COMMISSION STAFF WORKING DOCUMENT STAKEHOLDER CONSULTATION - SYNOPSIS REPORT Accompanying the Communication from the Commission to the European Parliament and the Council Europe's Beating Cancer Plan
Date: 2021-02-03
Institutions: Directorate-General for Health and Food Safety, European Commission
Subjects: EU action, cancer, carcinogenic substance, disease prevention, health care, health risk, innovation, medical diagnosis, research and development, therapeutics

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 3.2.2021  SWD(2021) 13 final  COMMISSION STAFF WORKING DOCUMENT STAKEHOLDER CONSULTATION - SYNOPSIS REPORT Accompanying the Communication from the Commission to the European Parliament and the Council Europe's Beating Cancer Plan  {COM(2021) 44 final}  
 
 
 
 
 
 
 
 
 
SYNOPSIS REPORT 

1.  INTRODUCTION: OBJECTIVES AND STAKEHOLDERS 

This  report presents  the  outcome of the four strands of consultation  conducted for Europe’s 
beating-cancer  plan.  The  consultation  process  was  launched  on  World  Cancer  Day  on 
4 February 2020.  

The  consultation  strategy  was  designed  to  gather  EU-wide  input  on  the  four  pillars  of 
Europe’s response to cancer, as outlined in the mission letter to Stella Kyriakides, European 
Commissioner for Health and Food Safety: (i) prevention; (ii) early detection and diagnosis; 
(iii) treatment; and (iv) care and quality of life for cancer patients, survivors and carers (plus 
knowledge  and  scientific  evidence).  Specifically,  the  consultation  strategy  aimed  to  create 
different entry points into the process to ascertain the main: trends, expectations; and concerns 
of  stakeholders  and  the  public.  Each  part  of  the  strategy  was  tailored  to:  capture  specific 
responses; identify areas of broad agreement; and identify points of significant difference.   

The process therefore included the following.  

  Feedback on the roadmap (4 February - 3 March).  
  A public online consultation (4 February - 22 May). 
  Targeted stakeholder consultations, including a ‘townhall’ meeting over the summer.  
  Engagement  with:  (i)  public  authorities  through  the  Commission’s  Steering  Group  on 
Health  Promotion  and  Disease  Prevention;  (ii)  the  European  Parliament,  through  the 
Special  Committee  on  Beating  Cancer;  and  (iii)  the  Mission  Board  of  the  proposed 
Horizon  Europe  Mission  on  Cancer.  There  were  also  additional  ad  hoc  contributions, 
provided primarily through meetings with Commission officials. 

The  consultation  process  drew  on 
the key groups, citizens and patients: 

the  stakeholder  mapping  which 

identified 

  NGOs  representing  the  cancer  community,  typically  patient  groups  or  European 

professional scientific bodies;  

  European public-health organisations;  
  professionals and professional associations;  
 
 
  Member States, including public authorities and European Parliament members; 
 

industry;  
researchers;  

international agencies. 

The consultation strategy and process reached all the above groups. It recognised that groups 
cannot  be  discretely  separated  (individuals,  patients,  professionals,  patient  associations  and 
professional  bodies  are  separate  categories  in  theory,  but  they  overlap  in  practice).  It  also 
ensured that all the key stakeholders identified in the mapping had opportunities to contribute.  

The consultation took place against the backdrop of the COVID-19 pandemic, which diverted 
the  attention  of  many  participants.  This  situation  was  mitigated  by  extending  the  public-

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consultation  timeframe  and  delaying  the  roll-out  of  the  targeted  stakeholder  consultations. 
Meetings were carried out virtually, and were sometimes delayed. 

As the pandemic’s impact on cancer patients and cancer care became clearer, a series of three 
webinars was organised. The goal of these webinars was to better understand the pandemic’s 
implications  and  gain  insights  into  the  situation  in  Member  States  to  inform  the  further 
development of the plan.  

2.  METHODOLOGY AND TOOLS  

The  Commission  gathered  feedback  on  both  its  roadmap  and  public  consultation  through 
online questionnaires.  

The  feedback  on  the  roadmap  was  analysed  quantitatively  and  qualitatively,  drawing  on 
machine learning and manual analysis to identify themes for each of the  four pillars, and in 
particular the fourth pillar on knowledge, data and scientific evidence.  

The  online  public  consultation  combined  a  mix  of  closed  questions  (where  respondents 
choose from a pre-determined selection of answers) and open questions (where they are free 
to  write  any  response  they  choose  of  up  to  600  characters  per  response).  Responses  to  this 
public  consultation  were  analysed  using  MS  Excel  and  text-analysis  tools.  Some  responses 
were  re-classified  using  the  name  of  the  respondent’s  organisation  and  information  on  the 
respondent’s website to allow for a clearer distinction between relevant types of stakeholders 
(e.g.  patient  organisations,  health  professionals,  etc.).  Where  relevant,  thematic  coding  and 
grouping  were  applied  to  free-text  responses  to  determine  grouping  and  frequency.  This 
involved a degree of interpretation. There was limited duplication of free-text responses (i.e. 
instances where different respondents wrote similar free-text responses); this was the case for 
only 5% of entries).  

The  targeted  stakeholder  consultations  took  place  with:  (i)  patient  representatives;  (ii)  the 
cancer  community  (scientific  and  expert  associations);  (iii)  the  European  public-health 
community; (iv) professional  associations;  (v) the healthcare industry; and (vi) international 
agencies.  These  consultations  were  supplemented  by  four  expert-informant  interviews. 
Invitees were identified for expert consultation based on: (i) their expertise in cancer or their 
activity in the field of cancer treatment; and (ii) their ability to represent an EU-wide or group 
perspective. Before the targeted stakeholder consultations, the organisers circulated questions 
based on: (i) the roadmap; and (ii) expert knowledge of the constituency being consulted. The 
organisers also facilitated discussion in the targeted stakeholder consultations. Notes from the 
targeted stakeholder consultations were sent to invitees after the consultations in the form of 
key messages for further comment. These comments were then consolidated and analysed. A 
public ‘townhall’ consultation provided further checks and inclusivity. 

3.  CONSULTATION ACTIONS 

a.  FEEDBACK ON THE COMMISSION ROADMAP 

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In total, 387 comments were received from stakeholders in 25 EU Member States (89%)1, and 
10 comments were received from stakeholders in non-EU countries (11%)2. The responding 
stakeholders  represented  a  great  variety  of  sectors.  Close  to  one  third  of  responses  (32%) 
came  from  non-governmental  organisations  (NGOs),  followed  by  the  EU  general  public 
(23%),  companies/business  organisations  and  associations  (22%),  and  research/academic 
institutions (7%). The low response rate from public authorities (2%) was noteworthy.  

The respondents broadly endorsed the initiative set out in the beating-cancer plan. There was 
particularly  strong  support  for  the  prevention  pillar  (tobacco  legislation  and  addressing 
workplace  exposure  to  environmental  risks),  but  there  was  overall  enthusiasm  for  the  other 
pillars as well. Respondents also made suggestions on strengthening the beating-cancer plan. 
In addition, the respondents raised other issues, suggesting greater emphasis should be placed 
on: 

  paediatric cancers, including innovation in medicines, work on genetic mutations that play 

 

a role in cancer, and survivorship strategies;  
integration  of  real-world  evidence  and  innovations  such  as  artificial  intelligence  for 
personalised care; 
improving training standards for medical professionals; 

 
  health literacy for patients, carers and the public;  
  equal opportunities for EU citizens to access cancer prevention and care;  
  high-quality monitoring and surveillance systems at EU level to inform policies; 
  sharing of best practices by Member States within the EU. 

A summary of the feedback was published. 

b.  FEEDBACK ON THE PUBLIC CONSULTATION 

2 078 responses  were  received  through  the  online  platform,  with  a  further  27 responses 
received  via  email.  These  27  email  responses  were  prompted  by  the  publication  of  the 
questionnaire,  but  they  did  not  all  follow  the  suggested  format.  All  EU  countries  were 
represented  in  responses  by  the  general  public  and  organisations,  and  184  (9%)  of  all 
responses stated that the respondent’s country of origin was outside the EU. 1 341 responses 
were from individuals, while 737 contributed on behalf of organisations. 

Among  the  organisations  responding,  the  largest  share  (35%)  was  engaged  in  academic 
research,  followed  by  patient  organisations  (25%)  and  associations  of  health  professionals 
(10%). 

Overall, the public consultation attracted a wide variety of inputs. There was some evidence 
of  a  small  number  of  concerted  responses  by  interest  groups.  There  was  clear  consensus  in 
many areas, and nearly all respondents felt the EU should do more across all four pillars.  

1   No comments were received from stakeholders based in Estonia and Slovenia. 

2   From non-EU countries, the most comments came from the United Kingdom (17 respondents), Switzerland 

(10 respondents), and the United States (6 respondents). 

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In prevention, the top three areas highlighted were tobacco, diet and carcinogenic substances, 
with  many  members  of  the  public  noting  a  lack  of  information  on  cancer  prevention. 
Respondents  said  they  would  like  public  authorities  and  national  governments  to  address 
cancer prevention through multiple mechanisms,  such as:  (i) providing  funding;  (ii) passing 
legislation  and  regulations  that  are  compatible  with  health  in  all  policies;  and  (iii)  reducing 
inequalities  in  the  determinants  of  health  that  increase  the  risk  of  cancer.  In  the  ‘early 
diagnosis’  section  (pillar  2),  there  was  broad  support  among  respondents  for  extending 
recommendations  for  screening  to  other  types  of  cancer,  where  screening  can  also  be 
effective.  In  the  section  on  treatment  (pillar  3),  respondents  said  that  the  EU  could:  (i) 
improve  access  to  –  and  the  quality  of  –  cancer  services;  and  (ii)  promote  universal  health 
coverage across all Member States (a breakdown by country revealed large differences in the 
availability  of  support  –  both  inside  and  outside  of  healthcare  settings  –  for  patients  across 
Europe) . Finally, in the section on quality of life and life after cancer (pillar 4), survivors and 
families said they experienced multiple challenges in daily life coupled with a lack of support 
(in psychological assistance, medical follow-up, and social integration). 

There was also considerable support among the respondents for greater focus on:  

tackling risk factors, and alcohol in particular; 

  paediatric cancer; 
 
  setting uniform care standards across Member States;  
  monitoring the implementation of the plan. 

Respondents wanted to see effective implementation with: (i) improvements in outcomes on 
population health and user experience; and (ii) greater support for people affected by cancer.  

of 

summary 

A 
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12154-Europe-s-
Beating-Cancer-Plan/public-consultation.  

consultation  was 

results 

public 

the 

the 

of 

published 

c.  TARGETED STAKEHOLDER CONSULTATION 

The Commission  used this  stage to  explore the issues in  more depth  and detail. Despite the 
qualitative  nature  of  the  targeted  stakeholder  consultations,  there  were  surprising  levels  of 
consistency across the groups in their views on the four pillars. Many respondents also raised 
the  same  cross-cutting  issues.  Their  views  are  summarised  below  under  five  headings: 
prevention (pillar 1); early detection and diagnosis (pillar 2); treatment and care (pillar 3); life 
after cancer (pillar 4); and additional issues.  

Prevention  (pillar  1):  there  were  widespread  calls  from  different  constituencies  for:  (i)  a 
‘health  in  all  policies’  approach;  (ii)  a  comprehensive  approach  to  risk;  (iii)  protecting  and 
promoting health through multi-sectoral action; and (iv) addressing behaviour through multi-
sectoral action. Respondents called for particular focus on:  

tougher regulation of alcohol, tobacco and food; 
regulations on environmental and occupational risk;  

 
 
  supporting the European code against cancer; 
  addressing:  (i)  commercial  determinants  of  health;  (ii)  cross-border  marketing;  and  (iii) 

digital communications; 

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  protecting  children  and  young  people,  including  through  effective  vaccination  (for 

example through the vaccine for human papillomavirus – HPV);  
fostering EU synergies to support Member States in implementation;  

 
  bolstering  the  share  of  government  budgets  allocated  to  public  health  and  disease 

prevention across the EU; 

  encouraging systematic impact assessment.  

Early  detection  and  diagnosis  (pillar  2):  were  widely  agreed  to  be  areas  the  EU  could  and 
should  strengthen  through  EU-wide  standard  setting.  Respondents  believed  the  following 
areas were particularly suitable for this: 

  developing  comprehensive  early-diagnosis  programmes,  high-quality  diagnostics, 

 

laboratory capacity, guidelines, and regulation; 
improving  screening  through:  standard  setting,  risk  categorisation,  quality  assurance, 
encouragement of best practices, targeted interventions, monitoring, and research;  

  helping to improve data collection, monitoring and analysis.  

Treatment  and  care  (pillar  3):  respondents  from  different  stakeholder  groups  tended  to 
prioritise slightly different actions in this area. Nonetheless, there was widespread consensus 
on the importance of:  

 

treatment  standards  and  guidelines  to  promote  quality  comprehensive  care  (including 
quality-assurance mechanisms and accreditation);  

  addressing rare cancers through European reference networks and cross-border care;  
 
 
  expanding the role and funding of European reference networks and their links to national 

treating paediatric cancers (and transition to adult-care services); 
treating multi-morbid and geriatric patients; 

reference centres;  

  ensuring  that  the  patient  experience  is  taken  into  consideration  when  developing  the 
patient ‘pathway’ (the series of steps and clinical encounters taken by patients from first 
diagnosis through to treatment and after care), and including psychosocial care and mental 
health in these pathways; 

  encouraging integrated multidisciplinary care teams and better communication; 
  addressing  workforce  education  and  staff  shortages,  and  recognising  professional 

qualifications; 
investing in surgery, radiation therapy, interventional oncology and nuclear medicine;  

 
  appropriate and coordinated research.  

Life after cancer (pillar 4): this area was of particular concern to patient representatives, but 
their  concerns  were  echoed  by  others  with  a  common  interest  in  EU  action  on  survivors’ 
physical,  medical,  psychosocial,  employment  and  wider  needs.  Specific  issues  raised  in  the 
targeted stakeholder consultations included: 

  cancer-survivorship design and planning, with integration into the cancer-care pathway;  
 

implementing  follow-up  care  plans,  infrastructures  and  interoperable  IT  tools  for  cancer 
survivors, including a survivorship ‘passport’; 

  managing the long-term side-effects of cancer treatment and cancer co-morbidities;  

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  addressing stigma, discrimination and financial implications (the ‘right to be forgotten’); 
 
  addressing the needs of paediatric and younger patients. 

the importance of considering the needs of families and carers; 

Additional  issues:  there  was  a  high  degree  of  overlap  in  the  additional  issues  flagged  by 
participants  in  the  targeted  stakeholder  consultations.  These  additional  issues  echoed  issues 
raised online and in interviews with key informants. The main additional points included the 
following views.  

  Collaboration  and  coordination  across  the  EC  should  be  encouraged,  and  synergies 

between EU initiatives should be exploited.  

  The  EU  adds  significant  value  by  promoting:  (i)  the  exchange  of  best  practices,  (ii) 
consistent  and  coherent  quality  standards;  and  (iii)  EU-level  monitoring  and 
evaluation.  

  The EU also has a significant role to play in: (i) the exchange and interoperability of data 
and  information;  (ii)  data-sharing  infrastructure(s);  and  (iii)  standards  and  work  across 
registries. 

  The  coordination  and  funding  of  research  should  be  encouraged.  In  particular, 
translational and organisational research should be studied to support the implementation 
and development of policies that are informed by patients.  

  The  EU  plays  a  useful  role  in  fostering  innovation.  This  innovation  should  cover  new 
diagnostics,  cancer-related  genomics,  big  data,  and  artificial  intelligence  (AI).  It  should 
also  ensure:  (i)  ethical  and  fair  access  to  cancer  treatment  for  all  people;  and  (ii)  an 
appropriate balance between public and commercial interests.  

  European  research  networks  are  an  important  mechanism  with  great  potential  –  if 

adequately funded – to play a much wider role. 

  Health-technology  assessment  would  benefit  from  centralised  action  to:  (i)  encourage 
quality and consistency;  and (ii) broaden the focus to include clinically meaningful end-
points. 

  Repeated reference was made to the European scope for action on: (i) fairness and access 
(to trials, early diagnosis and treatment); (ii) quality of care; and (iii) outcomes. In these 
references, respondents hoped that the EU could: (i) address unfairness in risk factors to 
tackle the socioeconomic and commercial determinants of health, risk behaviours, and the 
needs of vulnerable groups; (ii) raise quality and consistency, certify cancer-care centres, 
and promote value-based care; and (iii) consider greater price transparency and combined 
arrangements for purchasing and pricing.  

  An EU role to foster patient empowerment and patient-centredness was advocated. 
  Respondents  advocated  a  European  focus  on:  (i)  communication  and  health;  and  (ii) 
through  patient 

languages,  and  with  and 

literacy  (including 

in  native 

digital 
organisations). 

  The EU was encouraged to help the Patients Association to be independent of industry. 
  Stakeholders  also  called  for  the  EU  to  support:  (i)  the  education  and  training  of  health 
professionals;  and  (ii)  multi-professional  approaches  including  in  public  health  and 
communications.  

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  Finally, all groups advocated systematic monitoring and evaluation to support the plan. 

The  COVID-19  crisis  started  to  worsen  a  few  weeks  after  the  launch  of  the  consultation 
process. Because of this, there was no particular focus on COVID-19 in the feedback on the 
roadmap  and  the  public  consultation.  The  Commission  therefore  organised  a  series  of  three 
webinars with  key stakeholder organisations, which revealed that COVID-19 had an impact 
on the entire community of professionals working in cancer prevention and cancer care. 

Summaries  of  each  of  the  targeted  stakeholder  consultations  were  published  [include 
hyperlink]. 

d.  AD HOC CONTRIBUTIONS 

Steering  Group  on  Health  Promotion,  Disease  Prevention  and  Management  of  Non-
Communicable Diseases  

Input was sought from EU Member States as well as from Norway and Iceland through the 
Steering  Group  on  Health  Promotion,  Disease  Prevention  and  Management  of  Non-
Communicable  Diseases.  The  steering  group  discussed  Europe’s  beating-cancer  plan  in 
four of its meetings. The aim of seeking this input through the steering  group was to: (i) 
understand national priorities on cancer with reference to the roadmap’s pillars; and (ii) get 
insights  into  the  types  of  actions  Member  States  considered  to  be  part  of  an  EU-level 
response.  

In  total,  27  EU  Member  States  plus  Norway:  (i)  responded  to  a  survey  circulated  to  the 
steering group, which was launched on 2 July and closed on 21 September 2020; and/or (ii) 
shared  feedback  on  the  initiative  in  other  ways.  Member  States  among  others  described 
their national priorities, and selected topics for which they considered EU involvement to 
be  a  priority.  Almost  all  Member  States  considered  the  four  main  pillars  of  Europe’s 
beating-cancer plan as a high or very high national priority, and all pillars are expected to 
gain importance over the next 5 years. As challenges for implementing actions across the 
four  areas  Member  States  most  often  reported  the  challenges  of  insufficient  funding  and 
staff levels.  

In the prevention pillar (pillar 1), almost all Member States identified promotion of a healthy 
lifestyle  as  a  main  national  priority,  with  a  focus  on  raising  public  awareness  about 
behavioural  risk  factors.  When  asked  to  rank  in  which  areas  of  prevention  EU  involvement 
should  be  prioritised,  they  most  often  considered  that  working  on  a  ‘generation  prevention’ 
was  a  priority,  thereby  targeting  behavioural  risk  factors  of  young  people.  Other  high 
priorities were:  ‘tobacco’, ‘environmental  pollution’, ‘vaccination,  such as against HPV and 
hepatitis B’, ‘paediatric cancers’ and ‘alcohol’. 

For  the  pillar  on  early  detection  and  diagnosis  (pillar  2),  specific  cancer-screening 
programmes were mentioned most frequently as national priorities, with some Member States 
aiming to increase access to existing screening programmes, whereas others focus on quality 
of  the  screening  or  initiate  a  new  screening  programme.  At  EU  level,  the  highest  ranking 
priority areas included the quality of screening (also encompassing assured timelines), better 

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links between cancer-screening data and cancer registries  and diagnostics  (including  timing, 
availability and standards).  

On  treatment  (pillar  3),  ‘national  coordination  of  centres  of  excellence/expertise’  and  ‘the 
availability  and  affordability  of  medicines’  were  at  national  level,  which  were  raised  most 
often by Member States. This latter topic was seen as a priority for shared action at EU level, 
by  ensuring  EU-wide  access  to  (affordable)  medicines  and  treatments.  A  second  EU  level 
priority in this pillar was ‘sharing validated best practice’.  

For the pillar for survivorship and life with/after cancer, (pillar 4), Member States most often 
referred to their national priority of establishing a holistic and multidisciplinary follow-up for 
cancer survivors, while also pointing to psychosocial issues of both patients and their families, 
as well as palliative care. In line with this prioritisation, Member States also ranked ‘quality of 
life  of  survivors’  and  ‘social  protection’  most  highly  as  EU  level  priorities,  (‘social 
protection’ addresses issues such as the ‘right to be forgotten’ and protecting survivors from 
financial discrimination), closely followed ‘paediatric cancer survivors, including relatives as 
informal carers’, and ‘reintegration in the working environment’.  

All Member States said that action at EU level has added value, emphasising that EU action 
was especially helpful  in  the field  of knowledge, data  and scientific evidence.  The Member 
States were also in favour of supporting research, data exchange and knowledge-sharing, for 
example  through  the  European  health-data  space.  They  also  stressed  that  the  EU  could  add 
value by harmonising Member State efforts to reduce cancer and inequalities. 

Member  States  identified  a  number  of  topics  as  suitable  priorities.  On  prevention  (pillar  1), 
almost  all  Member  States  said  that  ‘work  on  a  generation  prevention’  was  a  high  priority. 
Other high priorities were: ‘tobacco’, ‘environmental pollution’, ‘vaccination, such as against 
HPV  and  hepatitis  B’,  ‘paediatric  cancers’  and  ‘alcohol’.  On  early  detection  and  diagnosis 
(pillar  2),  Member  States  ranked  two  topics  most  highly:  ‘screening’  (including  quality  and 
assured timelines) and ‘better links between cancer-screening data and cancer registries’. On 
treatment  (pillar  3),  Member  States  ranked  ‘EU-wide  access  to  (affordable)  medicines  and 
treatments’  and  ‘sharing  validated  best  practice’  most  highly.  On  the  pillar  for  survivorship 
and life with/after  cancer (pillar 4), Member States ranked  ‘quality of life of survivors’ and 
‘social  protection’  most  highly  (‘social  protection’  addresses  issues  such  as  the  ‘right  to  be 
forgotten’ and protecting survivors from financial discrimination).  

Member States also pointed to two ways in which the Commission had an enabling role: (i) 
promoting  international  academic  research;  and  (ii)  strengthening  data  sharing  and 
collaboration between cancer registries. They stressed the added value of  initiatives like the 
European  Network  of  Cancer  Registries  and  the  supporting  role  of  the  European 
Commission’s  Joint  Research  Centre.  On  training,  most  Member  States  stressed  the 
importance of training healthcare professionals in multidisciplinary collaboration. 

Fairness  was  considered  a  concern  for  most  Member  States,  and  almost  all  Member  States 
indicated that COVID-19 had at least some impact on cancer services in their country.  

A summary was published of the Member State feedback. 

Engagement with the European Parliament 

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On 15 June, the European Parliament Committee on the Environment, Public Health and Food 
Safety  published  a  report,  Strengthening  Europe  in  the  fight  against  cancer.  The  report 
outlines  a  comprehensive  set  of  recommendations,  and  covers  topics  which  echo  concerns 
raised  in  the  consultation  about:  (i)  research  and  action  on  cancer  prevention  (including  by 
focusing on tobacco, alcohol, healthy lifestyles, and vaccines); (ii) risk prediction, screening 
and early detection; and (iii) treatment, quality of care, and the needs of cancer survivors.  

The  newly  established  European  Parliament  Committee  on  Beating  Cancer  also  presented  a 
working  document  as  input  to  the  plan  on  27 September,  and  exchanged  views  with 
Commissioner Kyriakides. 

On  12 October,  members  of  the  committee  committed  to  supporting  the  development  of  a 
common standard for fighting cancer. This reflects the committee’s understanding that many 
advances in the field of cancer require common policy driven at European level. The working 
document  of  27 October  2020  is  consistent  with  the  other  strands  of  the  consultation.  It 
emphasises:  (i)  global  prevention  (through  action  on  tobacco,  alcohol,  diet,  exercise, 
environment and links to the Green Deal); (ii) screening and early detection; (iii) equality of 
access  to  patient-oriented  treatments  (with  reference  made  to  the  role  of  the  European 
medicines  market);  and  (iv)  the  need  to  support  patients  and  caregivers.  The  working 
document  also  identified  the  following  avenues  for  action:  (i)  holistic  research  and 
innovation;  (ii)  exchanging  knowledge  and  best  practices,  including  through  European 
reference  networks  and  cancer  registries;  and  (iii)  work  on  training  and  communication. 
Committee  members  also  voiced  their  concern  about  the  impact  of  COVID-19  on  the 
treatment of patients and of the potential postponement of early diagnosis. 

Meetings of Commissioner Kyriakides with key stakeholders 

In January 2020, Commissioner Kyriakides began meeting with key stakeholders engaged on 
the issue of fighting cancer. These stakeholders’ positions echoed those expressed above. 

Other outreach activities 

At  DG  level,  the  Directorate-General  for  Health  and  Food  Safety  has  participated  in 
conferences and meetings of stakeholder organisations. Stakeholders expressed positions very 
closely aligned to those gathered through other consultation activities. 

e. 

INTERDEPENDENCIES  AND  CONSISTENCIES 
STAKEHOLDERS  

IN  THE  CONTRIBUTIONS  FROM 

There  is  a  high  degree  of  consistency  between  the  stakeholder  contributions  across  the 
different  groups  and  between  the  findings  emerging  from  each  of  the  consultation  strands. 
The primary concerns of stakeholder groups are listed below. 

Patients,  patient  groups,  survivors,  and  the  public:  Many  of  the  concerns  expressed  by 
individuals, patient groups, survivors and carers were about the quality of care. These groups 
called for a more patient-centred approach and more consistent standards. They also called for 
psychosocial  and  mental-health  support  and  for  training  health  professionals  so  they  could 
work in multidisciplinary teams and communicate better. This group also said that the voice 
of  patients  should  be  taken  into  consideration  when  designing  pathways  of  cancer  care  and 

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wider policy. In addition, these groups were more concerned than any other stakeholder group 
about helping cancer survivors.  

Like other stakeholder  groups, patients,  patient  groups and the public also advocated for an 
EU role in data sharing, harmonising standards, and fostering innovation. They also showed a 
strong  commitment  to  addressing  inequalities  between  and  across  countries.  They  made 
specific  and  repeated  calls  for:  (i)  greater  attention  to  be  paid  to  paediatric  cancers;  (ii)  a 
stronger  role  for  European  reference  networks;  and  (iii)  the  EU  to  address  commercial 
determinants. 

Patient  groups  also  shared  specific  concerns  about:  their  role;  the  scope  for  independent 
funding; health literacy; and communications.  

Professionals  and  professional  associations:  There  was  considerable  overlap  between  the 
concerns  of  this  group  and  the  concerns  of  patients  and  survivors.  Professionals  and 
professional  associations  had  a  clear  focus  on  prevention  and  strong  concerns  about  fair 
access  for all patients  to treatment,  particularly for medicines. Professionals  also  recognised 
the  need  to  support  multidisciplinary  working  (and  the  importance  of  nurses,  general 
practitioners  and  specialists)  and  better  focus  on  patients.  Paediatric  cancers  also  featured 
strongly among the concerns of professionals and professional associations.  

This  group  shared  the  concern  around  data  also  felt  by  patients  and  survivors.  However, 
professionals and professional associations placed greater stress on: (i) the role of the EU in 
fostering  data  interoperability;  (ii)  the  role  of  cancer  registries  and  cancer  registry 
collaboration; and (iii) the scope for European-wide work on digitalisation and big data. This 
resonated with their interest in the EU’s potential for fostering appropriate research including: 
(i)  cross-border  clinical  trials;  (ii)  translational,  implementation  and  organisational  research; 
and  (iii)  outcome-based  research.  Professionals  and  professional  associations  also  called  for 
the  development  and  validation  of  new  diagnostic  methods  with  a  focus  on  efficiency  and 
cost-effectiveness. 

Research, scientific and public-health organisations: this group of stakeholders also echoes 
some of the concerns of the other two stakeholder groups. Issues of particular importance to 
research,  scientific  and  public-health  organisations  included  prevention,  diagnosis  and 
treatment.  

On prevention, this stakeholder group focused strongly on the action that needed to be taken 
against  risk  factors  (particularly  alcohol,  but  also  smoking,  diet,  exercise,  and  exposure  to 
carcinogenic substances). They also focused on HPV vaccination. In addition, this stakeholder 
group  stressed  the  role  of  information,  awareness,  education  and  health  literacy.  The  group 
also  raised  specific  points  about:  (i)  using  risk-assessment  tools  to  better  target  cancer 
screening;  (ii)  new  diagnostic  and  assessment  tools;  (iii)  EU  work  on  the  harmonisation  of 
treatment  protocols  to  ensure  common  standards  and  quality  of  care;  and  (iv)  paediatric 
cancers.  Research  and  innovation  were  important  to  these  stakeholders.  For  example,  they 
brought  up:  (i)  the  use  of  genetic  information  and  personalised  treatment;  (ii)  support  for 
understudied cancers; and (iii) drug development. These stakeholders also called for the EU 

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to: (i) promote reference networks; (ii) encourage networking and data sharing; and (iii) foster 
international academic research platforms via the Horizon Europe cancer mission.  

These  stakeholders  agreed  that  equality  of  access  across  countries  and  universal  health 
coverage were EU issues. They hoped for more centralised health-technology assessment and 
a European cancer fund. 

Industry  and  the  private  sector:  These  stakeholders  focused  most  on:  (i)  innovative 
approaches;  (ii)  personalised  medicine;  (iii)  the  use  and  reimbursement  of  biomarkers;  and 
(iv) real-world evidence platforms for personalised solutions. They called for action to cut the 
time taken to deliver innovation (‘time to patient access’) across Member States, including by 
‘smoothing’ perceived barriers in the regulation process. They supported the cancer mission 
and hope to see the EU foster: (i) public-private partnerships in health care; (ii) pan-European 
multi-stakeholder fora; (iii) pan-European fast-track funding/reimbursement models; and (iv) 
the  use  of  structural  and  cohesion  funds  to  equalise  access  to  innovation  for  resource-
constrained countries.  

They also shared common ground with the other stakeholders, particularly in emphasising the 
importance  of  patients  and  carers;  long-term  survival  and  co-morbidities;  and  paediatric 
cancers.  This  stakeholder  group  also  promoted  value-based  care.  On  screening  and  on 
biomarkers,  they  wished  to  go  beyond  the  areas  suggested  by  the  cancer  community. 
However, like the cancer community, this stakeholder group stressed the importance of early 
diagnosis.  They were also enthusiastic about  the prospect of:  (i) EU  action on data sharing; 
(ii) a pan-European, electronic cancer registry; and (iii) monitoring of the implementation of 
the  plan  through  a  ‘dashboard’  to  capture  progress.  Some  industry  groups  suggested  that 
vaping was a suitable harm-reduction measure, a view also present in online comments.  

Member States and public authorities: the views of this stakeholder group are presented in 
some  detail  above,  but  there  is  considerable  overlap  between  their  views  and  those  of  the 
other stakeholders consulted. Member States placed the greatest emphasis on research and on 
data sharing as key areas of EU added value. 

International agencies: The International Agency for Research on Cancer, the Organisation 
for  Economic  Cooperation  and  Development  and  the  World  Health  Organization  (Regional 
Office for Europe and Headquarters) agreed strongly with the other stakeholders. These three 
organisations  emphasised:  (i)  prevention;  (ii)  encouraging  the  setting  of  standards  for  early 
diagnosis  and  evidence-based  screening;  (iii)  endorsing  a  European  approach  to  patient 
centredness; (iv) data sharing and data harmonisation; (v) the use of non-traditional outcome 
measures; and (vi) support for registries. They also expressed interest in value-based care, and 
were particularly keen to see synergies across European initiatives and agencies. 

f.  MAIN MESSAGES FROM THE CONSULTATION PROCESS 

Overall,  there  is  very  strong  support  across  the  EU  for  Europe’s  beating-cancer  plan  and 
stakeholders called for a high-level of ambition for this plan. Stakeholders felt that a particular 
strength  of  the  plan  was  its  attempt  to  address  cancer  across  the  entire  cancer-control 
continuum.  This  support  for  a  holistic  approach  is  echoed  in  the  high  approval  ratings  that 
stakeholders  gave  to  all  four  pillars  of  the  plan  and  by  stakeholders’  commitment  to 
monitoring  and  evaluation  to  ensure  the  plan  helps  creates  real  change.  Stakeholders  also 

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consider that  an EU dimension in  addressing  cancer  adds significant  value, highlighting the 
Commission’s ability to work across sectors and with a ‘health in all policies’ approach. 

Addressing  risk  factors  in  a  comprehensive  way  was  widely  held  to  be  important.  Cancer 
prevention  is  expected  to  pay  dividends  by  reducing  the  effects  of  other  chronic  non-
communicable diseases.  

There  was  also  consistent  support  for  an  EU  role  in  optimising  existing  screening 
programmes (validating and strengthening the organisation, quality and monitoring of these 
programmes).  The  community  was  also  positive  about  the  EU’s  role  in  developing  new, 
effective  and  efficient  screening  programmes,  although  there  was  disagreement  on  what  to 
screen for. Stakeholders saw early detection as another area where the EU had an important 
role to play in promoting standardisation, evidence-based best practices, quality, and fairness. 

Stakeholders also felt that the EU was well placed to identify best practices, treatment and 
‘stratified’  patient  pathways.  They  encouraged  the  EU  to  look  beyond  treatment  to  wider 
patient  pathways,  covering  the  entire  patient  experience  from  start  to  finish,  including 
survivorship and social experience.  

The European reference networks were valued by all stakeholders. There was widespread 
support for greater funding to extend the pioneering role of these networks from work on rare 
diseases,  paediatric and rare cancers to: (i) wider research;  (ii) sharing of best  practices and 
guidelines; and (iii) collaboration. 

Stakeholders  also  stressed  the  importance  of  supporting  cancer  survivors.  Groups 
highlighted  a  range  of  (patient-informed)  approaches,  including:  (i)  survivorship  follow-up; 
(ii) care plans and infrastructures; and (iii) interoperable IT tools. They hoped that EU support 
would help to roll out best practices to all patients, regardless of their income. 

Stakeholders worried that it was not always possible to ensure equal access for all to quality 
cancer  care  and  they  all  hoped  that  Europe’s  beating-cancer  plan  would  address  this.  All 
groups stressed the importance of inclusivity, so that  all patient groups (including children 
and the elderly) and vulnerable populations could be appropriately covered.  

Finally,  stakeholders  stressed  their  belief  that  the  EU  has  a  key  role  to  play  in  cancer 
research.  They  believe  that  coordinated  European  action  is  the  route  to  efficient,  effective 
and rapid solutions to existing and emerging challenges. 

4.  HOW FEEDBACK WAS TAKEN INTO ACCOUNT 

Stakeholder views on Europe’s beating-cancer plan were analysed and taken into account as 
much  as  possible.  These  views  covered  the  plan’s  structure,  key  principles,  implementation 
and governance. 

After the stakeholders gave their overall endorsement of the plan, the Commission maintained 
and  refined  its  holistic  method  across  the  four  pillars  and  using  its  ‘health  in  all  policies’ 
approach. It did so to take account of cross-cutting issues and to improve connections between 
the pillars for greater impact.  

The  Commission  is  considering  strong,  cross-sectoral  actions  to  prevent  cancer.  It  is  aware 
that not all measures suggested during the consultation process will be politically feasible. A 

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key focus of Commission actions in the area of early detection and screening will be to update 
and  further  implement  existing  screening  recommendations.  It  will  also  consider  –  on  the 
basis of solid and robust evidence – extending these recommendations to other cancer types. 
The Commission recognises the great importance attributed by stakeholders to the sharing of 
best practices across the entire cancer-control continuum. They also understand stakeholders’ 
particular  commitment  to  the  importance  of  areas  such  as  quality  of  life  for  cancer  patients 
and  survivors.  The  Commission  has  noted  the  strong  call  to  strengthen  and  build  on  the 
existing European reference networks, and will consider this call. The Commission will also 
consider  other  initiatives  supported  through  the  EU4Health  programme  and  other  funding 
instruments.  

In  addition,  the  stakeholders  highlighted  several  issues,  which  appear  not  to  have  been 
sufficiently addressed in the roadmap. These issues include paediatric cancers, upskilling the 
health  workforce,  improving  health  information,  and  the  impact  of  communicable  diseases 
(COVID-19) on cancer patients and care. These will be considered in the development of the 
plan.  

Stakeholders  also  underlined  the  importance  of  the  EU’s  role  in:  (i)  cancer  research;  (ii) 
improving data and sharing knowledge; and (iii) facilitating cross-country collaboration. The 
Commission is now reflecting on this role and how it can further develop it. The Commission 
continues to develop the whole plan while keeping in mind cross-cutting issues on: (i) patient-
centred and citizen-centred approaches; (ii) access to all stages of the cancer-care continuum; 
and (iii) fairness across the entire care continuum. 

The consultation also showed a strong desire for the plan to be effectively implemented based 
on realistic goals that are systematically monitored and evaluated. 

Many actions proposed by stakeholders in the consultation touch upon – or are the exclusive 
competence  of  –  Member  States.  Implementing  these  actions  will  therefore  depend  on 
Member States’ ambition to take comprehensive cancer action. The Commission is prepared 
to support and complement Member State actions in this area.  

The consultation also revealed a variety of different views, many of which were very detailed 
and technical. It will be more appropriate to consider these views during the implementation 
phase  of  the  plan,  and  several  of  the  proposed  actions  will  require  separate  impact 
assessments  for  the  implementation  phase.  Results  from  this  implementation  may  alter  the 
approach  taken  at  EU  level  over  time.  However,  it  must  also  be  acknowledged  that  the 
complete set of suggestions from stakeholders is almost limitless in its overall ambition. 

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