Table 4. Key Observations About the Regulation of Quality and Availability of TB Medicinesa .
India | Tanzania | Zambia | |
Regulatory framework | |||
• No comprehensive policy framework for regulation of TB medicines (-) • Manufacture and import of TB medicines not specifically restricted • Drugs and Cosmetics Act and MoHFW guidelines outlined measures to assure quality of procured medicines (+) |
• Policy of MoHSW restricted imports to government operators only (++)b |
• Import of TB medicines not specifically restricted • PRA and MoH guidelines outlined measures to assure quality of procured medicines (+) |
• Production + procurement |
• Drugs and Cosmetics Act (universal) and MoHFW guidelines (government sector only) outlined measures to assure norms and standards during stocking and distribution (+) | • MSD and MoHFW guidelines outlined measures to assure norms and standards during stocking and distribution (+) | • PRA and MoH guidelines outlined measures to assure norms and standards during stocking and distribution (+) | • Stocking + distribution |
• MoHFW mandated DOTS regimens in all government facilities and in government-affiliated private facilities (+) • National drug schedules required that TB medicines be dispensed only on prescription (+) |
• Policy of MoHSW stated that only facilities affiliated to the NTLP were allowed to prescribe and dispense TB medicines, in accordance with DOTS (++)b |
• MoH mandated DOTS regimens in all government facilities and in government-affiliated private facilities (+) • PRA norms required that TB medicines be dispensed only on prescription by qualified medical practitioners (+) |
• Prescribing + dispensing |
Authority and capacity | |||
• Drug controllers faced severe human resource constraints (--)b
• Concerns over technical capacity of central and state regulatory authorities (-) • Amendments in laws were in process to increase criminal penalties for defaulters (+) • PQ requirement not universal (at time of study) (-) |
• Policy widely supported across constituencies (++)b
• Political support for regulatory body (++)b |
• Drug controllers faced financial and human resource constraints (-) | • Production + procurement |
• Drug controllers faced severe human resource constraints (--)b
• Clear lines of authority and perception of fair monitoring capacity in the government TB programme (+) |
• Clear lines of authority and perception of fair monitoring capacity in the government TB programme (+) | • Clear lines of authority and perception of fair monitoring capacity in the government TB programme (+) | • Stocking + distribution |
• Drug controllers faced severe human resource constraints to controlling dispensing practices, had no authority over prescribing practices (-) • Government recommendations for drug regimens not applicable in private sector (--)b • Professional councils were uninvolved in matters of regulating practices (-) |
• Clear lines of authority and perception of fair monitoring capacity in the government TB programme (+) • Professional councils were uninvolved in matters of regulating practices (-) |
• Drug controllers faced financial and human resource constraints (-) • Clear lines of authority and perception of fair monitoring capacity in the government TB programme (+) • Professional councils were uninvolved in matters of regulating practices (-) |
• Prescribing + dispensing |
Implementation | |||
• Some concerns over implementation of quality control. Few instances of penal action (-) | • Faithful implementation of import restrictions (++)b | • No specific observations of barriers or enablers | • Production + procurement |
• Drug controllers unable to monitor private distribution (--)b
• Inspections and prosecutions infrequent, in private sector (-) • Clear lines of authority and perception of fair monitoring capacity in the government TB programme (+) |
• Clear lines of authority and perception of fair monitoring capacity in the government TB programme (+) |
• Clear lines of authority and perception of fair monitoring capacity in the government TB programme • Drug controllers ability to monitor private distribution questionable (-) |
• Stocking + distribution |
• Fair adherence to dispensing, prescribing norms in government facilities (+) • Reports of widespread violation of dispensing, prescribing norms in private facilities (-)b • Inspections and prosecutions of private sector defaulters infrequent (-) |
• Fair adherence to dispensing, prescribing norms in government and affiliated facilities (+) • Some reports of abuse of prescription-drug norm in private facilities (-) • Inspections and prosecutions of private sector defaulters infrequent (-) |
• Fair adherence to dispensing, prescribing norms in government and affiliated facilities (+) • Several reports of abuse of prescription-drug norm in private facilities (--)b • Inspections and prosecutions of private sector defaulters infrequent (-) |
• Prescribing + dispensing |
Efficiency, transparency, and accountability | |||
• Perceived inefficiencies in coordinating state and central authorities’ roles (-) • Private representation and political involvement in regulatory affairs widely recognized (--)b |
• Perceived improved efficiency resulting from hierarchical control of TB programme, and exclusion of private actors • Perception that efficiency resulting from hierarchical control of TB programme, likely to be attenuated by moves to integrate disease programmes (-) |
• Perceived improved efficiency resulting from hierarchical control of TB programme • Risk of donor dependence in drug procurement (-) |
• Production + procurement |
• Drug controllers prioritized drug quality management over regulating distributors and practitioners (-) • Limited information about distribution networks among informal/small private sector catering to poor (-) |
• Perception that efficiency resulting from hierarchical control of TB programme, likely to be attenuated by moves to integrate disease programmes (-) | • Perceived improved efficiency resulting from hierarchical control of TB programme | • Stocking + distribution |
• Professional councils rejected role in regulating dispensing and prescribing practices (-) • Drug controllers prioritized drug quality management over regulating distributors and practitioners (-) • Some professional associations opposed government regimens (--)b |
• Perceived improved efficiency resulting from hierarchical control of TB programme • Private actors perceived lack of inclusiveness of policy-making by TB programme (-) • Little information about practices of informal/small private healthcare providers (--)b |
• Perceived improved efficiency resulting from hierarchical control of TB programme • Little information about practices of informal/small private healthcare providers (--)b |
• Prescribing + dispensing |
Abbreviations: MoHFW, Ministry of Health and Family Welfare; TB, tuberculosis; NTLP, National Tuberculosis and Leprosy Programme; PQ, Prequalification; PRA, Pharmaceutical Regulatory Agency; MoH, Ministry of Health; DOTS, directly observed therapy short-course; MSD, Medical Stores Department.
a Constraining and enabling factors are tagged with (-) and (+) signs, respectively.
b Most frequent and salient observation.