National Reporting Instrument 2024

Hide all

Background

Hide [INFOxNRI1] National Reporting instrument 2024
Hide [BGxINT] Background
Adopted in 2010 at the 63rd World Health Assembly (WHA Res 63.16), the WHO Global Code of Practice on the International Recruitment of Health Personnel (“the Code”) seeks to strengthen the understanding and ethical management of international health personnel recruitment through improved data, information, and international cooperation.

Article 7 of the Code encourages WHO Member States to exchange information on the international recruitment and migration of health personnel. The WHO Director General is mandated to report to the World Health Assembly every 3 years.

WHO Member States completed the 4th round of national reporting in May 2022. The WHO Director General reported progress on implementation to the 75th World Health Assembly in May 2022 (A75/14). The report on the fourth round highlighted the need to assess implications of health personnel emigration in the context of additional vulnerabilities brought about by the COVID-19 pandemic. For this purpose, the Expert Advisory Group on the relevance and effectiveness of the Code (A 73/9) was reconvened. Following the recommendations of the Expert Advisory Group, the Secretariat has published the WHO health workforce support and safeguards list 2023.

The National Reporting Instrument (NRI) is a country-based, self-assessment tool for information exchange and Code monitoring. The NRI enables WHO to collect and share current evidence and information on the international recruitment and migration of health personnel. The findings from the 5th round of national reporting will be presented to the Executive Board (EB156) in January 2025 in preparation for the 78th World Health Assembly.

The deadline for submitting reports is 31 August 2024.

Article 9 of the Code mandates the WHO Director General to periodically report to the World Health Assembly on the review of the Code’s effectiveness in achieving its stated objectives and suggestions for its improvement. In 2024 a Member-State led expert advisory group will be convened for the third review of the Code’s relevance and effectiveness. The final report of the review will be presented to the 78th World Health Assembly.

For any queries or clarifications on filling in the online questionnaire please contact us at WHOGlobalCode@who.int.

What is the WHO Global Code of Practice?

Disclaimer: The data and information collected through the National Reporting Instrument will be made publicly available via the NRI database (https://www.who.int/teams/health-workforce/migration/practice/reports-database) following the proceedings of the 78th World Health Assembly. The quantitative data will be used to inform the National Health Workforce Accounts data portal (http://www.apps.who.int/nhwaportal/).
Hide all

Disclaimer

Hide [INFOxNRI2] National Reporting instrument 2024
Hide [disclaim] Disclaimer

[1] Note: Case-based facility data collection as that in the WHO Global Bum Registry does not require WHO Member State approval.
[2] The world health report 2013: research for universal coverage. Geneva: World Health Organization; 2013 (http://apps.who.int/iris/bitstream/10665/85761/2/9789240690837_eng.pdf)
[3] WHO statement on public disclosure of clinical trial results: Geneva: World Health Organization; 2015 (http://www.who.int/ictrp/results/en/, accessed 21 February 2018).
For more information on WHO Data Policy kindly refer to http://www.who.int/publishing/datapolicy/en/
I have read and understood the WHO policy on the use and sharing of data collected by WHO in Member States outside the context of public health emergencies
Hide all

Contact Details

Hide [INFOxNRI3] National Reporting instrument 2024
Hide [CI] Contact Details
Name of Member State:
Barbados
Name of designated national authority:
Shakira Mascoll
Title of designated national authority:
Health Planning Officer
Institution of the designated national authority:
Ministry of Health and Wellness, Barbados
Email:
shakira.mascoll@health.gov.bb,WHOGlobalCode@who.int,cavalcaana@paho.org
Telephone number :
12465363834
Hide all

Contemporary issues

Hide [INFOxNRI4] National Reporting instrument 2024
Hide [NRIxI] The questions marked * are mandatory. The system will not allow submission until all mandatory questions are answered.
Hide [INFOx1]
Contemporary issues on health personnel migration and mobility
Hide [Q1x1] 1.1 In the past 3 years, has the issue of international recruitment of health personnel been a concern for your country?
Yes, and it is increasing in intensity

The Ministry is currently actively pursuing the recruitment of health personnel especially nurses to fill much needed gaps. This is particularly seen in the nursing and medical professions wherein in the countries in the Global North continue to offer better services and terms and conditions.

Hide [Q1x2] 1.2 In the past 3 years, has the issue of international reliance on health personnel (international recruitment of health personnel to meet domestic needs) been a concern for your country?
Yes, and it is increasing in intensity

Hide all

Health Personnel Education

Hide [INFOxNRI5] National Reporting instrument 2024
Hide [INFOx2]
Health personnel education, employment and health system sustainability
Hide [Q2] 2. Is your country taking measures to educate, employ and retain a health and care workforce that is appropriate for the specific conditions of your country, including areas of greatest need?
Yes
Hide [Q2x1] Please check all items that apply from the list below:
2.1 Measures taken to ensure the sustainability of the health and care workforce
2.2 Measures taken to address the geographical mal-distribution and retention of health and care workers*
2.3 Other relevant measures taken to educate, employ and retain a health and care workforce that is appropriate for the specific conditions of your country
Hide [Q2x1x1] 2.1.1 Measures taken to ensure the sustainability of the health and care workforce
Forecasting future health and care workforce requirements to inform planning
To some extent
Aligning domestic health and care workforce education with health system needs
To some extent, particularly in Nursing with the introduction of the Nurse Practitioner and Nurse Gerontology positions.
Improving quality of education and health personnel in alignment with service delivery needs
Above average
Creating employment opportunities aligned with population health needs
To some extent
Managing international recruitment of health personnel
Improving management of health personnel
To some extent
Specific provisions on health personnel regulation and recruitment during emergencies
Yes, this was demonstrated during COVID-19
Others
Hide [Q2x3x1] 2.3.1 Please describe - Other relevant measures taken to educate, employ and retain a health and care workforce that is appropriate for the specific conditions of your country.
Barbados has recruited over 300 nurses within the last 5 years from the global south to ensure that health care is provided adequately for the population. From time to time we have recruited medical staff to fill gaps in specific disciplines,
Hide [Q3x1] 3.1 Are there specific policies and/or laws that guide international recruitment, migration and integration of foreign-trained health personnel in your country?
Yes
Hide [Q3x1x1] 3.1.1 Please provide further information in the box below:
Law/policy 1
Bilateral agreement between Ghana and Barbados for the recruitment of nurses.
Law/policy 2
Bilateral agreement between Cuba and Barbados for the recruitment of nurses.
Law/policy 3
Hide [Q3x2] 3.2 Are there any policies and/or provision for international telehealth services in your country through health personnel based abroad?
Yes
Hide [Q3x2x1] Please describe
Telehealth services are used in specific disciplines for consultative, diagnostic and treatment services. These include internal medicine and psychiatry.
Hide [Q3x3] 3.3 Has your country established a database or compilation of laws and regulations related to international health personnel recruitment and migration and, as appropriate, information related to their implementation?
No
Hide [Q4] 4. Recognizing the role of other government entities, does the Ministry of Health have mechanisms (e.g. policies, processes, unit) to monitor and coordinate across sectors on issues related to the international recruitment and migration of health personnel?
Yes
Hide [Q4x1] Please describe
The Ministry of Foreign Affairs is integral to the process of fostering bilateral agreements.
Hide [Q5] 5. Please describe the steps taken by your country to implement the following Code recommendations.
Check all items that apply from the list below:
5.1 Measures have been taken or are being considered to introduce changes to laws or policies on health personnel consistent with the recommendations of the Code.
5.2 Actions have been taken to communicate and share information across
sectors on the international recruitment and migration of health personnel, as well as to publicize the Code, among relevant ministries, departments and agencies,
nationally and/or sub-nationally.
5.3 Measures have been taken to consult stakeholders in decision-making
processes and/or involve them in activities related to the international recruitment of health personnel.
5.4 Records are maintained on all private recruitment agencies for health
personnel authorized by competent authorities to operate within their jurisdiction.
5.5 Good practices, as called for by the Code, are encouraged and promoted among private recruitment agencies.
5.5a Promotion of the Code among private recruitment agencies.
5.5b Domestic legislation or policy requiring ethical practice of private recruitment agencies, as consistent with the principles and articles of the Code.
5.5c Public or private certification of ethical practice for private recruitment agencies.
5.5d Others
5.6 None of the above
Hide all

Government Agreements

Hide [INFOxNRI6] National Reporting instrument 2024
Hide [INFOx3]
Government-to-Government agreements on migration or mobility of health personnel
Hide [Q6] 6. Has your country or sub-national governments entered into any bilateral, multilateral, or regional agreements and/or arrangements with respect to the international recruitment and/or mobility of health personnel?
Yes
Hide [Q6x1xA] 6.1 A Please use the table below to describe each of the active bilateral, regional or multilateral agreements or arrangements:
a. Title of Agreement b. Type of Agreement
Agreement 1 Ghana 1
Agreement 2 Cuba 1
Agreement 3 Phillippines 1
Agreement 4 St. Vincent and the Grenadines 1
Agreement 5
Agreement 6
Agreement 7
Agreement 8
Agreement 9
Agreement 10
Agreement 11
Agreement 12
Agreement 13
Agreement 14
Agreement 15
Hide all

Government Agreements - 6.1 A

Hide [INFOxNRI7] National Reporting instrument 2024
Hide [Q6x1xAx1] c. Countries involved
Ghana
BRB
Cuba
BRB
Phillippines
BRB
St. Vincent and the Grenadines
BRB
Hide [Q6x1xAx2] d. Coverage
Ghana
National
Cuba
National
Phillippines
National
St. Vincent and the Grenadines
National
Hide [Q6x1xAx3] e. Main focus of agreement (check all that apply)
Education and training Health cooperation Promotion of circular migration Philanthropy or technical support Qualification recognition Recruitment of health personnel Trade in services Others
Ghana 1
Cuba 1
Phillippines 1
St. Vincent and the Grenadines 1
Hide [Q6x1xAx4] f. Categories of Health Personnel (check all that apply)
Doctors Nurses Midwives Dentists Pharmacists Other occupations
Ghana 1
Cuba 1
Phillippines 1
St. Vincent and the Grenadines 1
Hide [Q6x1xAx5] g. Validity period
Start Year End Year
Ghana n/a but current n/a
Cuba n/a n/a
Phillippines n/a n/a
St. Vincent and the Grenadines n/a n/a
Hide [Q6x1xAx6] h. Signatory of the agreement from your country
Ghana
Ministry of Health
Cuba
Ministry of Health
Phillippines
Ministry of Health
St. Vincent and the Grenadines
Ministry of Health
Hide [Q6x1xAx7] i. Signatory of the agreement from the partner country (ies)
Ghana
Others:
Cuba
Others:
Phillippines
Others:
St. Vincent and the Grenadines
Others:
Hide [Q6x1xAx7xoth] If other signatory of the agreement from your country(Please specify:)
Ghana
n/a
Cuba
n/a
Phillippines
n/a
St. Vincent and the Grenadines
n/a
Hide [Q6x1xAx7x1] If Ministry of Health is not a signatory, did the Ministry of Health participate in the development of the agreement?
Ghana
Yes
Cuba
Yes
Phillippines
Yes
St. Vincent and the Grenadines
Yes
Hide [Q6x1xAx8] j. Content of agreement
Hide [Q6x1xAx8x1] j.i. Does the agreement include elements to benefit the health system of your country and the partner country(ies)?
Ghana
Yes, has elements to
benefit the health system of my country and partner country(ies)
Cuba
Yes, has elements to
benefit the health system of my country and partner country(ies)
Phillippines
Yes, has elements to
benefit the health system of my country and partner country(ies)
St. Vincent and the Grenadines
Yes, has elements to
benefit the health system of my country and partner country(ies)
Hide [Q6x1xAx8x1x] Please explain:
Ghana
n/a
Cuba
n/a
Phillippines
n/a
St. Vincent and the Grenadines
n/a
Hide [Q6x1xAx8x2] j.ii. Does the agreement include elements on health worker rights and welfare?
Ghana
Yes
Cuba
Yes
Phillippines
Yes
St. Vincent and the Grenadines
Yes
Hide [Q6x1xAx8x2x] Please explain:
Ghana
n/a
Cuba
n/a
Phillippines
n/a
St. Vincent and the Grenadines
n/a
Hide all

Government Agreements - 6.1 B

Hide [INFOxNRI8] National Reporting instrument 2024
Hide [Q6x1xB] 6.1 B Please use the table below to describe the implementation of each of the active bilateral, regional or multilateral agreements or arrangements
Hide [Q6x1xBx1] Has the agreement been implemented?
Ghana
Yes
Cuba
Yes
Phillippines
Yes
St. Vincent and the Grenadines
Yes
Hide [Q6x1xBx1x1]
Start year of implementation:
Ghana 2021
Cuba 2020
Phillippines 2000
St. Vincent and the Grenadines 2015
Hide [Q6x1xBx2a] How many health personnel have left or entered your country through this agreement since its implementation?
Agreement: Ghana
Number of personnel
Doctors
Nurses 300-350
Midwives
Dentists
Pharmacists
Hide [Q6x1xBx2b] How many health personnel have left or entered your country through this agreement since its implementation?
Agreement: Cuba
Number of personnel
Doctors
Nurses 50
Midwives
Dentists
Pharmacists
Hide [Q6x1xBx2c] How many health personnel have left or entered your country through this agreement since its implementation?
Agreement: Phillippines
Number of personnel
Doctors
Nurses There is the intention to recruit in the near future.
Midwives
Dentists
Pharmacists
Hide [Q6x1xBx2d] How many health personnel have left or entered your country through this agreement since its implementation?
Agreement: St. Vincent and the Grenadines
Number of personnel
Doctors
Nurses n/a
Midwives
Dentists
Pharmacists
Hide [Q6x1xBx3] Please explain if and how has the health system of your country benefitted from the agreement.
Ghana
Primary care, geriatric and hospital based services.
Cuba
The COVID-19 response
Phillippines
Hospital care
St. Vincent and the Grenadines
Hospital care
Hide [Q6x1xBx4] Please describe if and how the health system of other country(ies) has benefitted from the agreement.
Ghana
n/a
Cuba
n/a
Phillippines
n/a
St. Vincent and the Grenadines
n/a
Hide [Q6x1xBx5] Please explain if and how the provisions on health workers rights and welfare were implemented.
Ghana
n/a
Cuba
n/a
Phillippines
n/a
St. Vincent and the Grenadines
n/a
Hide [Q6x1xBx6] Please provide any other relevant information on the agreement (e.g., context, positive elements, gaps and lessons learnt).
Ghana
Cuba
Phillippines
St. Vincent and the Grenadines
Hide [Q6x1xBx7] Full text of the agreement and associated documents (implementation plan, progress report, implementation report, evaluation report, etc.)
Upload document(s)
Ghana
Cuba
Phillippines
St. Vincent and the Grenadines
Hide [Q6x1xBx7xfile1]
Hide [Q6x1xBx7xfile2]
Hide [Q6x1xBx7xfile3]
Hide [Q6x1xBx7xfile4]
Hide [Q6x1xBx7xfile5]
Hide [Q6x1xBx7xfile6]
Hide [Q6x1xBx7xfile7]
Hide [Q6x1xBx7xfile8]
Hide [Q6x1xBx7xfile9]
Hide [Q6x1xBx7xfile10]
Hide [Q6x1xBx7xfile11]
Hide [Q6x1xBx7xfile12]
Hide [Q6x1xBx7xfile13]
Hide [Q6x1xBx7xfile14]
Hide [Q6x1xBx7xfile15]
Hide all

Responsibilities, rights and recruitment practices

Hide [INFOxNRI9] National Reporting instrument 2024
Hide [INFOx4]
Responsibilities, rights and recruitment practices
Hide [Q7] 7. If your country employs/hosts international health personnel to work in the health and care sectors, which legal safeguards and/or other mechanisms are in place for migrant health personnel and to ensure that enjoy the same legal rights and responsibilities as the domestically trained health workforce?
Please check all items that apply from the list below:
Migrant health personnel are recruited using mechanisms that allow them to assess the benefits and risk associated with employment positions and to make timely and informed decisions on the employment.
n/a
Migrant health personnel are hired, promoted and remunerated based on objective criteria such as levels of qualification, years of experience and degrees of professional responsibility on the same basis as the domestically trained health workforce.
n/a
Migrant health personnel enjoy the same opportunities as the domestically trained health workforce to strengthen their professional education, qualifications and career progression.
n/a
Institutional arrangements are in place to ensure safe migration/ mobility and integration of migrant health personnel.
n/a
Measures have been taken to promote circular migration of international health personnel
Other measures (including legal and administrative) for fair recruitment and employment practices of foreign-trained and/or immigrant health personnel (please provide details)
No measures in place
Not applicable – does not host/employ foreign health personnel
Hide [Q8] 8. If health personnel from your country are working abroad in the health and care sectors, please provide information on measures that have been taken or are planned in your country to ensure their fair recruitment and employment; safe migration; return; and diaspora utilization in your country, as well as difficulties encountered.
Please check all items that apply from the list below:
Arrangements for fair recruitment
Arrangements for decent employment contracts and working conditions in destination countries
Arrangements for safe mobility
Arrangements for return and reintegration to the health labour market in your country
Arrangements for diaspora engagement to support your country health system
Other
No measures in place
Not applicable – health personnel from my country are not working abroad
Hide all

International migration

Hide [INFOxNRI10] National Reporting instrument 2024
Hide [INFOx5]
International migration and mobility pathways for health personnel
Hide [Q9x1] 9.1 If your country hosts international health personnel to work in the health and care sector, how do they come to your country? (check all that apply)
Direct (individual) application for
education,
employment, trade, immigration or
entry in country
Government to
government
agreements that
allow health
personnel mobility
Private
recruitment
agencies or
employer
facilitated recruitment
Private education/ immigration
consultancies
facilitated mobility
Other pathways (please specify) Which pathway is used the most? Please include quantitative data if available.
Doctors 1 0 0 0
Nurses 0 1 0 0
Midwives 0 0 0 0
Dentists 0 0 0 0
Pharmacists 0 0 0 0
Other occupations 0 0 0 0
Other occupations 0 0 0 0
Other occupations 0 0 0 0
Other occupations 0 0 0 0
Other occupations 0 0 0 0
Hide [Q9x1oth]
Hide [Q9x2] 9.2 If health personnel from your country work/study abroad, how do they leave your country? (check all that apply)
Direct (individual) application for
education,
employment, trade,
immigration, or
entry in the
destination country
Government to
government
agreements that
allow health
personnel mobility
Private
recruitment
agencies or
employer
facilitated recruitment
Private education/ immigration
consultancies
facilitated mobility
Other pathways (please specify) Which pathway is used the most? Please include quantitative data if available.
Doctors 1 0 0 0
Nurses 1 0 0 0
Midwives 0 0 0 0
Dentists 0 0 0 0
Pharmacists 0 0 0 0
Other occupations 0 0 0 0
Other occupations 0 0 0 0
Other occupations 0 0 0 0
Other occupations 0 0 0 0
Other occupations 0 0 0 0
Hide [Q9x2oth]
Hide all

Recruitment & migration

Hide [INFOxNRI11] National Reporting instrument 2024
Hide [INFOx6]
Data on international health personnel recruitment & migration


Improving the availability and international comparability of data is essential to understanding and addressing the global dynamic of health worker migration. Please consult with your NHWA focal point, if available, to ensure that data reported below is consistent with NHWA reporting*.
(The list of NHWA focal points is available here. Please find the focal point(s) for your country from the list and consult with them.)

For countries reporting through the WHO-Euro/EuroStat/OECD Joint data collection process, please liaise with the JDC focal point.

Hide [Q10] 10. Does your country have any mechanism(s) or entity(ies) to maintain statistical records of foreign-born and foreign-trained health personnel?
No
Hide all

Inflow and outflow of health personnel

Hide [INFOxNRI12] National Reporting instrument 2024
Hide [INFOx7] Inflow and outflow of health personnel
Hide [Q11] 11. Do you have a mechanism to monitor the inflow and outflow of health personnel to/from your country? (check all that apply)
Inflow
Outflow
No
Hide [Q11xI] If yes for inflow:
Hide [Q11x1] 11.1 How many foreign-trained or foreign-born health personnel were newly active (temporarily and/or permanently) in your country in the past three years (inflow)?
Doctors Nurses Midwives Dentists Pharmacists Remarks
2021
2022
2023
Data Source (e.g. Regulatory authority, immigration records, work permits, etc.)
Hide [Q11xO] If yes for outflow:
Hide [Q11x2] 11.2 How many domestically trained health personnel left your country in the past years for temporary or permanent migration (outflow)?
Doctors Nurses Midwives Dentists Pharmacists Remarks
2021
2022
2023
Data Source (e.g. letters of good standing, emigration records, government to government agreements etc.)
Hide [Q11x3] 11.3 If you have any document with information on health worker inflows and outflows for your country, please upload
Hide all

Stock of health personnel

Hide [INFOxNRI13] National Reporting instrument 2024
Hide [INFOx8] Stock of health personnel
Hide [Q12x1] 12.1 Consolidated stock on health personnel, disaggregated by place of training and birth
For the latest year available, consistent with the National Health Workforce Accounts (NHWA) Indicators 1-07 and 1-08, please provide information on the total stock of health personnel in your country (preferably the active workforce), disaggregated by the place of training (foreign-trained) and the place of birth (foreign-born).
Hide [Q12x1a] Please provide data on the stock of active health personnel in your country by one of the following ways:
Share data in the NHWA platform through NHWA focal point
Hide [Q12x1x1x] If you have any document with information on stock of active health personnel for your country, their distribution by place of training and place of birth, please upload
Hide [Q12x2] 12.2 Please provide data on the top 10 countries of training for foreign-trained health personnel in your country.
This information can be provided by one of the following two options:
Share data in the NHWA platform through NHWA focal point
Hide [Q12x2x1x] If you have any document with information on the distribution of foreign-trained health personnel for your country by their country of training, please upload
Hide all

Technical and financial support

Hide [INFOxNRI14] National Reporting instrument 2024
Hide [INFOx9]
Technical and financial support
Hide [Q13] 13. Has your country provided technical or financial assistance to any source countries or countries in the WHO health workforce support and safeguards list 2023, or other low- and middle-income countries on health workforce development, health system strengthening, or for implementing other recommendations of the Code (e.g., strengthening data, information and research on health workforce for translation to policies and planning, etc.)
No
Hide [Q14] 14. Has your country received technical or financial assistance from any WHO Member State or other stakeholders (e.g., development partners, other agencies) for health workforce development, health system strengthening, or for implementing other recommendations of the Code (e.g., strengthening data, information and research on health workforce for translation to policies and planning, etc.)?
No
Hide all

Constraints, Solutions, and Complementary Comments

Hide [INFOxNRI15] National Reporting instrument 2024
Hide [INFOx10]
Constraints, Solutions, and Complementary Comments
Hide [Q15] 15. Please list in priority order, the three main constraints to the ethical management of international migration in your country and propose possible solutions:
Main constraints Possible solutions/recommendations
Hide [Q16] 16. What support do you require to strengthen implementation of the Code?
Support to strengthen data and information on health personnel
having appropiate mechanisms and software
Support for policy dialogue and development
training of Senior Management
Support for the development of bilateral/multi-lateral agreements
Others
No support required
Hide [Q17] 17. Considering that the Code is a dynamic document that should be updated as required, please provide reflections from your country on the past 14 years since the resolution on the Code.
Hide [Q17x1] Please comment on if/how the Code has been useful to your country.
The Code while useful for Barbados does not provide on the ground solutions for good implementation. Low income governments have to make the hard decisions with respect to funding of new healthcare positions and identifying the appropiate training needs.
Hide [Q17x2] Do any articles of the Code need to be updated?
No

Hide [Q17x3] Does the process of reporting on Code implementation and the review of the Code relevance and effectiveness need to be updated?
No

Hide [Q17x4] Please comment on the WHO health workforce support and safeguards list (e.g. if your country is included in the list, how has that affected you; if your country is reliant on international health personnel, how has the list affected you; if your country is not in the list, how has it affected you)

Hide [Q18] 18. Submit any other complementary comments or material you may wish to provide regarding the international recruitment and migration of health personnel, as related to implementation of the Code.

Please describe OR Upload (Maximum file size 10 MB)
While we appreciate and understand the purpose of this evaluation it is not solutions base and countries particularly in the Global South will have to come up with their own solutions to the human resource for health challenges. WHO may be better serve by giving countries menus of options base on their socioeconomic status so as to provide real time solutions for an acute problem. COVID-19 was one of the few times where WHO gave on the ground help for contact tracing and this added value to our contact tracing efforts. The questionnaire is long and highly repetitive and we may have been better serve by a short term in country consultation.
Hide [Q18x1]
Hide all

Warning

Hide [INFOxNRI16] National Reporting instrument 2024
Hide [WARN] You have reached the end of the National Reporting Instrument - 2024. You may go back to any question to update your answers or confirm your entry by clicking ‘Submit’.