Today, August 14, 2023, the National Children’s Network submitted its official position to the Ministry of Health on the draft of the National Strategy for Child and Adolescent Health and Pediatric Care 2030. The document, as it currently stands, only represents an analysis with recommendations, without any specific measures and indicators to track results. The text addresses many of the issues we at the NCN have been raising alarms about, but in practice, it does not define specific objectives or desired outcomes. The entire process of developing the strategy gives an impression of being closed and non-transparent.
The NCN proposes 7 steps for the National Strategy for Child and Adolescent Health and Pediatric Care 2030, to not just remain a document gathering dust on someone’s desk. The full text of our submitted opinion to the Ministry of Health is available on our website here.
Here’s a summary of our position:
Bulgaria has committed to ensuring the highest attainable level of health care for every child in a series of international treaties and its national legislation. At the same time, child mortality in our country continues to be almost twice as high as the European average. Not every child has access to health care, and the number of pediatricians is decreasing every year. Children rely on charitable campaigns for their lives. More than half of the budget for child health care is spent on hospital care. These are just some of the problems facing the health system, as flagged by doctors and civil organizations.
As an association of over 130 organizations and like-minded individuals, working with and for children across the country, who have for years insisted on the need for a specific focus on child health, it is crucial for us to have a strategic approach to guaranteeing the health of every child. That’s why we at the NCN welcome the creation of the National Strategy for Child and Adolescent Health and Pediatric Care 2030. We believe that the document should set high, but realistic and measurable goals, clearly linked to indicators and financial resources to achieve them.
We insist that the indicators for the implementation of the Strategy, envisaged as a system of key indicators for child health and the quality of pediatric care, be linked to the National Child Information System, currently being developed by the State Child Protection Agency, and with the National Strategy for the Child. This is so that monitoring of child health trends and progress on the strategy is based on unified indicators with the most reliable data collection system.
We also believe that additions should be made to the outlined priorities: to Priority 1, a priority area related to promoting breastfeeding and healthy eating for children of all age groups should be added. To Priority 2, in the “Target Recommendations for Implementing this Priority”, emphasis should be placed on measures to identify developmental difficulties in children up to 3 years of age and to provide early intervention for all children in need and their families. The need for such measures is highlighted in the justification for this priority, but the recommendations do not focus on this age group. We suggest including a separate priority direction “Building an Early Childhood Intervention System”, which will be in sync with the National Implementation Plan for the European Child Guarantee adopted in 2022. For Priority 4, priority direction 4.2 should specify that the training of health professionals is aimed at acquiring knowledge and skills for a holistic approach to child health, working with families, and collaborating in multidisciplinary teams with specialists from the fields of education and social activities.
We propose adding another priority area related to overcoming territorial inequalities in activities for the prevention of chronic non-communicable diseases, disabilities, and developmental difficulties.
Although the document mentions a mechanism for operational planning and monitoring results with the participation of all stakeholders, such a mechanism has not been developed, and it is not clear who will create it and within what timeframe.
We suggest that the Strategy implementation plans cover two, not three years, to allow for better updating of measures and tracking progress towards strategic goals with interim reviews at the end of each operational plan.
In this context, in order to create and adopt an applicable National Strategy for Child and Adolescent Health and Pediatric Care, it is necessary:
- To establish an inter-institutional working group with the participation of a wide range of stakeholders, including civil organizations, to formulate the document in a way that corresponds to the understanding of a Strategy and synchronizes it with other key childhood documents, including the National Child Strategy 2030.
- To formulate clear, measurable specific/operational objectives for each priority, expected outcomes, and indicators to track them.
- The Strategy must have a clear financial resource for its implementation. It’s vital to view expenses for child healthcare as investments in children rather than budget expenditures.
- To introduce a principle and practical mechanism for monitoring key indicators and tracking causality (e.g., data collection and analysis of the main causes of child mortality). We recommend introducing additional indicators in line with the child health and well-being indicators used by the World Health Organization, covering at least three areas: physical and mental health of mothers and newborn health; physical and mental health of children; and physical and mental health of young people.
- The Strategy must have a principle and mechanism for clear coordination with other responsible ministries and institutions on cross-sectoral topics (e.g., health education, health-social services, etc.). This mechanism must mandatorily include representatives from the Ministry of Health (MH), the Ministry of Education and Science (MES), the Ministry of Labor and Social Policy (MLSP), and the State Child Protection Agency (SCPA).
- A mechanism should be established for operational planning and monitoring the results of the Strategy with the participation of civil organizations active on the subject. After the adoption of the Strategy, it should be convened to plan the first Action Plan.
- Although the National Children’s Network (NCN) gained access to the draft of the Strategy following a decision by the Administrative Court in Sofia, we insist that after the above-described process, the National Strategy for Child and Adolescent Health and Pediatric Care should be made available for public discussion as a good practice and respecting the opinion of civil society on key issues.
In the current document, we evaluate several directions as positive:
- We welcome the explicit obligation of Bulgaria to ensure the highest attainable standard of health and medical services for the treatment of diseases and the restoration of health for every child. We suggest this wording be added in formulating the Vision of the strategic document.
- We appreciate the alignment of the Strategy’s approach with the approach used in the draft of the National Child Strategy – an approach focused on the child as a rights holder and understanding a holistic approach depending on the child’s age.
- We support and appreciate the well-described connections of the National Strategy for Child and Adolescent Health and Pediatric Care with the National Health Strategy.
- We especially welcome the consultation with the Children’s Council at the State Child Protection Agency and reflecting the children’s opinion, and support this practice to continue.
- We commend the expressed intention to actively seek the opinion of children and families in conducting interim and final assessments of the Strategy’s implementation.
From the National Children’s Network, we once again express our desire and readiness to participate in the development processes of the National Strategy for Child and Adolescent Health and Pediatric Care.
We have been supporting the processes and donating expert resources to the Ministry of Health for years, ensuring that health policies aimed at children are effective, efficient, and respect their best interests. We are ready to alert European institutions if the Strategy does not meet the highest standards for strategic planning. For us, this is a key document, and in our daily work, we advocate for the Strategy to meet the highest standards.
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