On January 14, 2021, the Government of Georgia approved the National Plan for COVID-19 Vaccine Deployment, which calls for the immunization of 60% of the country’s adult population by the end of the year. TI Georgia has studied this document within the limits of its competence and found that the plan does not include any corruption related risk assessment or measures against dishonest actions. Failure to take corruption risks into account may create problems down the line and hinder the immunization process. 

The national plan for vaccine deployment provides for all the stages and procedures and determines the responsible individuals/institutions whose joint efforts must ensure the vaccination of the population across the country. The document attaches great importance to ensuring the correct conduct of all procedures related to immunization, which we assess positively. 

However, we consider it problematic that the plan does not sufficiently provide for the prevention, detection, and response to the abuse of delegated authority by numerous individuals and institutions involved in the immunization process (vaccinators, mobile crews, healthcare centers, municipal bodies, etc.).

The risk of dishonest actions is real and is caused by three main circumstances:

1. The existence of a product that is in high demand and is hard to obtain – COVID-19 vaccine is a highly demanded product, which may lead to some people choosing to resort to violating rules in order to obtain it.  
2. Distribution of authority to many individuals/institutions – The scale of immunization makes it necessary to distribute the authority to many individuals and institutions across the country, and such an increase in the number of authorized entities without corresponding preventive measures increases the risk of corruption-related violations.
3. Involvement of additional external individuals in the system of immunization – As noted in the plan, achieving 60% immunization by the end of the year requires a near quadrupling of the existing capacity (number of shots) of the immunization system. This means that the vaccination process will additionally require the involvement of individuals new to the immunization and/or medical field, which may increase the risk of dishonest behavior.

Even though the vaccination plan provides for a large-scale training program for individuals involved in the process, the content of this training program does not include components of integrity and response to violations.

The plan also provides a hotline for vaccinators. However, the function of the hotline is to provide information on the correct conduct of the procedures rather than to report violations or dishonest actions.

According to the plan, the immunization process also involves a system of monitoring and oversight. However, this system is also directed at the observance of procedures, verification of the implementation of the immunization plan, and oversight on the side effects of the vaccine and does not provide for the management of corruption-relation violations.

It is a welcome fact that the management of the vaccine supplies and distribution and of registration of the vaccinated will largely take place electronically. Such automation and electronic conduct of the processes does decrease the risks of corruption. However, due to the large scale and multiple stages of the immunization process, there are stages that are more susceptible to corruption and that must be identified in advance. For example:   

• What happens if a citizen decides to obtain a vaccine before it’s their turn, using his/her connections, a bribe, influence, or official powers?     
• Which stage of immunization is the most susceptible to such a risk? 
• Are there any mechanisms for detecting and responding to such cases?    

The fact that the vaccination plan does not mention such risks of corruption and dishonest actions indicates that the responsible authorities have not assessed these risks and have not made an effort to develop mechanisms for their prevention.  

In view of this, we believe that, in order to lower corruption risks in the process of immunization, it is necessary to:

• Add a component of/section on integrity to the national plan for vaccine deployment which will be based on corruption risk assessment and will prescribe both prevention measures as well as corresponding sanctions.   
• Introduce a mechanism for reporting and responding to violations related to the immunization process. It should be possible to report the violations by means of the hotline for vaccinators, where the anonymity of whistleblowers is fully protected.
• Add an integrity component to the training program provided for by the immunization plan, which will be based on corruption risk assessment and will provide training participants with information on what they should do if they discover a violation.
• Conduct the process of immunization in conformity with the principle of complete transparency, so that representatives of the civil society and any concerned citizen have the opportunity to observe the process. This implies both the publication of all contracts related to vaccination (e.g. procurement of vaccines, reagents, immunization services, etc.) and timely disclosure of full information on the vaccinated population.

According to the National Plan for COVID-19 Vaccine Deployment, the document shall be updated periodically based on new information. We hope that the risks of corruption will be assessed and prevention mechanisms will be put in place before the start of the vaccination process, so that dishonest actions and corruption will not damage the immunization process.