A/HRC/7/11 page 23 97. Before their finalization, key elements of the draft plan must be subject to an impact assessment to ensure that they are likely to be consistent with the State’s national and international legal obligations, including those relating to the right to the highest attainable standard of health. For example, if the draft plan proposes the introduction of user fees for health services, it is vital that an impact assessment is undertaken to anticipate the likely impact of user fees on access to health services for those living in poverty. If the assessment confirms that user fees are likely to hinder access, the draft plan must be revised before adoption; otherwise, it is likely to be inconsistent with the State’s obligations arising from the right to the highest attainable standard of health.41 98. Of course, planning is only the means to an end: an effective, integrated health system that is accessible to all. The main task is implementation. Evaluation, monitoring and accountability can help to ensure that all those responsible for implementation discharge their duties as planned, and that any unintended consequences are swiftly identified and addressed. (b) Monitoring and accountability 99. As already discussed, monitoring and accountability have a crucial role to play in relation to human rights and health systems. Accountability provides individuals and communities with an opportunity to understand how those with responsibilities have discharged their duties. Equally, it provides those with responsibilities the opportunity to explain what they have done and why. Where mistakes have been made, accountability requires redress. But accountability is not a matter of blame and punishment. It is a process that helps to identify what works, so it can be repeated, and what does not, so it can be revised. It is a way of checking that reasonable balances are fairly struck. 100. In the context of health systems, there are many different types of accountability mechanisms, including health commissioners, democratically elected local health councils, public hearings, patients’ committees, impact assessments, judicial proceedings, and so on. An institution as complex and important as a health system requires a range of effective, transparent, accessible, independent accountability mechanisms. The media and civil society organizations have a crucial role to play. 101. Accountability in respect of health systems is often extremely weak. Sometimes the same body provides health services, regulates and holds to account. In some cases, accountability is little more than a device to check that health funds were spent as they should have been. Of course, that is important. But human rights accountability is much broader. It is also concerned with ensuring that health systems are improving, and the right to the highest attainable standard of health is being progressively realized, for all, including disadvantaged individuals, communities and populations. 41 With Gillian MacNaughton, the Special Rapporteur co-authored a report on impact assessments, poverty and the right to the highest attainable standard of health; for an outline see A/62/214 from paragraph 33. The full report is available from the website of Essex University, Human Rights Centre, Right to Health Unit (http://www2.essex.ac.uk/human_rights_centre/ rth/projects.shtm).