Global Project for the Evaluation of the Global Commission on HIV and the Law

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Title Global Project for the Evaluation of the Global Commission on HIV and the Law
Atlas Project Number: 00063928
Evaluation Plan: 2018-2021, Bureau for Policy and Programme Support
Evaluation Type: Final Project
Status: Completed
Completion Date: 02/2021
Planned End Date: 03/2021
Management Response: Yes
UNDP Signature Solution:
  • 1. Governance
  • 2. Sustainable
Corporate Outcome and Output (UNDP Strategic Plan 2018-2021)
  • 1. Output 1.2.1 Capacities at national and sub-national levels strengthened to promote inclusive local economic development and deliver basic services including HIV and related services
SDG Goal
  • Goal 1. End poverty in all its forms everywhere
  • Goal 10. Reduce inequality within and among countries
  • Goal 12. Ensure sustainable consumption and production patterns
  • Goal 16. Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
  • Goal 3. Ensure healthy lives and promote well-being for all at all ages
  • Goal 9. Build resilient infrastructure, promote inclusive and sustainable industrialization and foster innovation
SDG Target
  • 1.2 By 2030, reduce at least by half the proportion of men, women and children of all ages living in poverty in all its dimensions according to national definitions
  • 1.a Ensure significant mobilization of resources from a variety of sources, including through enhanced development cooperation, in order to provide adequate and predictable means for developing countries, in particular least developed countries, to implement programmes and policies to end poverty in all its dimensions
  • 10.2 By 2030, empower and promote the social, economic and political inclusion of all, irrespective of age, sex, disability, race, ethnicity, origin, religion or economic or other status
  • 10.3 Ensure equal opportunity and reduce inequalities of outcome, including by eliminating discriminatory laws, policies and practices and promoting appropriate legislation, policies and action in this regard
  • 12.4 By 2020, achieve the environmentally sound management of chemicals and all wastes throughout their life cycle, in accordance with agreed international frameworks, and significantly reduce their release to air, water and soil in order to minimize their adverse impacts on human health and the environment
  • 16.b Promote and enforce non-discriminatory laws and policies for sustainable development
  • 3.3 By 2030, end the epidemics of AIDS, tuberculosis, malaria and neglected tropical diseases and combat hepatitis, water-borne diseases and other communicable diseases
  • 3.4 By 2030, reduce by one third premature mortality from non-communicable diseases through prevention and treatment and promote mental health and well-being
  • 3.9 By 2030, substantially reduce the number of deaths and illnesses from hazardous chemicals and air, water and soil pollution and contamination
  • 3.a Strengthen the implementation of the World Health Organization Framework Convention on Tobacco Control in all countries, as appropriate
  • 3.b Support the research and development of vaccines and medicines for the communicable and non-communicable diseases that primarily affect developing countries, provide access to affordable essential medicines and vaccines, in accordance with the Doha Declaration on the TRIPS Agreement and Public Health, which affirms the right of developing countries to use to the full the provisions in the Agreement on Trade-Related Aspects of Intellectual Property Rights regarding flexibilities to protect public health, and, in particular, provide access to medicines for all
  • 9.4 By 2030, upgrade infrastructure and retrofit industries to make them sustainable, with increased resource-use efficiency and greater adoption of clean and environmentally sound technologies and industrial processes, with all countries taking action in accordance with their respective capabilities
Evaluation Budget(US $): 100,000
Source of Funding: UBRAF
Evaluation Expenditure(US $): 149,399
Joint Programme: No
Joint Evaluation: No
Evaluation Team members:
Name Title Email Nationality
Laura Ferguson Director, Programme on Global Health and Human Rights, Uni. of Southern California laura.ferguson@med.usc.edu
Sofia Gruskin Director, Institute on Inequalities in Global Health, Uni. of Southern California gruskin@med.usc.edu
GEF Evaluation: No
Key Stakeholders: Government, CSOs and UN partners
Countries: GLOBAL
Lessons
1.

LESSONS LEARNED

2. CRITICAL FACTORS OF THE COMMISSION’S SUCCESS
The section presents some conclusions around the impacts of the Global Commission starting with some overarching findings, and then in relation to the UNDP evaluation criteria of relevance, effectiveness, and sustainability.
The success is evident from the wide use of the Commission report from 2012 to the present day as well as citations of the Global Commission’s reports and recommendations across different types of publications, researchers, policy makers and implementers. From increasing understanding of the links between the law, human rights and HIV (and other areas of health) to expanding notions of what ‘counts’ as evidence to include testimony and civil society voices alongside more traditional evidence, the Commission provided a strong foundation on which others are already building.
The other primary aim of the Global Commission was to provide evidence-informed and actionable recommendations for law and policy reform. The Commission did indeed provide a long list of evidence-informed and actionable recommendations that have since been taken up at global, regional and national levels.
2.1. Relevance:
a.    Participatory approach
Across all levels – global, regional and national – attention to human-rights was seen as critical to the success of the Global Commission’s work. This started with the inclusive, participatory approach fostered through the regional dialogues carried out around the world as a part of developing the Global Commission’s original report. These regional-level consultations, along with written submissions from around the world, not only enabled useful connections within and across regions, but generated buy-in by a wide range of stakeholders and, importantly, resulted in ownership and connections within countries, sowing seeds for collaborative follow-up to implement the Commission’s recommendations at the national-level actions.

b.    Continued Relevance
Follow-up meetings and activities, including in relation to the supplement that was published in 2018, demonstrated the Commission was still a relevant body to external actors: while many of the topics from the original report remained relevant, as science had evolved other topics had also become relevant for analysis using the Global Commission’s lens. UNDP’s ongoing commitment to promoting action resulting from the work of the Commission, maintaining an updated website to serve as a resource for work in this area, and expanding attention to emerging areas of relevance within HIV and the law (e.g. interactions with responses to COVID-19) continues to contribute to the ongoing relevance and visibility of the work of the Commission today and into the future.


2.2. Effectiveness:
c.    Commitment to follow up work
From its inception, the Global Commission made clear it saw the report as part of a much larger strategy to improve HIV-related legal environments around the world which has ultimately contributed to its overall success. Senior UNDP leadership made clear that following up on Commission recommendations was part of the institutional mandate at regional and national levels, which led to support for activities across UNDP globally.  Many others, including civil society organizations and international development partners, have also invested time and resources in the recommendations and approaches championed by the Commission.
d.    Respect for Commissioner and other key participants
The collective experience and capacity of the Commissioners, their independence, and clear investment in the work was a factor that contributed immensely to the report and its recommendations being taken seriously. The Commissioners and the Technical Advisory Group, along with affiliations to the United Nations provided for strong credibility for what they set out to accomplish. Civil society, strongly engaged from the beginning of the Global Commission, are seen to be key participants in this work and have been instrumental in follow-on work that continues today.
e.    Adoption of a human rights-based approach
In grounding the Global Commission process in a human rights-based approach, follow-up activities and ensuing work has been organized according to the same principles of participation, equality, and non-discrimination and accountability. Participation was a major conduit to the effectiveness of the Commission in that it allowed for interventions to be tailored to respond directly to local realities and account for local factors such as politics, legal systems, epidemiological trends, and civil society capacity.
f.    Meaningful engagement of communities: the value of personal testimony
Emphasis was placed on representation from civil society and communities in the form of fully integrated written submissions to as well as participation in the initial regional dialogues. This paved the way for direct engagement between communities and duty bearers, in addition to showcasing the value of personal testimony as data. Testimony had previously been valued primarily in legal work, rather than public health, policy or government offices more generally. Inclusion of this testimony alongside quantitative data and legal judgments in the Commission’s report proved effective for the overall accessibility of the reports. Furthermore, it provided civil society with another advocacy tool and decision-makers with another type of evidence through which ongoing follow-up work could be evaluated.
g.    New partnerships and collaboration
The Global Commission was pioneering in bringing together such a wide range of stakeholders to collaborate on improving HIV-related legal environments. This multi-stakeholder approach is now much more common around the world. Perhaps one of the most influential partnerships catalysed by the Global Commission process is the HIV activist movement connection with the movement around the reform of intellectual property regimes, strengthening the advocacy base for access to HIV medications.


2.3. Sustainability:
h.    Financial Sustainability
Although some activities have yielded impacts that constitute fundamental transformations to the landscape that may help this work to move forward even without continued financial investment, other activities initiated as follow-on to the work of the Global Commission will require continued funding in order to be sustained. This is true for capacity building activities, regional convenings and support to strategic litigation for example. Financial support for these activities is critical for advances to continue.
i.    Weathering political winds
Politics and ideology continue to influence laws and policies regardless of solid evidence. Changes in government can erase hard fought wins. The Global Commission’s effort to apply an evidence-informed approach to addressing the role of law in the HIV response together with efforts around capacity building help to ensure that where negative political shifts happen, these changes will not completely erase all progress. The multi-sectoral nature of follow-on work and the increased capacity of civil society have immense implications for sustainability and resilience in the face of negative political climates.

 


Findings
1.

FINDINGS

In 2010, UNDP, on behalf of the Joint UN Programme on HIV/AIDS (UNAIDS), convened the Global Commission on HIV and the Law (the Global Commission) to examine legal and human rights issues through an HIV lens. The goal of the evaluation was to assess the impact of the Global Commission on HIV and the Law based on its stated aims of contributing to the evidence base on the relationship between HIV, human rights and legal environments; and providing evidence-informed and actionable recommendations for law and policy reform.

The objectives of the evaluation were:
1.    Assessment of the impact of the Commission’s report and follow up including the following:

1.1.    Global and regional advocacy and resource flow
1.2.    Global, regional and national policy and programming
1.3.    National laws and policies (including number of laws changed but also, to the extent possible, how the Commission contributed)

2.    Analysis of the critical success factors for the Commission’s success
1.1. IMPACT ON GLOBAL AND REGIONAL ADVOCACY AND RESOURCE FLOW

The impacts of the Global Commission’s work at the global level are multi-faceted and complex. There are three areas where its impacts have been particularly visible: other global level processes, the advancement of substantive discussions related to HIV and the law, and the promotion of collaborative learning and action. The Global Commission acted as a critical platform to open up the global response around HIV and the law, influencing global discussions and actions and facilitating other partners’ exploration and financing of these issues.

There is clear subsequent alignment between the priorities and strategies of some other global institutions such as UNAIDS and the Global Fund with the Global Commission’s work and recommendations, including with respect to legal environment assessments at country level. For example, the UNAIDS 2016-2021 On the Fast Track to End AIDS, the Global Fund 2017-2022 Investing to End the Epidemics and the PEPFAR’s PEPFAR 3.0—Controlling the Epidemic: Delivering on the Promise of an AIDS-Free Generation strategies all highlight the role of human rights and the law in the HIV response as part of their approaches, an area which had not previously been so explicit in their strategic materials. With respect to the Global Fund specifically, one key informant reported that it was only following the 2012 report that there was an effort by the Fund to reshape a strategic objective on human rights and gender.

The influence of the Global Commission on UNDP’s work is also evident: leveraging the Commission’s work, UNDP expanded its HIV and health portfolio and used findings to inform institutional strategies such as the UNDP HIV, Health and Development Strategy 2016-21 and the UNDP Strategic Plan 2018-21.

1.2. IMPACT OF GLOBAL, REGIONAL AND NATIONAL POLICY AND PROGRAMMING
The Global Commission’s influence on other global initiatives has had subsequent spill-over effects on legal environments in the areas of criminalization of HIV, intellectual property, drug policy, sex work and sexual minorities, and access to medicines.
a.    International Guidelines on Human Rights and Drug Policy
As just one example, presented in depth in the Evaluation Report, UNDP and a group of UN Member States, World Health Organization (WHO), International Centre on Human Rights and Drug Policy (HRDP), the Office of the United Nations High Commissioner for Human Rights (OHCHR), and the Joint United Nations Programme on HIV/AIDS (UNAIDS), jointly released the International Guidelines on Human Rights and Drug Policy in 2019. There was explicit acknowledgment in the Guidelines that they drew extensively from the recommendations and follow-up activities of the Global Commission, in that they were designed to act as international standards that serve to advance human rights protections in the context of drug control policy. These Guidelines in turn were explicitly cited in a 2019 court ruling on drug use in Colombia by a Constitutional Court judge.  

b.    Global HIV, Health and Development Agendas
While the Commission was still active, the 2030 Agenda for Sustainable Development was established, with the Sustainable Development Goals (SDGs) replacing the MDGs. Two key parts of that commitment were the goal to “leave no one behind,” and a push for Universal Health Coverage by 2030. The Global Commission’s work can be seen to have informed key components of both. For example, building on the Global Commission recommendation that countries remove legal barriers that impede women’s access to sexual and reproductive health services, a similar SDG target maintains that states must “ensure universal access to sexual and reproductive health and reproductive rights,” and a UHC Key ask suggests that states must “establish resilient, responsive and inclusive health systems that are accessible to all.”

c.    High-Level Panel on Access to Medicines
The Commission suggested the creation of a High-Level Panel on Access to Medicines (High-Level Panel), which was ultimately convened by the Secretary General of the UN, Ban-Ki Moon, in 2015 after a joint request from UNDP and UNAIDS. The High-Level Panel was tasked to  “review and assess proposals and recommend solutions for remedying the policy incoherence between the justifiable rights of inventors, international human rights law, trade rules and public health in the context of health technologies.” The High-Level Panel would go on to have a wide array of impacts globally, regionally and nationally, featuring prominently in the decisions of a range of multilateral organizations, global trade agreements and civil society organizations.


d.    Global Efforts to Challenge HIV-related Criminalization
The Global Commission is widely considered a catalyst in efforts to address HIV-related criminalization around the world, which are explored in more depth in the Evaluation Report. Through the consultation processes, networks and synergies created through Global Commission processes, clear momentum was built around tackling these issues. Additionally, the 2012 report provided stakeholders with a critical advocacy tool. Organizations such as Amnesty International, in conjunction with CREA, Realizing Sexual and Reproductive Justice, and Accountability International, for example, have worked together using recommendations from the Commission to challenge criminalization around sexuality, reproduction, gender and drug use.
e.    Africa Key Populations Expert Group
The Africa Key Populations Expert Group (AKPEG) was formed in 2014 as direct follow up to the Global Commission with the purpose of developing interventions to advance engagement of key populations in the HIV response and help the Regional Economic Communities develop regional HIV strategies for key populations. The AKPEG has grown to more than 105 members since its inception with members from 16 countries. The AKPEG is widely known to have aided the representation of key populations in regional and national responses to HIV and to have been central to the development of the Southern African Development Community (SADC) key population strategy.
Since the release of the 2012 Risks, Rights and Health report, a series of regional-level HIV-specific initiatives and law and policy reform efforts have been carried out with different regional entities around the world including the African Union Commission, the African Regional Economic Communities, the South Asian Association for Regional Cooperation, the South American Regional Economic Organization and the Caribbean Community.  While each effort differs, key initiatives have included the adoption of model laws, development of regional strategies, mobilization of civil society and key populations, and strategic litigation on issues raised during Global Commission consultation. These efforts, documented in the full Evaluation Report, have helped to facilitate deeper thinking around legal environments and HIV, with improved cross-sectoral engagement and increased civil society action.
1.3. IMPACT ON NATIONAL LAWS AND POLICIES
National level implementation of follow-up activities built on the success at the regional level in the form of national and sub-national activities. By the end of 2019, UNDP had either provided funding or support to 89 countries striving to implement Global Commission recommendations. The range of activities includes empowering key populations to promote human rights based HIV approaches, Legal Environmental Assessments; dialogues with and capacity strengthening of law enforcement officials; national dialogues; dialogues with and capacity strengthening of parliamentarians; law review and legal scans; dialogues with members of the judiciary; sensitization and dialogues with other key stakeholders; and civil society engagement scans.
Building on regional successes, Global Commission activities have fostered an inclusive, participatory approach that brought together government and civil society actors with the effect of establishing useful connections regionally and within national-level contexts. The regional dialogue approach has also been replicated in the form of national dialogues in 34 countries.
Many examples exist of court rulings at national level that were influenced by the Global Commission or its follow-up work. For example, in 2018, the Supreme Court overturned Section 377 of the Indian Penal Code which stated that “carnal intercourse against the order of nature” was a criminal offense punishable by life imprisonment.” The case effectively decriminalized homosexuality in India while simultaneously recognizing the identities of LGBT persons within the country. Evidence presented by the Commission report was used by the court in the lead-up to their ultimate decision. In addition, in 2015, the Botswana Court of Appeal upheld a ruling that foreign prisoners should receive free HIV treatment.15 In this case, judges who had attended the Regional Judges’ Forum were presiding.


Recommendations
1

Evaluation recommendation 1.
Use the evaluation report to inform the design and implementation of future partnership initiatives
 

2

Evaluation recommendation 2.
Apply the lessons to the COVID-19 response and future outbreaks/epidemics/pandemics
 

3

Evaluation recommendation 3.
Incorporate approaches, methodologies, and tools in processes to strengthen evidence- and rights-based national laws, policies, and practices
 

4

Evaluation recommendation 4. Sustain and adapt regional level activities

 

5

Evaluation recommendation 5. Support capacity building of stakeholders through peer networks
 

1. Recommendation:

Evaluation recommendation 1.
Use the evaluation report to inform the design and implementation of future partnership initiatives
 

Management Response: [Added: 2021/05/18]

Accepted: The evaluation report can inform how UNDP and other institutions might design and implement future partnerships with global, regional, and local government, civil society, UN, and academic partners to address complex health and development issues. UNDP will apply the lessons learned from the evaluation of the Global Commission on HIV and the Law to future partnerships. Critical to the implementation of this recommendation is the dissemination of the lessons from the evaluation within UNDP and with other stakeholders. A stakeholder meeting to disseminate the findings of the evaluation is planned for 25 May 2021.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
1.1 Dissemination of the findings of the evaluation of the Global Commission on HIV and the Law
[Added: 2021/05/18] [Last Updated: 2021/08/16]
Health Team 2021/06 Completed 1.1. UNDP organized a webinar to disseminate the findings of the evaluation findings. The event featured a high-level panel consisting of representatives of governments, civil society and UN entities. A recording of the event may be found at: https://hivlawcommission.org/evaluation-of-the-global-commission-on-hiv-the-law/. The evaluation report and an executive summary have also been posted on the website of the Global Commission on HIV and the Law as part of dissemination efforts aimed at reaching a broader audience. History
2. Recommendation:

Evaluation recommendation 2.
Apply the lessons to the COVID-19 response and future outbreaks/epidemics/pandemics
 

Management Response: [Added: 2021/05/18]

Accepted. The lessons learnt documented in the evaluation report can inform the ways in which governments address COVID-19 and future outbreaks/epidemics/pandemics, and how best to strategically engage government as well as civil society and their allies in their response.  UNDP and partners are applying lessons from the HIV response and the work to support countries to follow up on the recommendations of the Global Commission to inform COVID-19 responses. This includes highlighting the impact of laws, policies, and gender-related barriers on effective, rights-based pandemic responses to COVID-19.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
2.1 Support evidence- and rights-based legal frameworks for COVID-19 responses
[Added: 2021/05/18]
Health Team 2021/09 Initiated History
2.2 Address gender-related barriers to COVID-19 response vaccine deployment
[Added: 2021/05/18] [Last Updated: 2021/08/16]
Health Team and the Gender Equality Working Group of the SDG 3 Global Action Plan 2021/06 Completed The Guidance Note and Checklist for Tackling Gender-related Barriers to Equitable COVID-19 Vaccine Deployment is being disseminated through a variety of websites including UNDP, WHO, GAVI, Gender and Health Hub, New York University, Global Health 50/50. A webinar was hosted by International Institute for Global Health, United Nations University on 3 June 2021 to disseminate the Guidance. Webinar site: https://www.eventbrite.com/e/tackling-gender-related-barriers-to-equitable-covid-19-vaccine-deployment-tickets-156226941989 History
3. Recommendation:

Evaluation recommendation 3.
Incorporate approaches, methodologies, and tools in processes to strengthen evidence- and rights-based national laws, policies, and practices
 

Management Response: [Added: 2021/05/18]

Accepted. The Global Commission’s investment in multi-stakeholder and multi-sectoral participation and country ownership its work and follow up has enhanced the sustainability of this work.  The evaluation report noted the impact of the methodology of conducting legal environment assessments [LEAs] for engaging a broad range of stakeholders and ensuring country ownership of recommendations for action. UNDP continues to use the LEAs to engage stakeholders and incorporate legal and policy reform efforts into national structures.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
3.1 Strengthening country ownership on advancing enabling legal and policy environments for the HIV response through legal environment assessments
[Added: 2021/05/18]
Health Team 2021/12 Initiated UNDP supported governments, civil society, and UN partners in 90 countries in reforming discriminatory laws and policies on HIV, TB and broader health issues that perpetuate exclusion and marginalization and contribute to poor health outcomes. A few examples of incorporating what started as UNDP-supported follow-up work into national strategies, plans and budgets as well as external funding proposals include: • UNDP supported the development of a strategy for mainstreaming HIV and human rights in the legal and regulatory framework in Sudan to ensure a systematic and comprehensive approach in the protection of the rights of PLHIV and key populations. • In Somalia, the recommendations of the UNDP-led LEA were successfully included in the revised National Strategic Plan and were prioritized in the Global Fund approved grant, which will provide an important opportunity for their implementation. • In Moldova, national authorities addressed two legal issues concerning the access to health services and family and private life arising from the LEA including enacting a regulation that established a uniform practice and excluded discrimination of people living with HIV in the process of adoption and determining guardianship. • In Nigeria, recommendations from the Global Commission on addressing human rights-related barriers for key populations access to services were incorporated into the country’s Global Fund HIV/TB grant. • UNDP is working with Parliamentarians for Global Action to sensitize members of parliament from the Eastern Caribbean region on their role in guaranteeing the rights of LGBTI persons in the region. UNDP will continue to support countries to implement and institutionalise the recommendations of the Global Commissions and national LEAs. For example, through the development of a national strategic plan on addressing HIV-related discrimination in Argentina; the training of correction officers on the treatment of transgender prisoners in Thailand; and supporting the adoption of a judicial curriculum on human rights, gender, HIV and the law in South Africa.
4. Recommendation:

Evaluation recommendation 4. Sustain and adapt regional level activities

 

Management Response: [Added: 2021/05/18]

Accepted. Sustaining regional programmes, especially on politically sensitive issues, will be important to maximize the overall impact at national level over time. UNDP will continue to strengthen the capacity of national duty-bearers and rights-holders to advance inclusive governance and strengthen HIV-related legal and policy environments, including for key populations who continue to bear a disproportionate burden of new HIV infections. For example, building on lessons from the Being LGBTI in regional projects highlighted in the evaluation report, UNDP is implementing the “Inclusive Governance Initiative” in Africa.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
4.1 Sustaining regional activities to advance inclusive governance
[Added: 2021/05/18]
Health Team 2023/03 Initiated The aim of the Inclusive Governance Initiative is to support countries in the Africa region to become increasingly accountable to, and inclusive of, their entire populations, including sexual and gender minorities. This in turn will contribute to better laws, more responsive public sector services, and social norms that affirm rights and inclusion for all. Key activities include strengthening the capacity of government officials to collect and analyse data on sexual and gender minorities, and building broad coalitions to promote inclusion for marginalized populations across six countries.
5. Recommendation:

Evaluation recommendation 5. Support capacity building of stakeholders through peer networks
 

Management Response: [Added: 2021/05/18]

Accepted. As noted in the evaluation report, the Global Commission on HIV and the Law supported the creation of peer networks of different types of duty-bearers and rights-holders across regions with the knowledge and commitment to drive work within and across countries to strengthen HIV-related legal and policy environments. UNDP will continue to carry out this work. The African Regional Judges’ Forum highlighted in the evaluation report has proven to be successful for advancing evidence- and rights-based legal environments and the rights of people living with and affected by HIV. The peer network model of the regional judges’ forum has been replicated in Eastern Europe and Central Asia, and in the Caribbean. UNDP will continue to support peer networks of people living with HIV and key populations globally and regionally.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
5.1 Addressing discriminatory and punitive law impacting HIV and health through strategic litigation
[Added: 2021/05/18]
Health Team 2022/06 Initiated UNDP is strengthening the capacity of national stakeholders including civil society and UN entities to use strategic litigation to challenge the discriminatory and punitive laws impacting HIV and health. Two global seminars bringing together 100 participants have provided opportunities for sharing legal strategies, providing technical support to the development of amicus briefs, and sharing lessons learned from strategic litigation efforts across five regions. More region-focused strategic litigation seminars and support are planned.

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