India has been in regular and in-depth technical exchange with the World Health Organization (WHO) on the issue of collecting and making public the COVID-19 death toll in the country, the Union Health Ministry said on Saturday in response to The New York Times article titled India Is Stalling the WHO’s Efforts to Make Global Covid Death Toll Public dated April 16.

The Ministry, in a statement, said that the analysis while using mortality figures directly obtained from Tier I set of countries, uses a mathematical modelling process for Tier II countries (which includes India). 

“India’s basic objection has not been with the result (whatever they might have been) but rather the methodology adopted for the same,” it said. 

The Ministry elaborated that India had shared its concerns with the methodology along with the other Member States through a series of formal communications, including six letters issued to the WHO (on November 17; December 20, 2021; December 28, 2021; January 11, 2022; February 12, 2022 and March 2, 2022) and virtual meetings held on December 16, 2021; December 28, 2021; January 6, 2022; February 25, 2022 and the SEARO Regional Webinar held on February 10, 2022. 

During these exchanges, specific queries had been raised by India along with the other Member States, which included China, Iran, Bangladesh, Syria, Ethiopia and Egypt, regarding the methodology and use of unofficial sets of data.

“The concern specifically includes on how the statistical model projects estimates for a country of geographical size & population of India and also fits in with other countries which have smaller population. Such one-size-fits-all approach and models which are true for smaller countries like Tunisia may not be applicable to India with a population of 1.3 billion,” it said, adding that the WHO was yet to share the confidence interval for the present statistical model across various countries.

It said the model gave two highly different sets of excess mortality estimates when using the data from Tier I countries and when using unverified data from 18 Indian States.

Such wide variation in estimates raised concerns about the validity and accuracy of such a modelling exercise, it said.

“India has asserted that if the model accurate and reliable, it should be authenticated by running it for all Tier I countries and if result of such exercise may be shared with all Member States.”

The Ministry said that while India had remained open to collaborating with the WHO as data sets like these would be helpful from the policy-making point of view, India believed that in-depth clarity on methodology and clear proof of its validity were crucial for policy makers to feel confident about any use of such data.

The Ministry added that it was surprising that while The New York Times purportedly could obtain the alleged figures of excess COVID-19 mortality in respect to India, it was “unable to learn the estimates for other countries”.

Meanwhile, Rashtra News, in an email, had asked the WHO about the methodology used and about listing India under Tier II countries.

It responded saying: “ We are currently finalizing these estimates and will publish them shortly.” 

“WHO has developed the estimates with support from a Technical Advisory Group of international experts who have helped develop a robust methodology and the best estimates based on all available data. We have held extensive consultations with all countries, providing detailed explanations of the methods and data used to produce the estimates.”

The Health Ministry also said that the model used assumed an inverse relationship between monthly temperature and monthly average deaths, which did not have any scientific backing to establish such peculiar empirical relationship.

“India is a country of continental proportions. Climatic and seasonal conditions vary vastly across different States and even within a State and therefore, all States have widely varied seasonal patterns. Thus, estimating national level mortality based on these 18 States data is statistically unproven,” the Ministry said.

It added that the Global Health Estimates (GHE) 2019 on which the modelling for Tier II countries was based, was itself an estimate.

“During interactions with WHO, it has also been highlighted that some fluctuations in official reporting of COVID-19 data from some of the Tier I countries, including USA, Germany, France etc., defied knowledge of disease epidemiology. Further inclusion of a country like Iraq which is undergoing an extended complex emergency under Tier I countries raises doubts on WHO’s assessment in categorization of countries as Tier I/II and its assertion on quality of mortality reporting from these countries,” the Health Ministry said.