Unclear and variable criteria for determining priority groups for vaccination

Relating to the decision of the Ministry of health on the amendment of priority groups for vaccination, the Centre for Civic Education (CCE) urges again the decision-makers to address this process responsibly and systematically and to create necessary requirements for providing the right to equal availability of vaccination to all citizens of Montenegro, taking care of those who suffer from chronic diseases and therefore represent the additionally vulnerable category.

CCE reminds that the Minister of Health stated in the Parliament yesterday that the vaccination, apart from the citizens aged 65 to 69, but also for those who are considered clinically extremely vulnerable categories, regardless of age, will be available to numerous professions, including those employed in the Police administration, Armed Forces of Montenegro, seafarers, employees in the media, educators (from nurseries to university), pharmacists, as well as employees in state bodies and local self-government bodies. A bit different categorization is published on the official website so it remains questionable which one is valid and whether this opens the space for manipulation.

Strategic Advisory Group of Experts on Immunization (SAGE) established six principles on which the priority establishment must be based – Human WellBeing, Global Equity, Reciprocity, Equal respect, National Equity and Legitimacy. It seems that these principles were not respected in Montenegro, having in mind that the vaccination process, according to the decision of the Ministry of health, is not conducted according to medical, but according to functional and economic-social criteria.

National Strategy for the Introduction, Distribution and Deployment of Covid-19 Vaccines analyzed in detail the target groups and estimated their scope.  However, it is largely neglected in practice, although this Strategy was adopted right in the mandate of the current Government.

CCE emphasizes the importance of vaccination of those who come into direct contact with a large number of people while doing their regular work assignments, which can cause transmission and spread of the communicative disease Covid-19, with a note this must be based on pre-conducted analyzes.

CCE reminds that the World Health Organization (WHO) has previously indicated that those sections of the population who develop significantly more serious clinical conditions and complications after SARS-CoV-2 infection due to which need to be treated in hospitals and whose mortality is more frequent, must be given priority in vaccination in relation to other categories of society that currently belong to the priority population for COVID-19 Vaccination.

The Ministry of Health was obliged to take care that the criteria for the formation of priority groups for vaccination must not be discriminatory, in a way to put any person into a more favorable position without reasonable medical explanation. Precisely for this reason, all citizens have equal rights to vaccination, through the formation of a realistic assessment and avoidance of discrimination.

CCE considers that the Ministry of health must make a balance in all aspects of citizens protection, instead of giving a privileged position to individuals, as is given for example persons employed in the state administration, who may are not a vulnerable category in any way and who are quite numerous, while simultaneously ignoring the need for vaccination of part of the population whose health is exposed to numerous risks due to the pandemic.

Damir Suljevic, Programme associate