EPHA has submitted its response to the EC consultation on the Green Paper on the modernisation of EU public procurement policy - Towards a more efficient European procurement market. EPHA’s response argues that public procurement rules must be more flexible where public health and social objectives are concerned so that they can be considered at all successive stages of the process.
The Green Paper argues that public procurement is facing important new challenges: high public deficits and the resulting need for the most efficient use of public money, but also the growing demand that procurement contributes to the achievement of overall societal goals, amongst them social objectives to include vulnerable groups and decrease inequalities. The public stakeholder consultation was solliciting input from organisations and individuals as to how exactly this can be done.
In this context, EPHA’s letter reinforces the more detailed response submitted by our partner the Social Platform (of which EPHA is a member), which addresses a number of more technical consultation questions in more detail.
Among other points, the EPHA response argues that:
1. Procurement rules need to be unambiguous and flexible so that public health and social objectives matter during all successive stages of the procurement process. If they are only taken into account at a more advanced phase in the process, valuable expertise and knowledge from relevant service providers and users may already have been excluded.
2. Mandatory assessments of community needs and specialist third sector service providers should be carried out before a tender process is undertaken: the goods, services and works involved in the health and social field are not for consumption but to support citizens in leading healthy lives and enjoying meaningful participation in society.
3. Increased opportunities must be created for the third sector to participate in procurement processes. NGOs are well positioned as service providers given their knowledge of vulnerable groups and client proximity, but current rules can challenge their capacity.
4. Restricting public procurement to local or regional suppliers makes sense in cases where social objectives can be attained or where procurement rules contravene public health objectives.
5. Responsible purchasing decisions must be taken at local, regional and national level to ensure the quality and continuity of health and social services.
6. Far greater scrutiny and accountability must be exercised where subcontracting is concerned.
7. Accessibility criteria for people with disabilities must be respected given that current procurement rules leave scope for circumventing ergonomic characteristics.
8. The alternatives to public procurement must be better promoted to support public authorities’ ability to make investments that will lead to long-term health and social improvements and that will reduce costs to health and social systems over time.
European Consultation on the revision of the public procurement Directive
Report on Social Platform Working Group on Services of General Interest in the EU
A new guide to green procurement in Europe