU budget and its ESF+, we call on these to emphasise the need to address inequalities in our societies, with a focus on fairness, vulnerability and early years. Performance indicators should, in addition, be applied that are aligned to the Social Scoreboard and were possible the SDG indicators, and other reputable measures of equity and wellbeing (5).
References:
1. 1304/20130
2. Mc.Guinn J, Ganche M et al. ESIF for For Health. Investing for a healthy and inclusive EU. Milieu, 2018
3. Stegeman, I, Kuipers Y. Health Equity and Regional Development in the EU, Applying the EU Structural Funds, EuroHealthNet, 2013
4. EuroHealthNet Online Magazine, 2018 summer edition
5. A Healthy Budget? Analysis of the MFF 2021-27, EuroHealthNet, 2018
Read full responseMeeting with Florentine Hopmeier (Cabinet of Vice-President Jyrki Katainen) and European Association of Service providers for Persons with Disabilities and
22 Oct 2018 · Discussion on addressing social sector needs in the InvestEU Programme
Response to Multiannual Financial Framework: Internal Market, Competitiveness of SMEs and European Statistics Programme
6 Aug 2018
EuroHealthNet welcomes the proposal for the new EU Single Market Programme, aimed to enhance cohesion, competitiveness, productivity, and growth by strengthening the governance of the internal market, consumer rights protection and empowerment, while promoting human, animal and plant health. A well-functioning EU internal market, guided by principles of good governance and commitment to social equity, can advance rights, enable health and well-being of EU consumers. Wellbeing and cohesion are EU Treaty objectives, and EU citizens value their health as a priority . Therefore, it is essential to ensure EU internal market policies put population health on equal bases with economic and competitiveness considerations. The EU’s market focus on growth and jobs within the EU must aspire to inclusively benefit all EU citizens. Freedom of movement of goods (incl. medicines, medical devices, foods), people (incl. health workforce) and services has already benefited many, but also excluded others. With its specific focus on food, the new Programme can help improve access to and availability of high quality and sustainably produced food for consumers – ultimately advancing people’s health and well-being across a social gradient and life course.
EuroHealthNet believes that the EU Single Market Programme can reap the benefits of strong consumer protection, and an inclusive and health-promoting sustainable food production and consumption system. This success rests on important aspects that must be considered:
► Improving food systems’ sustainability and keeping up high standards on food safety: The EU Consumer Programmme has been successful in protecting the rights and health of European consumers, the environment, and making enforcements effective, efficient, and equitable according to programme evaluations. Maintaining high food safety standards can also improve the nutritional quality of the entire food supply chain, reduce contamination and control practices around supplementary foods for older infants and young children to ensure the health and nutrition of vulnerable population groups. The Programme can contribute to promotion of sustainable food production practices and consumption of health-promoting products.
► Empowerment of systems-embedded healthy choices: The proposal includes educational initiatives to make consumers aware of their rights and benefits of the EU Single Market. However, in order to promote healthy dietary practices as the easiest ones and address the increasing public health problem of diet-related non-communicable disease (NCD), choices should be facilitated by extended coherence with wider systems arrangements, including health-harming product regulations and duties (alcohol, HFSS foods ).
► Improving health cooperation in the EU and tackle inequality: The tool supports EU and its MS collaboration in areas related to determinants of health subject to EU internal market forces – goods, services and people. While recognising that better competition and choice has potential to improve health of individuals, its ‘unintended’ impact on aggravating health inequalities at population level should be considered. Currently, the EU internal market arrangements insufficiently address inequalities dimension in and among EU MS. The Programme’s boost for increasing digital transformation of the EU Single Market must also be inequality-proofed. Considering the substantial digital divide across the EU, digitalisation of public health services and initiatives – by means of e-health/m-health solutions - should be balanced with improved quality and access to ‘traditional’ preventative health services to be truly innovative and cost-effective.
► high-quality European statistics: The proposal calls for improved data reporting, including regional and local information, to encourage and strengthen quality evidence-based decision-making, which should be disaggregated with socio-economic indicators and equity-responsive.
Read full response26 Jul 2018
The following provides EuroHealthNet’s response to the proposals on establishing HorizonEurope and laying down the rules for participation and dissemination as well its Annexes setting out the Framework Programme on Research and Innovation.
Overall, we welcome the proposals and their premise that Horizon Europe must deliver on citizen’s priorities, boost productivity and competitiveness and is crucial for sustaining our socio-economic models and values and enabling solutions that address these challenges in a more systemic way. We commend the proposal’s strong focus on health within the Pillar II ‘Global Challenges and Industrial Competitiveness’, as a cluster and as a theme that appears in the other clusters, where actions will also impact strongly on health and health inequities. We are pleased that the proposal places the lack of sound health promotion and disease prevention, the rise of non-communicable diseases and the persistence of health inequalities at the top of the list of the major health challenges facing the EU. It also recognises that these complex challenges cannot be addressed by health systems alone and that they are interlinked, global in nature and require multidisciplinary, cross-sectoral and transnational collaborations. We also find the concept of ‘missions’ promising and trust that civil society representatives and end users will be adequately included in all relevant processes. However, we urge consideration for the following points:
► The link must be made between this and the cluster on ‘inclusive and secure society’, that aims to generate action leading to ‘social and economic transformation’.: The proposal, under the health cluster, calls for actions that `render health systems accessible, cost-effective, resilient, sustainable and trusted and designed to reduce health inequalities’. A key way of reorienting health systems and to make them more health promoting is to improve the awareness of leaders as well as of relevant professionals across sectors of the importance of taking holistic approaches for health and well-being for all, and to improve their capacities to deliver this.
► Social innovation is put on an equal footing to technological and industrial innovation: We would like to stress and see that a sufficient emphasis is put on the social dimension of health and well-being. We also hope to see a stronger prioritisation in the proposals objectives; the measures that are financed should first and foremost address health and social challenges in ways that subsequently boost productivity and competitiveness. Health technologies undoubtedly play an important role in strengthening health systems delivering health. Yet it is important to ensure that technologies support, but do not drive the development of health systems and thereby widen digital, social and health divides.
► Those designing and implementing HorizonEurope must prioritise measures that truly address core challenges in a systemic way: Health systems will not become more sustainable and they will not contribute to greater health equity through investments in expensive, person-centred technologies that simply redress problems generated at the systems level. The action area on food systems for example mentions ‘personalised nutrition especially for vulnerable groups, to mitigate the risk factors for diet-related and non-communicable diseases.’ While personalised medicine can certainly be important to improving individual well-being, it is more cost effective to focus on population-based approaches that make sustainably grown and nutritious food available to everyone.
► Budgets that have been proposed for the health strand under Horizon Europe do not reflect its high ambitions: We are concerned that the budget for health under the proposal is almost 1% lower than under Horizon2020. This is worrying, given that Horizon2020 was cut by more than €10 billion from the time of the proposal to its establishment.
Read full responseResponse to MFF: 9th Framework Programme for Research and Innovation and Rules for Participation and Dissemination
26 Jul 2018
The following provides EuroHealthNet’s response to the proposals on establishing HorizonEurope and laying down the rules for participation and dissemination as well its Annexes setting out the Framework Programme on Research and Innovation.
Overall, we welcome the proposals and their premise that Horizon Europe must deliver on citizen’s priorities, boost productivity and competitiveness and is crucial for sustaining our socio-economic models and values and enabling solutions that address these challenges in a more systemic way. We commend the proposal’s strong focus on health within the Pillar II ‘Global Challenges and Industrial Competitiveness’, as a cluster and as a theme that appears in the other clusters, where actions will also impact strongly on health and health inequities. We are pleased that the proposal places the lack of sound health promotion and disease prevention, the rise of non-communicable diseases and the persistence of health inequalities at the top of the list of the major health challenges facing the EU. It also recognises that these complex challenges cannot be addressed by health systems alone and that they are interlinked, global in nature and require multidisciplinary, cross-sectoral and transnational collaborations. We also find the concept of ‘missions’ promising and trust that civil society representatives and end users will be adequately included in all relevant processes. However, we urge consideration for the following points:
► The link must be made between this and the cluster on ‘inclusive and secure society’, that aims to generate action leading to ‘social and economic transformation’.: The proposal, under the health cluster, calls for actions that `render health systems accessible, cost-effective, resilient, sustainable and trusted and designed to reduce health inequalities’. A key way of reorienting health systems and to make them more health promoting is to improve the awareness of leaders as well as of relevant professionals across sectors of the importance of taking holistic approaches for health and well-being for all, and to improve their capacities to deliver this.
► Social innovation is put on an equal footing to technological and industrial innovation: We would like to stress and see that a sufficient emphasis is put on the social dimension of health and well-being. We also hope to see a stronger prioritisation in the proposals objectives; the measures that are financed should first and foremost address health and social challenges in ways that subsequently boost productivity and competitiveness. Health technologies undoubtedly play an important role in strengthening health systems delivering health. Yet it is important to ensure that technologies support, but do not drive the development of health systems and thereby widen digital, social and health divides.
► Those designing and implementing HorizonEurope must prioritise measures that truly address core challenges in a systemic way: Health systems will not become more sustainable and they will not contribute to greater health equity through investments in expensive, person-centred technologies that simply redress problems generated at the systems level. The action area on food systems for example mentions ‘personalised nutrition especially for vulnerable groups, to mitigate the risk factors for diet-related and non-communicable diseases.’ While personalised medicine can certainly be important to improving individual well-being, it is more cost effective to focus on population-based approaches that make sustainably grown and nutritious food available to everyone.
► Budgets that have been proposed for the health strand under Horizon Europe do not reflect its high ambitions: We are concerned that the budget for health under the proposal is almost 1% lower than under Horizon2020. This is worrying, given that Horizon2020 was cut by more than €10 billion from the time of the proposal to its establishment.
Read full responseResponse to Multiannual Financial Framework - AGRI Proposal (3/3) - Common Organisation of the Markets
25 Jul 2018
EuroHealthNet takes a note of the proposal for an Amending Regulation on the rules of the Common Organisation of the Markets in Agricultural Products, aimed to outline provisions related to certain sectoral interventions. EU financial support given to the EU farming sector takes a big slice of the EU budget and affects how and what kinds of agricultural goods are produced and consumed in the EU. It also impacts on environmental conditions, public health, health inequalities -and levels of poverty and social exclusion in the EU. To justify the use of public money in this area, it is important that spending guidelines are aligned with EU, national and local priorities in these other areas to ensure that these funds contribute to the well-being of EU citizens and people across the world.
While realising the limits of the CAP to improve public health outcomes on its own, the system of subsidies plays an important role in shaping the food demand-supply chain. It is important that EU funds for agricultural production are spent in ways that are coherent with our current understanding of public health needs. This would strengthen broader public support for the policy. To this end, the proposals must consider:
► EU agriculture and the CAP strategic plans at national level must align with state of the art public health evidence: A removal of tobacco subsidies in the last round of the CAP reforms was a big success for public health. It was a good sign of political will to fix some of inconsistencies between EU farming and health policies. Alcohol, meat and insufficient fruit and vegetables consumption as NCDs risk factors should also be addressed. Therefore, it is concerning to still observe sectoral support to other health-harming agricultural goods that this tool offers. Proposed allocation of more than 1 billion EURO between 2021-27 to 16 EU MS for wine production and promotion, continuous substantial funds to livestock and industrial crops production (150 billion EURO between 2017-2020) all but undermine Art.168 of TFEU, and contradicts the EU’s sustainability and public health goals.[1]
►The CAP should reward farmers that produce commodities that promote health and applying ecological and sustainable methods: The level of fruit and vegetable consumption in European countries falls short of the daily recommendations to maintain a healthy diet. Supported by the advice from the EU Strategy on Nutrition, Overweight and Obesity-related Health Issues, EU Childhood Obesity Action Plan and the WHO European Nutrition Action Plan, EU MS are committed to support the production and distribution of fruit and vegetables at various points along the farm-to-plate chain. This can be done through financial incentives to farmers to produce and public institutions to procure healthy and sustainable foods and for schemes that increase access for vulnerable groups.
► Next EU budget under the CAP should sufficiently pay for the EU aid for the supply of fruit and vegetables in educational establishments to contribute to closing the consumption gap: Considered a good practice that fosters collaboration between the education, health and agriculture sectors to improve the availability and affordability of fruits and vegetables, the EU School Fruit Scheme has been implemented across the EU to increase consumption levels and ultimately contribute to better health outcomes among children[2]. A planned cut in annual spending (down to €130 million per year) for this scheme is discouraged, as it may overturn and dismisse its health- and equity-promoting return on investment that has only started showing its value.
[1] Expert Review on Agricultural and Food Supply, from Transforming Food and Drink Policies for Cardiovascular health (2017)
http://www.ehnheart.org/publications-and-papers/publications.html
[2] https://ec.europa.eu/agriculture/sites/agriculture/files/evaluation/market-and-income-reports/2012/school-fruit-scheme/synt_sum_en.pdf
Read full responseResponse to Multiannual Financial Framework: Establishiment of the European Solidarity Corps programme
25 Jul 2018
EuroHealthNet welcomes the proposed fund to support the European Solidarity Corps (ESC), but important considerations are necessary to take into account.
The ESC will create opportunities for young people aged between 17 and 30 to support communities and people in need through work or volunteering and has the potential to improve health and well-being. Whilst opportunities exist, the implementation of the scheme needs to be carefully managed to ensure it is equitable and gives tangible benefits. The promotion of health and health equity is inextricably linked to the notion of solidarity. It requires collaboration with those less able to reach good levels of health and wellbeing, and partnership with young people in designing engagements. Health and social work are fields in which young people, with a wide range of backgrounds and skills, can provide valuable support in both care and prevention; not all roles in the health sector require specific medical training. This type of work not only develops solidarity with those in need, but will equip young people with skills which will help them into employment. Many people in the ESC target age range have many skills that can be contributed alongside learning gains including creativity, initiative, innovation, adaptabilities and IT-literacy. However, genuine equal opportunities for all should be guaranteed or inequalities will be exacerbated.
► The programme should not be cut from otherwise good and effective projects, such as Employment and Social Investment (EaSI) and the Erasmus+ programme. The recent MFF proposals indicate an increased imbalanced attention to Erasmus+ and the Solidarity Corps vis-à-vis the Employment and Social Investment (EaSI) and the Health Programme, which also play important roles in achieving similar objectives e.g. social inclusion through employment and skills development.
►The ESC should not become an ‘elite club’ where only the best university students are picked as volunteers or interns for career progression, while others are abused to substitute volunteering for employment. In addition, the Corps should avoid fuelling the ‘Generation Intern’ debate which is associated with social dumping problematics and low levels of qualification and career development.
►The specific focus is to build EU solidarity. Addressing poverty and social inclusion should be a key priority both in the training, treatment and in the work of the volunteers. To avoid overlaps with the existing EU Programmes, such as Erasmus +, Youth Guarantee, etc., the Corps should work in new fields and with clear engagement of local communities. The EVS and the ESC overlap: there is a need for a clearer distinction or collaboration.
►The ESC should take care not to abuse young people. The Programme may grant valuable new and exciting opportunities to young people and could help to alleviate the suffering of many Europeans. It cannot, however, replace work or allow organisations to offer low-quality working and living conditions, nor should it be perceived to be doing so by those already facing financial and work insecurity.
►The ESC will require alignment of national intern and volunteering laws in order to be effective, plus significant opportunities for cross-border placements where an ESC participant could enjoy placement within several Member States, helping to foster European values, language skills and dialogues, cultural understanding and strengthen the social fabric of the EU.
Read full responseResponse to Multiannual Financial Framework-Draft legislative proposal on the InvestEU Programme and EFSI evaluation SWD
25 Jul 2018
EuroHealthNet welcomes the proposed InvestEU Programme and EFSI evaluation. This is a promising initiative, now comprising a dedicated window on social investment and skills, including health, education and housing, with potential to help reduce inequalities and stimulate appropriate leadership from investors and health stakeholders. The 4 billion EUR assigned, and the budget to support capacity-building and locally-oriented technical assistance, are welcome. The desire to connect public and private finance is cautiously welcomed, if carefully monitored. The successful implementation of this endeavor necessitates the full involvement of the relevant public stakeholders as well as civil society. The InvestEU represents an opportunity for the EU to foreground social measures, including health promotion and facilitate sustainable funding to reduce health inequalities. It must not reduce the public responsibility of state authorities to sufficiently fund social sectors.
► A “health in all finances” agenda through integrated governance would help to fully embed health benefits throughout decision making: The need for new and innovative financial impetus for reducing health inequalities is clear. The High-Level Task-Force on Investing in Social Infrastructure in Europe concluded that the investment gap in social infrastructure and services has reached EUR 150 billion[1], while the cost of chronic disease is estimated for EU economies at 115 billion EUR or 0.8% of GDP annually.[2] However, a recent systematic review found that for every 1 EUR spent on health promotion 14 EUR was returned to the economy[3]. Integrated approaches are the most efficient way to address social, economic, and environmental determinants of health and inequalities. Smart EU investment on social, health, and research programmes and funds should be linked to achieving the Sustainable Development Goals and implementing the EU Pillar of Social Rights[4] (EPSR) that include social investments, health, and support for the EPSR offers potentially improved opportunities for coherent, connected work, on the ground in Member States and communities. The InvestEU has promising potential if a “health in all policies” approach is incorporated; but funding should be linked to outcomes and have strategic health promotion orientated aims.
► Sustainable finance is key for health improvements: A key concern is the issue of sustainability of projects and results. There is a clear need to maintain access to different types of funding and different sources of funding for health promotion. This goes hand in hand with the need to maintain connections with all stakeholders, authorities, and ministries. At present, the project focused requirements of funds are a good mechanism to get health promotion initiatives developed and started. However, this ultimately creates a strict and short timescale to deliver recognisable results. The ‘life-span’ of the funding needs to be radically re-thought. The InvestEU should initiate this by envisioning sustainable long-term health promotion measures. This will create a clear European added value beyond national capacities.
Sources:
[1] Fransen, L. et al (2018) Boosting Investment in Social Infrastructure in Europe: Report of the High-Level Task Force on Investing in Social Infrastructure in Europe (doi:10.2765/794497/Discussion Paper 074).
[2] OECD/EU. (2016). Health at a Glance: Europe 2016: State of Health in the EU Cycle.
[3] Masters, R. et al (2017), Return on investment of public health interventions: a systematic review, Journal of Epidemiology & Community Health (DOI: 10.1136/jech-2016-208141).
[4] Dyakova, M et al (2017) Investment for health and well-being: a review of the social return on investment from public health policies to support implementing the Sustainable Development Goals by building on Health 2020. (9789289052597/WHO Regional Office for Europe).
Read full responseResponse to Multiannual Financial Framework: Digital Europe programme
25 Jul 2018
With caveats, EuroHealthNet welcomes the initiative on the establishment of the Digital Europe Programme (DEP), which sets out to support the digital transformation of the European society and economy and bring its benefits to European citizens and businesses. It sets out to match the Digital Single Market Strategy’s robust framework with “an equally robust investment programme” (proposal, p. 2).
Digital technologies do offer new opportunities to transform health and care systems, including new approaches to personalised prevention and promotion, treatments and care, independent living, integrated health and social care, accelerated scientific progress for early diagnosis and prevention of diseases. However, there are significant risks and obstacles of inequitable implementation including safety, access, effectiveness and authority. Caveats include:
►Artificial Intelligence (AI) – precaution:
AI can be an effective support for health and care services, yet should not replace human inputs, which are necessary for best possible health (particularly mental health) and wellbeing. EuroHealthNet has serious reservations towards risks of the too rapid creation of “a Common European Data space…open to public and private sector.” (Annex 1, p. 1). Digital health is characterised by many global and non-health actors where motivations behind innovations are often related to profit rather than public health impacts [1]. Effective, accountable safeguards for individual privacy are essential: until that is transparently guaranteed, EuroHealthNet advises precautionary approaches for access to public data spaces, health and social impact assessments, and greater use of health and equity knowledge into design and implementation policies at all levels.
►Cybersecurity and trust – holism:
The attention to cybersecurity and building trust is welcome; it is crucial to ensure protection of personal data, cross-border health protection rights and access. A holistic view is needed towards cybersecurity: like a chain, it is no stronger than the weakest link. Therefore, the element of the proposal to involve co-investment with Member States may involve significant drawbacks co-investment may vary effectiveness, widen gaps between States and regions and heighten risks of and sustainability in terms of commitment.
►Advanced digital skills – literacy:
Digitising the public sphere, including the health and care sector, risks widening health inequalities by limiting access to health systems and to society, especially older people, viz. among the 20% of citizens not digitally literate even by the most optimistic forecasts. It is important to look beyond the immediate digital skills as referenced in the proposal (AI, cybersecurity etc.) to consider the public need for improved health literacy, including digital skills, which will reduce health inequalities. EuroHealthNet regrets that the EC Communication on the ‘Transformation of Health and Care in the Digital Single Market’ has not mentioned digital nor health literacy, and we call on EU Institutions to prioritise this. Accordingly, the indicators for this pillar should better reflect literacy capacities and access factors, taking age and socio-economic backgrounds into account.
►Interoperability and digitising the public sector – accessibility:
The proposal calls for “Ensur[ing] that EU citizens can access, share, use, and manage their personal health data securely across borders irrespective of their location or the location of their data” (Annex 1, p. 3). To ensure appreciate uptake of digital services, accessibility should be placed at the centre. Accordingly, accessibility should not only be seen in terms of remoteness but also socio-economic conditions capacities or capabilities, and generational preconditions.
[1] EuroHealthNet Policy Précis on mHealth: https://eurohealthnet.eu/sites/eurohealthnet.eu/files/publications/PP_mHealth_web_version.pdf
Read full responseResponse to Multiannual Financial Framework - CAP Strategic Plans
25 Jul 2018
EuroHealthNet takes a note of the proposal for a Regulation on the rules of the Common Agricultural Policy’s Strategic Plans financed by the European Agricultural Guarantee Fund (EAGF) and the European Agricultural Fund for Rural Development (EAFRD). EU financial support given to the EU farming sector takes a big slice of the EU budget and affects how and what kinds of agricultural goods are produced and consumed in the EU. It also impacts on environmental conditions, public health and inequalities herein, and levels of poverty and social exclusion in the EU. To justify the use of public money in this area, it is crucial to align EU spending guidelines with national and local priorities in other areas to ensure these funds contribute to overall population well-being.
“Unravelling the Food-Health Nexus” report by the International Panel of Experts on Sustainable Food Systems concluded that substantial changes in European (and increasingly interlinked global) food systems over the last decades have resulted in profound negative impacts on public health and well-being. These range from food insecurity to diet-related chronic and non-communicable diseases, and from environmental pollution/degradation to poorer economic opportunity for rural communities, decline of livelihoods and depopulation of rural areas. These impacts are experienced unequally across the EU, between and within the MS, and between different population groups.
EuroHealthNet therefore calls for the following measures to improve the alignment between the EU’s objectives and strategies in farming and rural development and those in the area of the environment, social policy and health:
► Encourage targeted support to small and family farms and less developed areas to strengthen the socio-economic fabric of rural livelihoods as well as more sustainable food production and consumption: An EU common framework should broadly guide national, regional and local level authorities to analyse their local circumstances and allocate funds in ways that foster sustainable development. This means that funds should promote ecological approaches as well as social inclusion, fight poverty and deprivation in rural areas, and ensure access to sufficient, safe, nutritious, and quality food always, based on current public health evidence.
► Strengthen conditionality criteria on socio-economic conditions, environmental and climate change factors, and public health EU agriculture sector’s obligations under conditionality criteria and list of indicators outlined in Annex I of the CAP Strategic Plans Regulation should better reflect food systems’ impact on health and social equity outcomes. Compliance with higher sustainability standards on environment/climate protection, prudent use of antibiotics in food production, ensuring bio- and diet-diversity should be better regulated and enforced, since the links between these areas and farming are well established.
► EU farming and rural development policy and strategies should further support locally-led development strategies, empower local authorities and relevant civil society actors in the programming and management of the funds: This should be extended to providing support and building capacity of the civil society, local authorities and relevant bodies responsible for promoting social inclusion, fundamental rights, gender equality and non-discrimination principles to meaningfully engage and systematically incorporate health and social equity aspects in the design and implementation, collaboration and advocacy along the food systems-rural development-health nexus.
Read full responseResponse to Common provisions on the ERDF, the ESF+, the CF, the EAFRD, the EMFF and AMIF, ISF and IBM
25 Jul 2018
EuroHealthNet notes the Common Provisions Regulation (CPR) related to the ERDF, the ESF+ and the CF. We welcome aims to simplify, assure predictability and flexibility for funds’ beneficiaries. This CPR will not be applicable to the ESF+ EaSI and Health strands, as they are to be regulated through a mix of other Funds-specific mechanisms.
EuroHealthNet believes that rules and guidelines outlined in the CPR can benefit the programmes’ design and delivery, through better focus on health and social equity and preventative approaches advancement. This success rests on important aspects that should be implemented:
► Promote horizontal principles on eliminating inequalities and non-discrimination, promoting gender equality, accessibility for persons with disabilities in all CPR MFF regulations. Use funds to advance, not undermine all human rights: the principle should guide the preparation and implementation of the programmes. The Funds should not support actions that contribute to any form of segregation, including in health and social services.
►More ambitious objectives of the Funds committed to reducing inequalities and advancing social inclusion: the objectives of the Funds should be pursued in the framework of sustainable and integrated development, implementing the European Pillar of Social Rights, including through regional, local and community-led local development initiatives. This would ensure equal representation of socio-economic interests, networks and innovation in local contexts. A smarter Europe benefits from social and health research and innovation for health equity and preventative approaches. A greener Europe invests in anti-pollution measures of sound health and social impact. A more connected Europe transitions to smart public and active transport infrastructures. A more social Europe should invest in people and communities they live in, social and health infrastructure that improves health equity and prevents diseases. This should be extended to providing support and building capacity of civil society and sub national authorities working with marginalised communities and in the field of health inequalities.
► Strong emphasis on shared management and partnership: the principle of partnership builds on the multi-level governance approach and offers space for the involvement of civil society and social partners, regional, local, urban and public authorities promoting health equity and social inclusion. Diverging from increasing national co-financing, multi-stakeholder and cross-sector participation offers better sustainability and ownership prospects.
► enabling conditions and national co-financing: from a public health perspective it will be essential for EU MS implementing interventions prioritised under the ERDF, the ESF+ and the CF to be integrated and aligned with national strategic policy frameworks for social inclusion and poverty reduction, and strategic policy frameworks for health, where health equity, preventative and inter-sectoral approaches are central. Investment in and capacity building to strengthen enabling policy and good governance conditions should be ensured. Negative effects of financial, and economic crises on EU MS public spending in areas vital to social and economic determinants of health are still felt by many. Economic recovery has not yet benefited all socio-economic groups and regions. Therefore, the CPR returning co-financing rates to previous levels with a 70% cap for less developed regions is inadequate. It risks reversing essential investment levels in underdeveloped areas, excluding public bodies and organisations not able to meet the co-financing contribution from applying for the Funds.
Read full responseResponse to Legislative proposals for ERDF/CF, ETC (Interreg) and ECBC
25 Jul 2018
EuroHealthNet welcomes the proposal for the European Regional Development Fund (ERDF) and the Cohesion Fund (CF) to continue investments in reducing regional disparities and underdevelopment across Europe, respecting the principles of the European Pillar of Social Rights (EPSR).
Latest Eurostat evidence: “regional GDP per capita ranges from 29 to 611% of EU average” is unacceptable, also resonating in large implications for health and well-being. New ERDF/CF can benefit less developed regions, marginalised communities and disadvantaged groups by focusing on contributing to a more social and healthier, greener and interconnected Europe by promoting social inclusion, combating poverty and inequality. Applying a health fairness, sustainability and preventative approach in doing so is critical. To this end, the proposals must consider the following points:
► Proposal to put only 35% of ERDF and 15% of CF to objectives of a more inclusive, connected and sustainable Europe falls short of the EU’s ambition of addressing regional and local needs, and the development’s gaps, including in health and well-being: The objectives of the Funds must be pursued in sustainable and integrated ways, implementing the EPSR, and through community-led local development initiatives. Significant differences in health outcomes due to regional and local factors are best addressed closest to where people live (e.g. decentralised air pollution measures, access to quality preventative health services or safe/clean multimodal mobility). As a result, in many regions the ERDF/CF are a critical tool to ‘close the health gap’ by direct co-investments in community-based primary health, care and research facilities, strategic workforce, active transport infrastructure or sustainable local food supply.
► Promote horizontal principle on eliminating inequalities and non-discrimination, gender equality, accessibility for persons with disabilities through CSR and all Funds specific regulations: The principle should guide the preparation and implementation of the programmes. The ERDF/CF such as the proposed European Urban Infrastructure should not support actions that contribute to any form of segregation, including in health and social services; cross-sector collaboration should be promoted to ensure maximum level of coherence and good governance.
► “Beyond-GDP approach” to the funds’ allocation and possibility to combine funds: Extending criteria for the allocation of the funds beyond GDP per capita model will better capture local demographic and deprivation needs. To this end, the proposed performance, output and result indicators should be reviewed, respecting the EPSR’s principles, supported with the Social Scoreboard and the ECHI indicators.
► Regions must have a say in the Semester: Regions must be involved throughout the Semester process with clearly defined national-regional responsibilities and independence. The extent to how best reap benefits of linking the Funds with implementation of the Semester’s recommendations would need further debate as health equity, multi-level authorities’ and civil society’s capacity to meaningfully engage in these processes are still poor or non-existent.
► Cohesion Policy should further support locally-led development strategies and empower local authorities in the management of the funds.: This should be extended to providing support and building capacity of the civil society, public health professionals and local authorities to monitor and systematically incorporate health and social equity in the design and implementation, collaboration and advocacy around the Funds.
► Align the ERDF and the CF budgetary allocations with wider disinvestment approach to the tobacco and fossil fuels industries, and the global Agenda 2030 for Sustainable Development: Any subsidies to health-harmful initiatives within the EU would be against other EU and international commitments, health strategies and public health targets.
Read full responseResponse to Multiannual Financial Framework – European Social Fund Plus (ESF+)
25 Jul 2018
EuroHealthNet welcomes the initiative on the establishment of the new European Social Fund+, guided by the Social Pillar. The wider social determinants – the conditions in which we born, grow, live and work – play a crucial role for people’s health and well-being. Health is highly valued among EU citizens; therefore, it is important to reduce unjust and avoidable health inequalities experienced within and between EU MS. Investing in people and their well-being, across the social gradient and life course, quality and integrated systems that promote health and prevent diseases offers multiple benefits.
Under the right conditions, the ESF+ can lead coherent address of key social determinants of health and a more preventative health systems framework. This success rests on key factors:
►Address inequalities by focusing on social gradients: The proposal to merge several funds into one tool promises to amplify the impact of ‘investing in people and social cohesion’, with support for implementation of the Social Pillar and the European Semester. It is encouraging to see the ESF+ prioritising equal opportunities for all, tackling discrimination and addressing inequalities, including in health long-term and community-based services. Focus should not only be on vulnerability but extend to level up the socio-economic gradient.
►Leverage resources needed for the future of good health but clarify details on principles, methodology and transparency in partnerships: From a “health in all policies” approach, the ESF+ rightly recognises added value of EU cooperation on health and social policies for addressing health determinants, building synergies with other sectors and complimentary EU Programmes. Investing in people’s health constitutes an important pre-condition for advancing economic and social resilience and upward social convergence. Integrated, sustainable multisectoral actions can unlock additional opportunities for multiple gains, but transparent evidence across communities is vital. To this end, combining it with ERDF/CF and other relevant funds needs to be enabled.
►Propose concrete governance structures for new EaSI and Health strands: Public health interventions proposed lack details and concretisation necessary to assess potential impact. It is yet to be seen what adequate governance structure is there to ensure strategic guidelines and technical assistance - in terms of human and financial resources, as well as coordination and leadership. While annual investment overall may remain stable, both strands face real cuts (6-8%[1]) putting into question their tangible and timely impact.[2] Adequate, realistic levels of funding, balanced by reducing outdated funding of health-harmful measures, will be needed.
►Clarify what scope the ESF+ will give to supporting integrated work and implementation of good practices in areas of more preventative, structural, systemic and social innovations in public health: The ESF+ intention to “mainstream effective preventative models… and solutions to contribute to innovative, efficient and sustainable health systems” is welcome. However, clearer assessments of how those solutions would reduce health and social inequalities, and go beyond individual approaches, are crucial. A recent systematic review of public health return on investment to health systems and societies demonstrates that public health interventions are highly cost-saving (14.3 to 1[3]), by focusing on health promotion and prevention, wider determinants of health and change to legislative environments.
►Align ESF+ Performance Indicators with the Social Scoreboard, strongly linked to the EU Semester: The Scoreboard’s areas of equal opportunities, social protection and inclusion are crucial, especially related to living conditions and poverty (incl. in-work), early childhood development health and care (incl. promotion and prevention), and public policy impacts on reducing poverty and inequalities (incl. health).
Read full responseResponse to Multiannual Financial Framework: Rights and Values programme 2021-2027
25 Jul 2018
EuroHealthNet welcomes the proposed Rights and Values Programme aimed to fund actions to protect and promote rights and values as enshrined in the EU Treaties. The concepts of equality, non-discrimination and human rights are at the heart of EuroHealthNets work. Article 2 of the TEU stipulates that human dignity, freedom, equality, and respect for human rights, tolerance, and solidarity are values on which the Union is founded. Article 3 further specifies that the “Union’s aim is to promote … wellbeing of its people”. EuroHealthNet’s mission, namely to help build healthier communities and tackle health inequalities within and between European Member States is rooted in these aims and values.
Differences in the conditions in which people are born, grow, live, work and age give rise to inequalities in health. The more favourable a person’s social circumstances in terms of e.g. income or education level, the better their chance of enjoying good health and a longer life, leading to a ‘social gradient in health’ that can be observed in all countries with the relevant data. Health inequities are preventable and therefore unjust. Health is an enabler of social and economic participation in daily life, the “motor” behind our economies, and a key determinant of a person’s well-being, happiness and satisfaction[1]. It is therefore imperative to tackle the key underlying factors that undermine people’s right to good health, like lower resource and income levels, education levels, lack of social and family support, an unhealthy living environment and limited access to preventative care [2].
A wide range of decisions and actions taken across sectors, at different levels of government, shape the conditions in which people find themselves. Through initiatives funded through e.g. the EU EaSI, Health and Research Programmes, EuroHealthNet brings together and contributes to the evidence base on what works to reduce health inequities, thereby also supporting the objectives and priorities of the Rights and Values Programme.
PRIORITISE ACTIONS FOR THOSE IN GREATEST NEED:
A key approach to strengthening all EU citizen’s right to health and to reducing health inequalities is the application of the ‘principle of proportionate universalism’ to ensure that universal services are resourced and delivered at a scale and intensity proportionate to the degree of need. The Rights and Values Programme should therefore contribute to encouraging governments to apply this principle. The Programme should also encourage actions that improve conditions in early childhood, since health inequities often manifest themselves in early life and have adverse life-long consequences.[3] It should, furthermore, focus on tackling discrimination. Many groups, like LGBTI people[4], people with mental health conditions[5], marginalised and socially excluded groups (for instance migrants[6], young NEET people[7], older people [8] etc.) face high levels of explicit and implicit discrimination, with grave consequences to their health.
The Rights and Values Programme offers a welcome opportunity to redress injustice, through investments that can tackle harmful cultural and social norms, discrimination, stigma and other barriers to good health and wellbeing. It can help the EU profile itself as a global leader. To have a real impact however, it is vital that the provisions of the Programme are also integrated in key EU policies and programmes like ESF+, Horizon Europe and InvestEU, and not least those linked to the implementation of the European Pillar of Social Rights and the UN Sustainable Development Goals.
Please find the sources in the attachment.
Read full response25 Jul 2018
EuroHealthNet welcomes the proposal for the development of the Reform Support Programme (RSP) with its aim to enhance cohesion, competitiveness, productivity, growth, and employment by offering technical and financial support for national reforms that are closely linked with the European Semester.
Structural reforms at national levels can be mutually beneficial for both Member States (MS) and the EU. Upwards economic and social convergence through inclusive growth across the EU has a positive impact on citizens’ health and wellbeing. The wider social determinants of health – the conditions in which people are born, grow, work, live – play an immense role for people’s wellbeing, a Treaty objective. It is important to reduce unjust and avoidable health inequalities experienced both within and between EU MS. The Semester is an important mechanism to address the commonly identified needs of MS. Crucially, it now better incorporates the new EU Pillar of Social Rights, which we strongly welcome. However, the European Semester has yet to be fully inclusive and equitable; it faces barriers including sustainable political and systematic ownership of reform planning and implementation, lack of administrative capacity and financial resources to achieve the country specific recommendations (CSRs).
EuroHealthNet believes that under the right conditions the RSP can help to achieve the objectives of the European Semester for the benefit of people. This success rests on important aspects that must be considered:
►Avoid silo-thinking: It is positive to see that RSP is intended to “address all the key economic and societal areas [including]… services and labour, education and training, sustainable development, public health and social welfare”. But such policies and programmes are closely interdependent. The RSP should stimulate and support reforms with an integrated approach. This not only refers to the integrated planning between policy sectors (e.g. social, health, economic and fiscal policies) but also refers to the added-value of a whole of government, whole of society approach.[1]
►Address health related implementation deficits: It is necessary to increase efforts to support implementation of CSRs. The EC 2018 Communication on the Country Specific Recommendations [2] demonstrated that: Long-term care and health recommendations were found to be the least implemented areas over the years of the European Semester.
►Few and consistent recommendations: EuroHealthNet’s recommendations from our European Semester Analysis 2016[3] and 2017[4] show why it is important to address targeted attention to fewer, more consistent structural challenges and recognise that sustainable implementation and evaluation is often a long-term process.
►Differences in MS capacity: The RSP should maximise effective impacts but minimise administrative burdens and obstacles. The capacity to cope with extra administration differs greatly across MS and should be considered in planning for levelling up and support.
►Use learning across the EU, but respect diversities: Our analyses of annual EU Semester processes and the design of the EPSR shows that, for public health and social equity, cooperation is valuable but diversities should be respected for effective implementation of structural reforms. The Convergence Facility has an important role to help level up and address structural challenges in MS within or committed to joining the Eurozone. But creating a cleavage between the Convergence Facility, the Reform Delivery Tool and Technical Support Instrument (which pertain to all EU MS) should be avoided.
►Use a diverse range of experts: to avoid silo thinking and make sure RSP uses the best of “the old” and the new innovative approaches, RSP should diversify the experts used across disciplines and implementation side, not only health care, but also public health and health promotion specialists.
Sources in attachment.
Read full responseResponse to Multiannual Financial Framework: Erasmus Programme 2021-2027
25 Jul 2018
EuroHealthNet welcomes the proposed Erasmus Programme, particularly its objective “to support the educational, professional and personal development of people in education, training, youth and sports … thereby contributing to sustainable growth, jobs, and social cohesion” (Proposal, Art. 3). The Erasmus Programme can play a valuable role in reducing unfair and unjust health inequalities by reducing social and economic exclusion and encourage physical activity measures. Social inclusion is especially addressed in the proposal’s plan to “…improve outreach to learners with fewer opportunities” (Proposal, p. 2).
It is well-documented that the individual and societal costs of exclusion, particularly for younger people are high. Young people who are not in employment, education nor training, ‘Young NEETs’ are unable to fully contribute to society, and this puts the ‘social fabric’ and long term-economic growth in question.[ ] In light of Europe’s ageing population, a lack of young people in the labour market and the associated social exclusion is a concern.[ ] Youth unemployment and inactivity is not only an issue of national expenditure, but also of public health. People who are NEETs are at risk of marginalisation, exclusion, and lower wellbeing.[ ] Unemployed people experience lower psychological well-being than employed people. They suffer more from anxiety, depression, psychosomatic symptoms, lower self-esteem, and poorer life satisfaction.[ ] Unemployed people make significantly more visits to their physicians, take more medication, and spend more days in bed sick compared to those who are employed.[ ] Digital transformation of societies and economies offers new opportunities, but also new risks. These should be better emphasised in the proposal.
EuroHealthNet welcomes the opportunity the Erasmus Programme can play to support people in vulnerable situations, to reduce social exclusion and thereby health inequalities. However, consider the following:
►Caution of abuse of vulnerable people: One of the three specific objectives is to “promote learning mobility of individuals” which refers to “study, training, non-formal and informal learning” (Proposal, Art 2). “Informal learning” is defined as “learning resulting from daily activities and experiences which is not organised or structured in terms of objectives, time or learning support. It may be unintentional from their learner’s perspective” (Proposal, Art 2). The clear purpose must be measurable vocational development which can benefit the learner and trainer, not abuse of people, especially younger NEETs, through low quality and unpaid work, or poor work/life balances. This is important in health and social care systems.
►Find the balance between quality and quantity: “The goal is to triple the number of participants while at the same time introducing qualitative measures and incentives that would allow to improve outreach to learners with fewer opportunities.“ (Proposal, p. 2). While the goal is welcome, it could dilute impacts. The aim should be proportionate universalism: access for all but smart targeting for the least advantaged. The risk diversification level of boosting the Erasmus Programme is very low. This is critical as socio-economic and health equity is best addressed through a lifecycle approach, not one single stage in life. In the coming transformative period, whole life adaptation and reskilling opportunities will be essential.
►Recognise the life cycle approach: While the Programme could better address concerns connected to health inequalities and social exclusion, it should enhance, not reduce other effective programmes building on the EaSI and Health Programmes in ESF+. The proposal to more than double the size of Erasmus+ is imbalanced; it disproportionately favours the Erasmus Programme’s capacity e.g. the EaSI Programme also addresses similar goals to reduce social exclusion through employment and skills-development.
Sources attached
Read full responseResponse to Quality in Early Childhood Education and Care
16 Apr 2018
EuroHealthNet welcomes the initiative of a future Recommendation on Quality in Early Childhood Education and Care (QECEC). This feedback builds upon the health equity implications of QECEC and the related positive and negative consequences. Health inequalities (HI) reduce people’s ability to contribute to society, and undermine economic growth and prosperity. They increase health, social care, and wider public expenditures.
FINDINGS OF THE LINK BETWEEN QECEC & HEALTH EQUITY
In 2016, more than one in four (26.4 %) children in the EU28 countries were at the risk of poverty or social exclusion[1]. In all European societies, for every step down the socio-economic ladder, children and young people experience a higher level of a wide range of physical and mental health problems that will also affect their future health and life opportunities. This is not only related to access and quality of health services, but to the broader conditions in which they live, learn, and grow[2]. There is clear evidence that access to high-quality health care, together with effective health promotion, disease prevention, and social protection policies can help reduce health inequalities, social exclusion, and poverty[3]. It is essential to address the root causes of these wider social determinants from a holistic, integrated approach in order to sustainably tackle the challenges described in the QECEC Roadmap.
The foundations for emotional, intellectual, and physical development are laid early in life. The environment a child lives in, from the prenatal period through early childhood, can have a profound influence in later life[4]. Socio-economic status is a significant factor in children’s health and wellbeing[5]. Research findings have shown that children who have low cognitive scores at 22 months but grow up in families of high socioeconomic conditions improve their relative scores as they approach the age of 10; however children with high scores at 22 months who grow up in families of low socioeconomic position worsen as they approach age 10[6]. To level up the health gradient among mothers, particularly those in low income groups, it is important to activate labour markets and expand the provision of quality early child education and care programmes. These provisions should be accessible and affordable for all[7]. Timely access to health care can increase workforce productivity, support people to actively participate in society, and can avoid higher costs for health care in the long run[8].
POLICY RECOMMENDATIONS
►The QECEC Recommendation should make a clear connection to health equity and wellbeing over the life course.
►The QECEC Recommendation should promote the investment in early years to support good quality early years education and childcare provided in a proportionate way across the social gradient[9]. Support for families should be improved by investing in pre- and post-natal interventions, encouraging parental leave, ensuring the income for a decent life, as well as through parenting programmes and children’s centres including outreach interventions to identify the most vulnerable and provide targeted support.
►Use the European Regional Development Fund and European Social Fund to implement early child health and development interventions in areas of social deprivation.
►Foster the implementation of the EC Recommendation on Investing in Children, which calls on MS to support parents into paid work and improve access to affordable early year’s childcare, education, and healthcare.
►Connect the initiative to the EU Semester (Country Specific Recommendations, National Reform Programmes, and the Social Scoreboard, in the latter is it necessary to broaden the use of indicators to children at the risk of poverty and social exclusion).
►Connect the initiative to the European Pillar of Social Rights (Principle 11: Childcare & Support to Children; the Social Scoreboard; the Work-Life Balance Directive).
Sources in attachment
Read full responseResponse to Strengthened cooperation against vaccine preventable diseases
21 Dec 2017
Vaccination is saving millions of people from illness, disability and death each year. It is one of the most cost-effective public health interventions available. There is a continuous need for effective and safe vaccines to protect people against many serious diseases.
In the 21st century, every child has the right to live free from vaccine-preventable diseases (WHO Europe recommendation ). Consequently, strengthening immunization remains vital. More than ever it is important to fully acknowledge the success of immunization in the past decades and to support investments to sustain this success and advance to new vaccine development, while improving the quality and safety of existing ones.
EuroHealthNet welcomes this initiative of the European Commission. There is a clear EU added value in this action, with several issues requiring a more coordinated and integrated way:
- Address the needs and fulfil the rights to health of the underserved; existing differences between Member States in commitment, investment and outreach programmes is increasing the level of health inequalities with increased under-coverage for those marginalised, migrant or socially disadvantaged children and families;
- Address the complex interplay of social, gender and economic marginalisation, and access to vaccinations in groups such as the Roma community, Irish Travellers, isolated immigrant communities and those in lower socio-economic groups. These groups are already at disproportionate risk from illnesses such as influenza and generally have low health literacy.
- Better alignment of policies, surveillance for socio-economic groups, investment and vaccination schedules, also considering the free movement of citizens and open borders; and considering antimicrobial resistance.
- Improve and invest in health promotion and education programmes, involving medical professionals and public authorities, making use of digital tools (such as apps to track vaccination status) and social media, addressing vaccine hesitancy by providing transparent and evidence-based information to the public;
- As resources for immunization services are mobilised from national budgets, there are discrepancies between Member States in uptake or use of new vaccines or investment in research or procurement; an improved coordination and support from the EU would be beneficial to enable development of new vaccines and improve safety of existing ones; it will also enable the development of more cohesive EU crisis management and preparedness plans.
The EU has also an important leading role to play in promoting and supporting the implementation of the UN Agenda 2030 for Sustainable Development. Moreover, there are significant socio-economic returns in protecting child health and avoiding child mortality. Priority should be given to supporting coverage for children, families and elderly from low and disadvantaged socio-economic groups. Coordinated and inter-sectoral efforts from local to EU level are needed.
Read full responseResponse to Communication on Digital transformation of health and care in the context of the DSM
16 Aug 2017
EuroHealthNet welcomes the consultation towards a Roadmap for the EC Communication on this subject. The collaboration between DGs CONNECT and SANTE is particularly important; however this should be extended to ensure cohesion with other relevant DGs and EU instruments such as the EU Semester processes and the potential EU Pillar of Social Rights. Mention of the need to address health inequalities is welcome; however this is potentially both a key positive and negative factor and should be more prominent. Since the 2009 Communication Solidarity in Health it is increasingly recognised that health inequalities cost EU governments significantly: they reduce people’s ability to contribute to society, undermine economic growth and prosperity, and increase health, social care and wider public expenditures.
Digital technologies do offer new opportunities to transform health care systems, including new approaches to personalised prevention, treatments and care, independent living, integrated health and social care, accelerated scientific progress for early diagnosis and prevention of diseases. However, there are significant risks and obstacles of inequitable implementation including safety, access, effectiveness and authority.
KEY ROLE IN HEALTH PROMOTION
EuroHealthNet welcomes the recognition that digital health tools and processes can play a transformative role in health promotion for European citizens. For instance, mHealth has the potential to prioritise integrated health promotion, disease prevention, provision of care and monitoring for people from vulnerable groups; thereby reducing health and social inequalities. Emerging technologies can further empower patients and carers by giving them more control over and understanding of their health. Conversely, unregulated digital innovation risks widening health inequalities by limiting access according to wealth of states, societies, systems or individuals, especially older people among the 20% of citizens not digitally literate even by the most optimistic forecasts.
TRUST IS IMPERATIVE
Protection of personal data, cross border patient rights and electronic identification are crucial elements to clarify and flag for citizens as well as health and social care professionals in order to encourage a Single Digital Market where health and care is sustainable and effective. The rise of new global actors raises serious questions of systematic and individual rights, benefits, transferability, transparency, interoperability, security and ownership. Innovation must be balanced with a precautionary principle. EuroHealthNet welcomes the Roadmap recognition of wide stakeholder involvement and urges that public health stakeholders, including health workforce professionals, authorities, researchers and civil society in social, cultural and demographic fields are properly involved. Digital Health Single Market instruments should be carefully aligned with the EU Pillar of Social Rights, the UN Sustainable Development Goals and other global standard data protection measures for citizens.
ACCESS FOR ALL
Greatly improved literacy and technical skills, including digital and health literacy for all, are vital for citizens, providers and professionals to avoid widening health inequalities within and between states. How to achieve this should be a feature of the Roadmap and Communication. Digital health technologies are a means to a goal, where health and wellbeing are set out in the TEU objectives. The proximate relationship to the health professional or caregiver should not be substituted for only digital solutions; patient choice is fundamental. Providers also need to understand sensitive matters regarding mental and physical wellbeing, before proposing applications, to avoid harmful unintended consequences.
With those above caveats EuroHealthNet welcomes the EC Roadmap aims and will be interested to contribute towards their progress and development.
Read full responseResponse to Evaluation of the long-term unemployed recommendation
19 Jul 2017
This feedback builds upon the impact long term unemployment (LTU) has on health inequalities (HI). HI cost EU governments significantly: they reduce people’s ability to contribute to society, undermine economic growth and prosperity, and increase health, social care and wider public expenditures.
LTU IMPACT ON HEALTH INEQUALITIES
The link between unemployment and ill health is well established. Unemployment has a higher negative on health for people from low socio-economic groups. Unsurprisingly, LTU sees effects on ill health compounded: people experience negative pressures on their physical and mental health (for numbers on HI cf. Mackenbach et al. 2008 Eurothine & for employment influences on HI cf. DRIVERS goo.gl/xufYyY).
The attached policy briefing includes comments on LTU recommendation in relation with health inequalities and the aspects that could have been better addressed. The main messages should be addressed in the evaluation questions:
‣Health services can play a useful role for integrated and personalised approaches to support LT unemployed
‣Conditionality should be implemented based on proven effectiveness in terms of helping people across the social gradient
‣Addressing the demand side of the labour market is needed to successfully achieve the objective of the recommendation
‣More emphasis is needed on the importance of the right balance between flexibility and security.
SUGGESTIONS FOR IMPROVEMENT OF EVALUATION
‣Evaluation question (reg. Effectiveness) “What measures have been taken to improve outreach to LTU furthest away from the labour market?” This question could be further developed to include the effectiveness in reaching people across the social gradient. For example, to reflect on measures to stimulate job creation per se including tackling barriers to work confronting discriminatory hiring practices or promoting workplace adaptations for workers with particular needs.
‣Evaluation question (reg. Effectiveness) “Has the coordination between employment and social services but also other providers (healthcare, childcare, housing, financial etc.) improved … how?”, This question should include the extent to which inter-service collaboration has taken place, including integrated and personalised services and possibilities to refer job seekers to care and prevention services.
‣Evaluation question (reg. Efficiency) “Are the costs proportionate to the benefits achieved?” This question should also include the assessment of conditionality measures and their effectiveness in terms of helping people from across the social gradient.
‣Evaluation question (reg. Coherence) “To what extent is the LTU recommendation coherent with other EU instruments supporting bringing people back to employment, such as the … The European Semester?” This could be most useful, for example, to identify correlations between social, employment, fiscal and economic NRPs, CSRs and the LTU recommendation, and the extent to which the LTU objectives are being monitored through the EU Semester.
‣Evaluation question (reg. Coherence) “Have the EU structural and investment funds … as well as EaSI been used … to implement the requirements of the Recommendation and how?” This is a very good question which complements the ones above and could provide a good perspective on the use of EU funds for implementation at national and regional level. The question ‘why not?’ can be included, if that is the case, and also to ‘what could improve the use of these funds?’.
‣Evaluation question (reg. Relevance) “How do the measures proposed in the Recommendation correspond to the goal of integration of job seekers in the labour market?” Include the possibility to suggest additional EU-level measures.
It is pertinent to involve local and regional authorities and civil society bodies in the evaluation and consultation phase as they work closely on the targeted measures addressing those furthest away from the labour market.
Read full responseResponse to A NEW START TO SUPPORT WORK-LIFE BALANCE FOR PARENTS AND CARERS
22 Jun 2017
This feedback builds upon the impact the proposal has on tackling health inequalities as a central objective to the health programme. Health inequalities cost EU governments dearly. They reduce people’s ability to contribute to society, undermine economic growth and prosperity, and increase health and social care expenditure.
Work-life balance has an important role in the goal of reducing health inequalities. Addressing health inequalities and breaking the cycle of child poverty and disadvantage requires support for parents and carers to combine work with other responsibilities. More available flexible and part-time work and parental leave provisions can be key to a more inclusive labour market for improved social and health equity. While strong caution must be taken to ensure that both genders benefit equally from these flexible arrangements, so they do not widen the gender pay gap further. The DRIVERs sets out solutions to improve health equity through policy and practice in early childhood, fair employment, and income & social protection. Among the recommendations is the following: “Promote affordable, high-quality pre-natal and early years provision alongside supportive employment policies and parenting and family support services, to help parents combine work with parental responsibilities” (http://eurohealthnet.eu/health-gradient/information/drivers)
▶IMPACT ON HEALTH INEQUALITIES
Gender differences between males and females determine whether individuals are able to realise their potential for a long and healthy life. This translates into differences in life expectancy, mortality and morbidity risks, healthy life years, health behaviours and the use of and access to health care services. It has consistently been found that role conflicts, total workload and unpaid work have adverse effects on women’s well-being and long-term health as well as on opportunities for professional careers. Furthermore, lower parental occupational social class and parental unemployment that can come with female labour market exclusion has a wide range of adverse child health and developmental outcomes. Differences in health status and survival between men and women are unnecessary, unjust and avoidable. These inequalities hinder labour productivity and also have a substantial economic impact, among others explained in the impact assessment (Commission SWD(2017)203 final) of the proposal.
▶KEY CONSIDERATIONS
‣ (1) It is further essential to apply an integrated holistic approach to realise the goal of the draft directive. This includes looking at other policy areas affecting family choices and preconditions regarding labour market participation. This concerns e.g. accessibility, availability and quality of childcare services as well as gender pay gap and stigmatisation of the caring role. According to the Eurobarometer on Gender Equality from 2015, these are all reasons considered by European citizens to influence women’s labour market participation the most. A holistic approach also means ensuring consistency in EU policies across DGs, this can be ensured through the European Semester. This can appropriately be addressed in the Social Scoreboard by including gender quality indicators on childcare use.
‣ (2) It is necessary to take different families structures into account in order to fight discrimination of unconditional families.
‣ (3) Along the primary objective of the proposal it could also be added that “men increasingly want more involvement in the lives of their children.”(Sobel et al., 2016, p. 187). In fact, this directive proposal does not only elevate the rights of women to work, but also the rights for men to spend time with their children. This right is backed by Article 4(3) of the EU Charter of Fundamental Rights: “Every child shall have the right to maintain on a regular basis a personal relationship and direct contact with both parents.”
Read full responseResponse to Access to Social Protection
19 May 2017
Social Protection has a great role in the goal of reducing health inequalities; this is addressed as a general objective by the Health Programme (2014-2020).
▶THE STATE OF PLAY
The world of work as we know it is changing. Digitalisation on the labour market blurs the lines between the physical, digital, and biological spheres. Precarious and non-standard work is becoming more conventional. Approximately, 1/4 of the workforce is in non-standard employment and approximately 1/6 are self-employed, half of these are estimated to have insufficient access to social protection benefits and services, and are therefore less protected. This has been found to contribute to health inequalities, and social and economic divergence – as opposed to convergence.
▶HEALTH INEQUALITIES AND THE EU SUSTAINABILITY CHALLENGE
HEALTH INEQUALITIES ARE A PROBLEM: Health inequalities represent a cost to society in a number of ways: they reflect a loss of individual potential and well-being as well as a loss in people’s economic contributions and an increase in social and care expenditures. The systematic correlation between health status and socio-economic status, are becoming steeper in many EU countries. While health-care systems are an important determinant of health, health is also shaped by a range of other factors, many linked to the nature of social and employment policies that affect e.g. employment levels, long-term unemployment rates, benefit rates, income distribution and material deprivation. Reducing health inequalities is possible, through an appropriate mix of universal and targeted policies, particularly those relating to social protection. Doing so presents an opportunity to tangibly improve the lives of European citizens and will lead to more sustainable and resilient societies.
A CONVERGENCE PROBLEM: Not addressing health inequalities stands in the way of upward economic convergence, due to burdens they place on health systems and consequently public finances. Investing more in measures to promote health, particularly amongst the more and most vulnerable members of society can help make health systems more sustainable and contribute to convergence. Health promotion and addressing wider socio-economic determinants of health were also emphasised in the October 2016 ECFIN Report (ISSN 2443-8014). European health systems are under pressure from demographic aging, rising needs for long-term care (LTC) and not least, the startling rise of non-communicable diseases (NCDs). Health and long-term care absorbs a great and growing share of Member State’s GDP. In 2015, this amounted to 8.7%; this is projected to increase to 10.6-12.6 % in 2060. LTC expenditure alone is projected to increase with almost 70% from 2015-2060. NCDs are resulting in the loss of 3.4 million potentially productive life years. This amounts to an annual loss of EUR 115 billion for EU economies.
▶ACCESS TO SOCIAL PROTECTION CAN HELP
Social Protection can contribute to addressing the sustainability challenge of growing social inequalities within and between states. Increasing the coverage and range of social protection measures can improve health and reduce health inequalities. Access to good quality health services, including health promotion and disease prevention programmes to avoid the need for more costly medical interventions, are a crucial component of this. Evidence shows social determinants (i.e. unemployment, poverty, gender equity, ethnicity, education and income) are key factors impacting health across the life course. Well-designed social protection systems sustain health and well-being by reducing the economic consequences of illness or unemployment, and are particularly important to those with lower levels of education and smaller incomes. Social protection and employment services are therefore essential for a sustainable labour market and for job creation and growth.
Attached: DRIVERS for Health – Social Protection’s influence on Health
Read full responseMeeting with Vytenis Andriukaitis (Commissioner) and
20 Oct 2015 · Health in the EU Semester, health promotion and disease prevention
Meeting with Léon Delvaux (Cabinet of President Jean-Claude Juncker)
4 Feb 2015 · Health matters