Content Analysis of India’SNational Mision on Medicinal Plants

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Content analysis of Indias National Mission on Medicinal Plants:

Operational Guidelines Document: Issues and Responses

Rahi Jain, Bakul Rao

Abstract

Resources play an important role in any health system functioning. This study focuses on National

Mission on Medicinal Plants (NMMP) of India, which was initiated to promote Medicinal Plants

(MPs) for providing sustainable resources supply to health systems both nationally and

internationally. The study analyzed the missions documents available in public domain namelyoperational guidelines with its two amendments to understand the missions designing and evaluate

the potential implementation impact. Content analysis of the documents was performed to identify the

issues in the original operational guidelines and its response in the subsequent two amendments. The

study identified 60 key issues in the original document related to the issues of document clarity;

accountability and transparency of governance as well as financing and various stakeholdersrepresentation. The issues were partially addressed in two amendments indicating persistent

inadequacies in the document design and unreliable decision-making. This study raises the awarenessregarding the various design issues and provides inputs for next amendment to improve missionsimplementation.

Introduction

Indian System of Medicine (ISM) has been an affordable, accessible and an acceptable system by

people (Priya & Shweta, 2010) having low per capita income in India. The system allows India to

improve its health status, while preserving its traditional medical system and has been a focus in Five

year plan since independence along with allopathy or modern system of medicine (Planning

Commission of India, 1951). ISM educational infrastructure of 504 institutions (1st

April, 2011) and

manpower of 712,121 doctors (1st

January, 2011) in India is significant in comparison with 626

allopathic educational institutions (2011-2012) including 291 dental colleges and 846,472 doctors

(31st December, 2010) (Central Bureau of Health Intelligence, 2011). In addition to the codified

system, there are around 1 million village-based, traditional ISM community health workers and 100

million households with traditional knowledge related to various streams like primary healthcare and

nutrition (Planning Commission of India, 2011). According to National Rural Health Mission

(NRHM) report 2010, in places with good ISM services significant utilization of these services is seen

even with availability of good public modern health services (Priya & Shweta, 2010) reflecting deep

belief/trust in ISM system (Planning Commission of India, 1985). Importance of resources in

determining health system effectiveness is recognized by the World Health Organization (WHO)

(World Health Organization, 2000). The codified ISM uses around 2400 medicinal plants (MP)

making medicinal plants as one of its most important resources (Ved & Goraya, 2008). With forests

being the major source of MP, their overexploitation has lead to decreased natural stocks and raised

issues regarding affordability and sustainability of the industry catering to ISM as well as modernsystem (National Medicinal Plants Board, 2008).

In order to maintain and enhance ISM, importance of sustainable supply of several overexploited and

threatened medicinal plants was recognized by India and a five year National Mission on Medicinal

Plants (NMMP) scheme was launched in 2008. In addition to ISM, allopathic system also gets

benefitted with this scheme due to their dependency on several medicinal plants for manufacturing

drugs. The Department of AYUSH in Ministry of Health and Family Welfare (MOHFW) through

National Medicinal Plants Board (NMPB) runs this mission (National Medicinal Plants Board, 2008).

This mission is a central level scheme with focus on the commercial aspect of the medicinal plants

with total budgetary allocation of Rs 63 million for year 2008-2012. The only mission document

which has been published in the public domain is operational guidelines document and has been twice

amended since its inception in 2008, first in June, 2011 (National Medicinal Plants Board, 2011) andsecond in January, 2012 (National Medicinal Plants Board, 2012) though mission was coming to an


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end. The amendments of the operational guidelines documents indicate not only design and

operational lacunae, but also the efforts to improve the implementation on the part of the department.

The recommendation for continuation of the scheme was put forth by the Steering Committee on

Department of Ayurveda, Yoga, Unani, Siddha and Homeopathy (AYUSH) for 12th

Five Year Plan(Planning Commission of India, 2011). In the light of a possibility of furthering the scheme, it is

imperative to analyze the mission both from the design as well as implementation perspective aslacunas can endanger the sustenance of the low cost ISM system. Further, analysis can help in

predicting the future strategies which Indian Government can take as well as helping the decision

makers by providing information about unaddressed issues. The paper attempts to analyze the mission

design through documents. The objectives of the study are primarily to determine the issues with the

original document in terms of its field implementation (2008- NMMP) and subsequently to determine

its addressal in subsequent amendments.

Methodology

The method adopted for analysis of NMMP was the content analyses (CA) approach of the documents

in the public domain namely the guidelines and its two amendments. The CA tool has been used as an

alternate approach or in combination to surveys, archival studies and firsthand observations, foranalyzing documented work, for obtaining an individual or community or governmentsopinion/strategies/trend/behavior towards an issue or situation (Mills, 1985). This tool had been used

by different researchers for analysis of health policies in health sector for Australia (Bail, Cook,

Gardner, & Grealish, 2009), Belgium (Lemiengre, Dierckx de Casterl, Denier, Schotsmans, &

Gastmans, 2008), Canada (Iannantuono & Eyles, 1997), Danish (Mygind, Traulsen, Nrgaard, &

Bissell, 2011) and Pakistan (Siddiqi, Haq, Ghaffar, Akhtar, & Mahaini, 2004).

For any guidelines put out by the government towards an implementation of a project/programme,

various components such as current status or issues, targets, objectives and strategy need to be

documented to achieve set goal/s. The strategy in itself has several sub-components like governance,

stakeholders, financing and mission assessment. The governance plays a critical role for proper

management and functioning of the mission. Stakeholders are important in a mission as they areaffected party. Financing determine the funds available to run the mission, while mission assessment

will help in determine the efficiency of the mission. These components and sub-components can be

used as the primary criteria to analyze the documents content. This document studied the originaldocument to find out the shortcomings followed by the response towards those shortcomings in the

two amendments. In the original document, the first level analysis using these primary criteria was

done by capturing the information provided by the documents through creation of objective questions

under each criterion as mentioned in Table 1. This is followed by a second level analysis, where the

original operational guidelines lacunae were identified and elaborated.

Table 1: Selected criteria for document analysis with objective questions under each criterion

Criteria First Level Questions Criteria First Level Questions

Current Status or Issues Are any issues identified?

Governance

Is governance mentioned?

Target Are target/s mentioned?Is accountability

considered?

Objectives Are objective/s mentioned?

Stakeholder

Are stakeholders

mentioned?

Strategy Are strategies mentioned?Is accountability

considered?

Financing Is Financing mentioned?Mission

assessment

Is assessment of mission

mentioned?

The responses in the two subsequent amendments were scrutinized vis--vis the issues identified in

the eight segments of the original document. The responses which can be classified as eitheramendments or clarification/explanation obtained for the responses as well as no-responses can


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provide inputs for obtaining the complete picture of the NMMPs mission and subsequenteffectiveness of the programme.

Results and Discussions

Issues in the Original Document

Current status or issues: The missions operational guidelines (2008) have identified three issues.Firstly, the issue of sustainable supply of medicinal plants due to high dependency of wild sources

and unsustainable harvesting from wild sources. It inherently assumes that the minor fraction which

comes from cultivation uses sustainable cultivation and harvesting practices. Secondly, AYUSH

system outreach and acceptability is an issue due to poor quality of the medicinal plants. The concept

of quality is, however, not elaborated as it can be presence of adulterants, lower quantity of active

ingredient or greater variability in the active ingredient in plant sample. Finally, poor global herbal

market share is another issue which has been attributed to the major export in the form of raw herbs

and extracts as well as poor quality compliance of the products. The document uses word herbal

and AYUSH interchangeably which makes it difficult to understand the market share as variousnon-AYUSH systems like medicinal plants based allopathic drugs and traditional Chinese medicine

can also form the part of the global herbal trade. NMPB came into existence in 2000 with one of theobjectives being domestic and global supply/demand scenario assessment (National Medicinal Plants

Board, 2008). However, NMMP mission fails to provide the adequate basis for supply demand and its

correlation with identified issues.

The promotion of cultivation to address the issue of sustainable medicinal plant supply as well as

AYUSH system outreach and acceptability has been based on following basic assumption. Namely,

increase in cultivation will reduce harvesting from the wild and improve quality of medicinal plants

but it does not address the strategies for reducing harvesting from wild. NMMP seems to assume that

the higher demand than cultivated plant supply is the cause of collection from wild and ignores the

contribution of other factors like the possibility of increasing demand and cost of collection in plants

collection from wild. GAP/organic compliance are assumed to improve the quality and can help in

creating better global outreach and acceptability of AYUSH system. However, they ignored the ideaof possibility of active ingredient content decrease through cultivation (Han, Mao, Yan, Ji, & Chen,

2012; Schippmann, Leaman, & Cunningham, 2002). Promotion of value addition and processing is

expected to increase Indias share in global market by creation of value added product. The missionfails to identify the importance of quality control at the value added products and does not recommend

any strategy to address this issue which can be of grave concern in export. The reason for not

addressing non-AYUSH domestic market (including allopathic drugs) while addressing non-AYUSH

export market is not available. Such failures to appropriately identify the issues or to properly provide

adequate background for identified issues create ambiguity in the document and makes recommended

solution questionable.

Mission Objectives: Main objectives of the mission include providing livelihood to farmers,

improving AYUSH system and its acceptability and increase value added products export whilesecondary objectives include promoting cultivation, coordination and linkage between different users,

creating linkage between allied services and market and implementing and supporting quality

certification system for medicinal plants. In the light of absence of any background information

regarding the current collection based system, the objectives fail to evaluate the impact on the current

and future of the collection based system with promotion of cultivation and vice versa. The mission

inherently assumes that collectors are responsible for poor quality and over-exploitation of medicinal

plants from wild. In such a scenario, lack of guidelines for capacity building for collectors can affect

their future livelihood/ seasonal employment. This may mean the shift in livelihood from collectors to

cultivators, which may leave collectors with no permanent/seasonal livelihood option and cultivators

with multiple livelihood options.

Mission Targets: The mission document has mentioned about both qualitative and quantitativetargets which needs to be achieved by the end of this mission. Quantitative targets are set for the


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and GAP/Organic certification. Indirect subsidies are provided by subsidizing the set-up of planting

material unit, testing labs, post harvest management units, processing units and marketing activities.

The infrastructure for establishing forward as well as horizontal linkages can be setup either in the

designated cluster or outside the cluster (with linkage with the cultivation cluster). This strategy

provides multiple options to the cultivators but this model of establishing infrastructure for forward

and backward linkages outside the cluster is far from the idea of maintaining geographical proximity.

The creation of clusters provide incentive to all users as it provides geographical proximity but lack of

compulsion to have all types of infrastructure like labs, processing units, post harvesting management

units, marketing units in a cluster questions the practicality of the cluster. Further, non-cultivation

units are allowed to be set-up outside the cluster, which act as deterrent to have all types of

infrastructure in cluster.

The strategy to achieve rural livelihood target is not explicitly explained. It can only be implicitly

predicted that main livelihood is expected to be generated from cultivation with some smaller

contribution through employment in allied activities like processing, planting material generation,

marketing, post harvesting management, field assessment studies and lab testing. This makes it

unclear about whether livelihood is created by diverting people from existing livelihood or by creating

new livelihood options

There are certain aspects not considered by the strategy like no identification of plant tissue culture

lab for providing planting material and no strategy to reduce harvesting from wild. On the other hand,

certain strategy decisions are not explained. Firstly, the strategy to set up labs with ability to certify

the value added products quality is mentioned without explanation. This strategy is possibly based on

the assumption that the quality certified value added products can increase both trust on the AYUSH

system and value of the product. Secondly, the strategy to reduce the dependence on wild by

promoting cultivation is mentioned without considering the collection system.

Governance: It is a four tier structure at centre level, state level, district level and cluster level. The

centre NMPB level structure comprises of Standing Finance Committee (SFC) and Technical

Screening Committee (TSC) with the head of both committees being the Secretary, Department of

AYUSH. SFC members compose of MOHFW, Department of Science and Technology, Department

of Biotechnology, Department of Agricultural Research and Education, Ministry of Environment and

Forests, Ministry of Commerce, Ministry of Development of North Eastern Region (DONER), North

Eastern Council, Ayurvedic Industry, Exporters, Growers association/federation, domain experts and

NMPB official. TSC members compose of representatives from National Horticulture Board, Indian

Council of Agriculture Research (ICAR), Council for Science and Industrial Research (CSIR),

Department of AYUSH, North Eastern Council, Domain Experts and NMPB official.

The state level governance is under State Level Steering Committee (SLSC) headed by the Additional

Chief Secretary/ Agriculture Production Commissioner/ Development Commissioner with members

from state government departments/boards like State Medicinal Plant Board (SMPB),

Health/AYUSH, Horticulture/Agriculture, Industries, Forest and State Horticulture Mission along

with members from NMPB, facilitation centers/central government institution and domain experts.

Under SLSC, Technical Support Group/Technical Screening Committee and State Level

Implementation Agency (SLIA) are constituted. The technical support group is comprised of

academic institutions (like State Agriculture Universities), research institution (ICAR, ICFRE, CSIR),

facilitation centers and experts. For SLIA, three different governance mechanisms have been

recommended by central government to give the State choice of implementing agency based on

agencys efficiency and effectiveness.

In first mechanism, the SLIA is under State Horticulture Mission (SHM) which is currently

implementing the National Horticulture Mission (NHM) in the state. The SHM acting as a SLIA will

form a society with functional and implementation autonomy and will directly receive funds from the

NMPB while coordinating with AYUSH, industries and SMPB for implementation. In this first

mechanism the district level governing body can be either District Mission Committee (DMC) of

SHM. The DMC members will comprise of representatives from concerned departments, grower


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Figure 1: Basic Mission Proposal Sanctioning Process

It has a decentralized functioning with preparation of the plans and implementation at the lowest level

with sanctioning of the plans for financing at the higher level as shown in Figure 1. The structure

lowest functioning unit is cluster which can be processing cluster (raw material is processed with orwithout cultivation) or cultivation cluster (raw material is cultivated). The cultivation cluster needsto have a link with a processing cluster or market/ exporter/trader or manufacturer though it does not

mention of how the cultivation cluster can identify such links. The identified clusters annual plan will

be prepared by the cluster level implementation agency which will be sent to the district level

implementation agency or directly to the SLIA. The district level implementation agency will prepare

a common district level annual plan which will be sent to SLIA. In the meanwhile, the activities

mentioned in the cluster proposal and district proposal will be carried out by the users. SLIA in

consultation with Technical support group will evaluate different district and cluster plans andselected plans will be integrated into the state level annual plan. The state level annual plan will be

CENTRE LEVEL

STATE LEVEL

NMPB

Standing Finance

Committee

Technical ScreeningCommittee

Release of

State Funds

Release of

District/Cluster Funds

Release of Cluster/

Other Activities Funds

Release of

Credit Funds

Release of

Non-Credit Funds

For activities upto

Cluster Level

For Other Activities

State Level

Implementation Agency

District Level


Cluster Level


BankCredit Settlement

Applicant upto Cluster Level

Applicants not in

Cluster

State Level

Steering Committee

Technical Support

Group

Proposal

Cluster Level Plan and

Other Activities Proposal

District/Cluster Level

Plan/Other Proposals

State Level Plan

Consultation

Consultation

Result

State Level

Plan Proposal

State Annual

Plan Proposal

State AnnualPlan Proposal

State Annual

Plan Proposal

LEGEND

Proposal Sanctioning

Process

Proposal Financing

Process

Other Activities

Proposal

Cluster Level

Plan

Cluster Level

Plan

District Level

Plan


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sent to NMPB where it will be evaluated by the TSC and SFC for approval. The cluster and district

identification is the state responsibility but identification process clarity is not clear. In second

governance mechanism where agriculture ministry is SLIA with society formation at district level, the

society role is unclear when cluster level agencies, KVK and ATMA can directly report to SLIA. The

information related to the governance of cluster level implementation agencies created by DMC/DMD

will govern the clusters for its implementation is not provided making it all the more difficult to

understand the role and functioning of these agencies.

The mission document fails to provide the adequate clarity on the functioning of the various

governmental bodies especially the SHM and agriculture ministry and linkages thereof. The future

possibility of SMPB as SLIA or any other active role other than the providing funds to agriculture

ministry in case of first and third governance mechanism is not mentioned in the mission document.

One of the plausible reasons for lack of providing active role could be assumed to be relatively new

formation and lack of capacity and infrastructure. There is a lack of the information on the time lines

for setting the governance structure. The mission document does not provide the mandate for the state

agencies to declare their evaluation process for selection of various agencies for implementation at

different levels, thereby making it difficult to evaluate the agencies for their progress. Moreover,

mission lacks the provisioning for the databases for maintaining information related to progress and

stakeholders.

SLIA manpower requirements are not mentioned in terms of deputation from existing departments.

The mission talks about acquiring contract staff for meeting manpower requirement, but it fails to

provide information about the working levels and roles and responsibilities to be fulfilled at those

levels.

Mission has mentioned about provision of technical support to all types of units through the

Facilitation Centers (FC) created in State Agriculture Universities (SAUs) and R&D institutions of

CSIR/DBT. However, role and responsibilities and mechanism of reaching out to the potential and

existing users like technology databases, adaptation of technology to local conditions and decision

making tools for technology selection is not provided. This leads to an indirect assumption that any

R&D for developing technologies of need to be done by cooperatives and SHGs, formed by poor

people.

Stakeholder: The mission has considered several stakeholders namely government ministries and

departments, local level governing bodies/Panchayati Raj Institutions (PRIs), academic institutions,

field experts, civil society organizations/non-governmental organizations (NGOs), local community

groups, cultivators, industrialists and exporters. The stakeholders involved in making the committees

of centre or state level are involved in all the main decision making activities namely higher level

governance (centre/state level), local governance (district/cluster level), regulation, monitoring,

technical assessment of proposals, financing and marketing. Stakeholders namely government

ministries and departments, academic institutions, cultivators, industrialists and exporters are present

in SFC, TSC, SLIA or state technical steering committee but the process of selection of representative

of cultivators, industrialists and exporters as well as field experts is not provided. Academic

institutions can even make decision about the technology information dissemination.

Local governing bodies/PRIs, civil society organizations and local community groups are allowed to

be involved but their involvement has been optional. Traders, gatherers and collectors have not been

acknowledged as the stakeholder by the document indicating the strong possibility of leaving them

unaccounted in any kind of decision-making. Stakeholders who have to receive financial assistance

have a built in validation system but the mechanism for reporting and checks are very weak for other

stakeholders.

Financing: Finance requirements are for multiple purposes like pre-implementation studies

(feasibility study and baseline surveys), creation of governance system at different levels, capacity

building, functioning of FC, provisioning of subsidy and post-implementation studies. The totalbudgetary allocation for mission is Rs 63 million, but allocation of funds for each of the above


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activities is not mentioned. Though, state based allocation of funds is not mentioned, state can use up

to 5% of the state annual budget for management of the state level implementation which involves

staff and consultant salary, annual plan preparation, monitoring, administrative expenses and exposure

visits. The criteria for selection of 5% is not known as during initial years of mission state may need

more funds to create the system while number of projects proposed by users may not be sufficient

enough to meet those requirements. Further, the compensation given to contractual staff or any

government official is not mentioned, which makes it difficult to understand the strategy to get

involvement of manpower.

The process of funds flow is complex. In case of SHM or SMPB as SLIA, the funds will be directly

released to the state level society by the SFC at NMPB but in case of agriculture ministry as SLIA, the

flow of funds would be from SFC to agriculture ministry either directly or indirectly through SMPB

or State Health Societies. The role of State Health Societies and reason for using them as the

intermediate to provide funds to agriculture ministry is not mentioned. The reason for such different

mechanisms for funds flow is not explicitly justified.

The words Financial assistance and Subsidies has been used interchangeably for the process ofproviding refund for the certain portion of the invested funds of the users. Financial

assistance/subsidies process as mentioned in the operational guidelines is a centralized process(Figure 1) which is triggered with acceptance of the projects in state annual plan by SFC in

consultation with TSC. These subsidies are provided for various activities like infrastructure set-up,

planting material unit, cultivation expenditure, post harvest management unit, value addition unit,

testing labs and marketing expenditure. However, there is no mechanism to ensure the timely sanction

and release of the subsidies. SFC releases funds to SLIA which in turn provides those funds to district

level agency or cluster level agency which distributes it to users directly or through cluster level

implementation agency after confirmation of investment by the user.

The document is unclear on two aspects; firstly, whether the investment by the user should be pre and

post sanction of proposal and secondly, the process of release of sanctioned subsidy to the creditor

bank or user (in case of financially stability proof through bank certificates). Though, the steps have

not been clarified, it can be assumed that the process of approved funds release to the user involve

two steps namely validation of the investment and subsequent release of the subsidy to users. The

need for initial investment for any subsidy can dampen the interest of SHGs and financially weak

users interest in scheme even if subsidy preference is given to them over others. A long subsidy

process deters people with no financial strength to invest in the projects which would lead to the

failure in the achieving mission objectives. Further, this mechanism, while deterrent for financially

weak farmers, can create a possibility of contract farming where financially surplus industries/farmers

can invest in cultivation for cultivators and purchase the produce. Thus, the whole purpose of

financial subsidy to overcome financial constraint and promote medicinal plants gets lost. Lack of

availability of the guidelines on the ways to get funds from the financial institutions like NABARD,

SIDBI or local banks and no clarification for the development of financing guidelines by centre or

state makes it difficult for the farmers/industries to setup cultivation or processing unit.

Further, the information related to the subsidy given is not clear. The cultivation investment is high

and deterrent for cultivators as no subsidy assurance for infrastructure and inputs like irrigation,

power, fertilizer, pesticides is provided. Cultivation subsidy does not provide information on number

of installments and number of cultivation cycles. While, agro-climatic conditions for selecting plants

for cultivation is mentioned but agro-climatic conditions are not considered for determining the

timing of sanctioning of the projects. The sanctioning of the subsidy either during or after cultivation

season may force cultivator to wait for next season for making investment.

Eligibility and extent of subsidy for various applicants is different as shown in Figure 3. In case where

planting material is seeds namely Research Wing of State Forest Departments/Research

Organizations/State Agricultural Universities (SAUs), Non-Governmental Organizations (NGOs) and

Corporates are permissible for supplying planting material to cultivators. While, where planting

material is plantlet nurseries namely public and private sector agencies are permissible for supplying


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planting material to cultivators. While, comparing private (including NGOs) plantlet nurseries with

private (including NGOs) seed producers more benefits provided to plantlet (including NGOs)

nurseries both through subsidies and self-accreditation. However, while comparing government seed

producers and government plantlet nurseries the benefits to both have been provided as former do not

need certification while latter gets 100% subsidy with certification in hand. The certification for

plantlet nurseries needs to be done by an accredited certification agency which will be identified and

notified by the NMPB. Such a blanket support to plantlet nurseries both private and public as

compared to seed producers especially for private nurseries (including NGOs) provides unfair

competing grounds.

In case of plantlet nurseries applicants, the size of the nursery in terms of number of plantlets

produced will determine the amount of subsidy provided. Large nurseries producing 200,000-300,000

plantlets per year will get subsidy on infrastructure with 100% subsidy of up to Rs 2 million for public

nurseries and 50% subsidy of up to Rs 1 million for private nurseries. Small nurseries producing

60,000-70,000 plantlets per year will get subsidy on infrastructure with 100% subsidy of up to Rs

400,000 for public nurseries and 50% subsidy of up to Rs 200,000 for private nurseries. Further, the

need for small nurseries to maintain plantlets for 9-12 months is important criteria as it plays crucial

role in selecting medicinal plants as potentially medicinal plants with long gestation period are the

only viable options in meeting the criteria. This criterion, though, will help the small nurseries to

lower their operating cost due to lower throughput rate; it increases the risk for such nurseries due to

lower number of options in terms of medicinal plants selection as well as longer time for recovery

from the investment.

In case of cultivation application, the applicants eligible for cultivation are growers, farmers,

cultivators, growers associations/federations/cooperatives, self help groups and corporates. They canget subsidy for planting material, inputs (like fertilizers, pesticides, irrigation and power), process as

well as product certification, crop insurance and product testing. Subsidy on planting material is based

on the medicinal plant planted as plants with longer gestation period are given higher subsidy. It is

mandatory for the cultivator to procure this planting material from NMPB sanctioned nurseries or

seed centers. In case of agriculture inputs like fertilizers, pesticides, irrigation and power subsidy, is

based on the need felt by the NMPB without giving clarification on the need assessment process.

Overall, a state level subsidy cap of 30% on cultivation of medicinal plants is defined which may be

difficult to achieve for the state due to following reasons. Firstly, a review of various medicinal plant

subsidies revealed that more than 50% MP have subsidy exceeding 30%. Secondly, at the state level

without any decision making tools/guidelines arriving at the state cap of 30% subsidy may lead to

bias. The provision for state level cap only for cultivation does not seem to arise out of any proper

reasoning. One of the probable reasons which could be assumed is that the subsidy of processing

(25%) is comparable with state cultivation subsidy cap (30%), which will increase the possibility of

higher representation of value added products in subsidy, but it can create the possibility of

inadequate cultivation production due to low subsidy. GAP certification and organic farming

certification subsidy of 100% with maximum of Rs 500,000/ha is provided. Crop insurance subsidy of

50% of premium is provided. Product testing subsidy of 50% with maximum of Rs 5,000 is providedin case the laboratories used are AYUSH/NABL accredited laboratories.

In case of marketing applicants, subsidy is provided for different purposes namely market promotion,

market intelligence, buy back intervention and marketing infrastructure. Market promotion subsidy is

provided on project basis for promotion of sale of medicinal plants (only those produced by the

cultivators) with 50% subsidy of maximum Rs 500,000. Market intelligence activity aims at providing

market information to growers. Buy-back intervention activity is aimed at increasing the buyer-seller

linkage between growers and buyers. Project based financial assistance will be provided for market

intelligence and buy back intervention activities. The information regarding the upper limit of number

of projects for market promotion, market intelligence and buy back intervention and no specific

eligible applicant list or eligibility of applicants is not provided. The applicants eligible for marketing

infrastructure are SHGs, cooperatives and public organization with 100% subsidy with maximum ofRs 1 million for village level mandi and Rs 20 million for state/district level mandi.


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Infrastructure set-up for post harvesting management and processing can be done by the applicants

like government organizations, NGOs, federations, cooperatives, industry R&D unit, corporates,

NABL accredited laboratories, SHGs, R&D institutions and universities. Industry R&D unit will be

allowed only if it is duly registered and has more than three years of experience in the field, while

government R&D institutions and universities do not need this criteria. There is a cap on investment

for subsidy for infrastructure activities till which subsidy will be provided. Percentage of subsidy in

case of drying sheds and storage godowns is100% for SHGs, cooperatives and public organization

and 50% for private sector. Processing units are eligible for subsidy of 25% of the project cost for all

users with maximum limit of Rs 5 million. These units are not provided any subsidy for product

testing, which can be added cost burden for the start-ups due to strict product quality requirements

especially in Europe and USA. Testing laboratories are eligible for subsidy of 30% of the project cost

for all users with maximum limit of Rs 3 million; however they need to be set-up in Public Private

Partnership (PPP) involving SLIA and NMPB. The document does not mention the need for these

labs to be AYUSH/NABL accredited because if they fail to get AYUSH/NABL accreditation the

subsidy of the government will be wasted as cultivators will use only AYUSH/NABL accredited labs

for product testing. However, it may be assumed that the involvement of NMPB and SLIA in setting-

up using the subsidy will ensure the AYUSH/NABL accreditation.

The mission intends to promote weaker section, but no additional incentive for those people in the

activities other than cultivation, post harvest management and marketing infrastructure. The lack of

additional incentives in other activities is not explained making the intent questionable and efforts

inadequate. It may be assumed that the mission finds the potential inability of weaker section to make

investments in processing industry or laboratory set-up. A successful run of mission may allow

weaker section to set-up processing industry or laboratories with provision of better incentives but

such scenario has not been considered.

The document fails to provide the mandate to provide the list of the various accreditation or

certification agencies which can be approached by the applicants for certification except for the

plantlet nurseries. This increases the difficulty for the applicants to get access to subsidy in cases

where certification is required for subsidy. Further, it de-incentivizes applicants to aim for better

process and product quality standards. The document does not make quality certification mandatory

for several activities like government seed centers, private nurseries, cultivation, testing laboratories,

processing units and marketing infrastructure which make it difficult to achieve the objective of

improving AYUSH system and increasing exports due to possibility of availability of sub-standard

product quality. Further, this will make it difficult for them to compete with the existing collection

based system as both cultivation and collection based system may end having same quality issues.

Mission Assessment: Mid-term and end term monitoring and evaluation of the scheme is the

proposed strategy. The activity of monitoring and evaluation is to be carried out by the project

management unit formed by project management consultants and support staff both at the centre and

state level. However, it is not mentioned if consultants have to be same or different for centre and

state level which creates ambiguity. Lack of involvement of third party monitoring unit allows thepossibility of missing issues due to non-user stakeholder accountability. The ambiguity in the

consultants selection makes it difficult to assess the transparency of the assessment.


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Figure 3: Linkages between different components of herbal industry and subsidies provided to different components

PLANTING MATERIAL

PRODUCTION UNIT

SEED PRODUCERSEligible Producers: NGOs, Goverment,Corporates

CULTIVATION

PLANTLET PRODUCING NURSERYEligible Producers: NGOs, Government,Corporates

1. Subsidy not provided for setup

2. Certification not complusory forgoverment agency

1. 100% subsidy for government

agency for setup

2. 50% subsidy for others for setup

3. Certification compulsory for

government agency

4. Others are allowed self-

accreditation

PROCESS/PRODUCT CERTIFICATION(Optional)

MEDICINAL PLANTS CULTIVATORS

Eligible Producers: Cultivators,Corporates, SHGs, Growers associations/federations/cooperatives

Planting Material

1. Subsidy based on plant

Inputs (Irrigation, Power,

Water, Agrichemicals)

1. NMPB needs based subsidy

Produced Product Testing

(Optional)

1) 50% Subsidy

2) NABL/AYUSH accredited Lab

for subsidy

CROP INSURANCE(Optional)

1. 100% Subsidy is provided to

cultivator for getting certification

1. 50% Subsidy is provided on

insurance premium to cultivators

POST-HARVEST MANAGEMENT

DRYING SHEDS AND STORAGEFACILITIESEligible Developer: SHGs, Cooperatives,

Government Agency, Corporate

1. 100% subsidy for government

agency, SHGs and cooperatives

to setup

2. 50% subsidy for others to setup

PRODUCT TESTING LABORATORIES

1. 30% Subsidy is provided for setup

2. Setup as Public Private Partnership

(PPP) between Private, State Level

Implementation Agency and NMPB

PROCESSING UNITS

Eligible Developer: NGOs, SHGs,Government organizations,

Federations, Cooperatives, Corporates,Industry R&D unit, NABL accreditedlaboratories, R&D institutions and

universities

1. 25% subsidy for all to setup

2. Registered and 3 years experience

for Industry R&D unit

SALE OF PRODUCT

EXPORTERS/TRADERS

Procurement and sale of value addedas well as raw products

MARKETING

MARKET PROMOTION

Eligible applicant not specified

MARKET INTELLIGENCE

Eligible applicant not specified

1. Project based subsidy is provided to

applicant

BUY-BACK INTERVENTION

Eligibile applicant not specified

MARKET INFRASTRUCTURE

Eligible Producers: SHGs, cooperativesand government organization

1. Project based subsidy is provided to

applicant1. Project based subsidy is provided to

applicant

2. 50% Subsidy is provided

1. 100% subsidy is provided for village,

district and state level setup

LEGENDMain Components/Links

Linkages subsidized bythe document

Linkages not subsidized by

the document

Cultivators to buy

only certifiedplanting material

Cultivators can getGAP/Organic

certification

Cultivators can get

Crop Insurance

Cultivators can storetheir produce

Cultivators can getProduct Quality

Tested

Sale of raw productsto processing

industries

Sale of Valueadded product

to exporter/trader

Sale of product

to targetconsumer

Sale of raw product to exporters/traders

Product Quality Testingduring storage

Value Added ProductQuality Testing

Cultivators productcan be promoted

Promotion of product by exporter/traderPromotion of

Value addedProducts


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Mission Targets

12 Various quantitative targets have been given but no baseline for all targets is provided. Modification No No

13Cultivation products are expected to feed into the processing but no targets are given for forward

linkages of the cultivation based indicatorsModification No No

14Value added product is given importance in terms of ability to improve global trade yet no

quantitative indicator for value added productsModification No No

15 Total Medicinal plant production was not considered as issue yet it is considered as mission target. Clarification No No

Mission Strategy

16 The clusters creation is proposed for promoting mission but definition of cluster is not provided. Clarification Yes Yes

17 No consideration of externalities like commercial crop intervention, land use pattern and localbiodiversity is given.

Modification No No

18Geographical proximity is assumed as the key for the mission success but inadequate restrictions and

incentives are mentioned to maintain geographical proximity of non-cultivation activities.Modification Yes Yes

19It may be assumed that cultivation promotion may be the major livelihood source in rural areas but no

explicit strategy to achieve rural livelihood target is explained.Clarification No No

20Financial support to certain types of plant material units is provided while other units are ignored

without any clarification.Clarification No Yes

21No explanation is provided behind functioning of the strategy to reduce harvesting from wild by

promoting cultivation without focusing on collection system.Clarification No No

22

The mission current status/issues, objectives or targets did not focus on the value added products

quality but focus to value added products quality certification in mission strategy is given with no

explanation.

Clarification No No

Mission Governance

23

SHM is running in mission mode and no clarification has been provided on the status of SLIA society

formed under SHM once the SHM mission is over Clarification No No

24The CEO is needed for running an SLIA under SMPB but no clarification is provided for a need togive such directions, when SHM and agriculture ministry are given no such directive.

Clarification No No

25 CEO is needed for SLIA under SMPB but no eligibility criteria for its selection are given. Clarification No No

26In case of SMPB as SLIA, no reason is given for having only KVKs and ATMAs as District Level

Implementation Agency.Clarification No No

27 In case of SHM as SLIA, various agencies were mandatorily involved at district level decision Clarification No No


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making but in case of agriculture ministry no such mandate is provided without providing any reason.

28The formation of society at the different level in different governance is mentioned but no clarity onrole of different societies is provided if state agriculture ministry absorbs the SLIA under SHM or

vice versa

Clarification No No

29The cultivation cluster needs to link with the market but no clarification is provided on the process bywhich cultivation cluster can identify such links.

Clarification No No

30State is given responsibility to identify cluster and district without explaining the identificationprocess.

Clarification No No

31The role of district level societies is not clarified in case of direct reporting of clusters, ATMAs andKVKs to the SLIA

Clarification No No

32 District level agency is supposed to govern the cluster but the mechanism of governance is notclarified

Clarification No No

33The mission fails to provide the adequate clarity on the functioning of the various governmental

bodies and linkages thereofClarification No No

34 The information regarding the timelines for setting up the governance structure is not provided Modification No No

35The selection of implementation is at the state's discretion but there is lack of mandate for state to

declare their evaluation process for selection of agenciesModification No No

36 Mission lacks provisioning for databases to maintain information related to progress and stakeholders. Modification No No

37Manpower requirement for this mission is identified but no clarity is provided about the workinglevels and roles and responsibilities to be fulfilled at those levels as well as about manpower

deputation from existing departments.

Clarification No No

38The state has mentioned about the FC to provide technical support to the applicant but their role andresponsibilities are not clearly defined

Clarification Yes Yes

Mission Stakeholder

39The many stakeholders representative are involved at centre and state level governance but no clarityis provided on their selection process.

Clarification No No

40Traders, gatherers and collectors have not been acknowledged as the stakeholder for decision makingby the document though they play an important role in running of herbal trade.

Modification No No

41The accountability mechanism has been provided for applicants of subsidy but for other stakeholders

and job and responsibilities no reason for very weak mechanism for reporting and checks is provided.Modification No No

Mission Financing

42 Funds are provided for the mission but its allocation is not adequately clarified. Clarification No No

43 The information about flow of funds from centre to state is given without clarification on need for Clarification No No


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multiple funds release mechanism.

44The sanctioning of the process is centralized but no information is provided on the mechanism toensure the timely sanction and release of the subsidies.

Clarification No No

45

Subsidy will be given to applicant only if him/her has performed the applied activity but no adequate

information is provided about the time when he/she should make investment for his/her proposal andthe process of release of sanctioned subsidy to the applicant.


46This mission aims to provide opportunities to small and marginal farmers but requirement of initialinvestment can be challenge for them especially with no appropriately recommended support

mechanism to enable the groups of these to get access to initial investment.

Modification No No

47

Subsidy is provided for cultivation but no adequate information is provided about subsidy for

cultivation infrastructure and inputs, number of instalments in which subsidy is given and number ofcultivation cycles for which subsidy is available.


48Subsidies is provided to various planting material units setup but clarification is not adequatelyprovided for giving unequal benefits (financial and non-financial) to different planting material units.

Clarification No Yes

49 A state level cap is put on the cultivation subsidy for which no clarification is provided. Clarification Yes Yes

50Subsidy for marketing activities is provided but no adequate clarity is provide about the eligible

applicants and number of projects limits in certain cases.Clarification Yes Yes

51

Industry R&D unit is allowed to get subsidy for post harvesting management, processing and

laboratory setup but no clarity is provided on making eligibility process more stricter for them as

compared to their government counterpart.

Clarification No No

52Mission intends to promote value added products but no mandate is provided for lack of any subsidy

for quality testing of value added products.Modification No No

53Mission provides subsidy for laboratory setup but no mandate is provided for their AYUSH/NABL

accreditation when cultivators will use only AYUSH/NABL accredited labs for product testing.Modification No No

54

Mission intends to promote weaker section, but there is lack of clarification for no additional

incentive for those people in the activities other than cultivation, some post harvest management and

marketing infrastructure


55

Mission wants the applicant to get certification for products and activities but accessibility to these

agencies can be an issue. Since, the document fails to provide the mandate to provide the list of the

various accreditation or certification agencies which can be approached by the applicants for

certification except for the plantlet nurseries.

Modification No No

56Mission intends to promote better quality products but it inability to provide mandate for certification

of various activities makes the achievement of the desired objective difficult.Modification No No

Mission Monitoring and Assessment


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57The monitoring is important to learn from mistakes but no reason is provided for only single

monitoring during the implementation of whole plan.Clarification Yes Yes

58Consultants are needed for mission monitoring and assessment both for state and centre but no clarity

provided about whether the consultant for state and centre has to be same or different.Clarification Yes Yes

59 The selection of process of consultants is not clarified in mission. Clarification Yes Yes

60 The monitoring is done without any third party involvement. Modification Yes Yes


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Responses observed in the two Amendments

The complete list of 60 issues identified from the eight segments of the original document have been

classified on the basis of the required solution type as those requiring explanation/clarification and

those requiring modification as shown in Table 2. The study tried to analyze these issues responses by

performing intra as well as inter document analysis. Two-third of the issues are of clarification type

where more information is needed to have better understanding, while one-third of the issues are

modification type which unless addressed can create a possible undermining of efforts and intent of

the NMMP. While, the two amendments tried to address issues, the four segments namely current

status/issues, mission objective, mission target and mission stakeholders have not been addressed. In

the other four segments, three out of seven strategy issues (43%), one out of 16 governance issues

(6%), six out of 15 financing issues (40%) and four out of four regulation issues (100%) were

addressed. Twelve issues were addressed in the 1st

amendment in which 10 issues were of

clarification type and 2 issues were of modification type as shown in Table 3. Out of the 10

clarification type issues in 1st

amendment, seven responses were of clarification type, two responses

were of modification type and one response was of both clarification and modification type. One of

the two modification type responses was re-responded in 2nd

amendment with modification.

The two modification type issues identified in the original document were responded with

modification in the 1st

amendment out of which one issue was responded with modification, while

other received both clarification and modification which was readdressed in second amendment with

more modification. In addition to these issues, two additional clarification type issues were responded

only in the 2nd

amendment with modification, taking total of issues from original document with

response to 14. Amongst the mission strategy issues, the issue of cluster definition (Issue no. 16) was

addressed clearly in first amendment by providing clarity on it size as the region comprised of

maximum 3 adjoining villages in which there will be at least 5 farmers cultivating minimum of 2 ha

of land for medicinal plants. No further changes were made in the second amendment.

The issue of geographical proximity (Issue no. 18) was responded in first amendment both by

providing clarifications as well as modifications. The clarification given helped to provide greaterclarity on the financial subsidy eligibility based on the people and location of installation of non-

cultivation activities like processing and post-harvesting units. According to the clarification, public

sector and panchayats were allowed to claim subsidy to set-up units for non-cultivation activities

anywhere provided they can link with cultivation cluster. However, private sector players were

restricted to setup non-cultivation units only inside industrial estate/zone/park/cluster/area designated

by the competent authority in a state for claiming subsidy with an exception of

organizations/companies of farmers who could claim subsidy for setting-up units anywhere provided

they can link with cultivation cluster. Further, in order to make geographical proximity more

attractive, an explicit reference to permit provision of services to non-shareholders on payment basis

is provided as modification in the document which will make the unit more financially stable.

In an effort to enhance commitment of private sector players, subsidy could be provided only throughSpecial Purpose Vehicle (SPV) which needs to comprise of at least 10

enterprises/company/firms/partnership firms/producers company/traders/co-operative with Rs500,000 corpus fund provided by all the members in SPV bank account and having 2 acres of land in

target industrial estate/zone/park/cluster/area designated by the competent authority in a state. For the

cultivator groups while the permission to set-up units anywhere and requirement of SPV for set-up

inside industrial estate/zone/park/cluster/area designated by the competent authority in a state which

can potentially cause the failure of the geographical proximity solution. This disincentive was

recognized and addressed by the government as the modification in the 2nd

amendment was made by

simply removing the explicit line ofSPV necessity from the mission document. However, SPV canstill be formed by private players to access benefits such as direct approach for funds through Scheme

Monitoring Committee (SMC) and financial support up to 60% of project cost with maximum limit of

Rs 100 million with a mandate of either available laboratory or set-up of laboratory by SPV. As perthe 2

ndamendment, the number of private entities which must be enrolled for SPV is ambiguous with


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15 given in one place and 10 given in another place. The government efforts to simultaneouslyattract committed private players in the sector and maintain geographical proximity would reach

better clarity if certain ambiguities are addressed. The issue oflimited planting material productionmethods promotion (Issue no. 20) has been addressed in the second amendment by permitting plant

tissue culture units under subsidy scheme which indicates the effort of NMMP to support every

possible activity linked to herbal trade.

Amongst the governance issues, the issue of FC roles and responsibility (Issue No. 38) is addressedin a limited manner in 1

stamendment, in that role and responsibility focused mission monitoring and

mentoring activities. The FC personnel have to visit the subsidy holder at least once every six months

and monitor the status of the mission and provide mentoring to the people.

Amongst the financing issues, issue of sanctioned subsidy release process (Issue No. 45) wasaddressed with limited clarification only for certain activities namely cultivation and market

promotion in 1st

amendment and SPV based activities in 2nd

amendment. In case of cultivation,

cultivators can get subsidy sanctioned for the same land only once in the three years, which is

provided in one to three installments over a period of one to three years based on the medicinal plant

used. Annual plants will receive complete subsidy in one installment in first year itself. However, no

mention had been made about the timing of the subsidy release with respect to the growth of plants.Shrubs and climbers subsidy would be released in two installments with 75% of total subsidy

provided in the first installment in first year and remaining 25% installment in second installment in

second year provided the adequate progress was made in the first year. Tree crops and woody

climbers subsidy would be released in three installments with 65% of the sanctioned subsidy will be

given in first year and remaining subsidy of 20% and 15% of total sanctioned subsidy in second and

third year based on the progress in the first year and second year respectively. However, in case of

shrubs, climbers, tree crops and woody climbers, no explicit mention of the progress criteria which

will be checked for subsidy release is mentioned. This addressal of cultivation subsidy release also

partially addresses issue of cultivation subsidy pattern (Issue No. 47) which is otherwise notaddressed in any of the amendments.

In case of clarification made for market promotion in 1st amendment ofIssue No. 45, applicants willget 50% of the sanctioned subsidy before the start of the activity and 50% after the finishing up of the

activity. SPV based non-cultivation activities were not mentioned in the original document but these

activities sanctioning process had been clarified in the 2nd

amendment as per which funds will be

released in three installments of 20%, 40% and 40%. First installment of funds will be released with

final approval of project. 2nd

installment release will be done once 60% of 1st

installment funds are

used and proportionate expenditure is shown. Similarly, 3rd

installment is released once 60% of total

of 1st

installment and 2nd

installment funds are used and proportionate expenditure is shown.

The issue of unequal treatment meted out to different planting material production units (Issue No.48) had been addressed in the 2

ndamendment. Both seed production units and plant tissue culture

units have been provided subsidy without the provision of back ended subsidy. In case of plantlet

based nurseries, norms have been made easier while keeping the back-ended subsidy in place. The

subsidy for seed production unit for public sector is 100% with maximum of Rs 50,000/ha limited to

2.5 ha/beneficiary is provided. In case of private sector, 50% with maximum of Rs 25,000/ha limited

to 2.5 ha/beneficiary is provided. In case of Plant tissue culture units, the subsidy for public sector is

100% with maximum of Rs 5 million/unit is provided for producing 500,000 plantlets per year. In

case of private sector, 50% with maximum of Rs 2.5 million/unit is provided for producing 500,000

plantlets per year. In case of plantlet nurseries, the norms have been made easier with the increase in

subsidy by 25% for large nurseries and 56.25% for small nurseries. The plantlets production

requirement is reduced for both large and small nurseries to 50,000 plantlets/ year. However, no

reason is provided for higher increase in subsidy for small nurseries as well as maintaining same

lower limit for both large and small scale nurseries.

The issue of state cap on cultivation subsidy (Issue No. 49) had been addressed in bothamendments. In first amendment, the subsidy is increased from 30% to 35% and in the second


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amendment cap is removed altogether indicating the promotion of the mission itself. Marketingissues of inadequate information on the eligibility criteria, number of projects and project type for the

subsidy (Issue No. 50) had been addressed in a limited manner in the 1st

amendment. Marketing

intelligence activities carried out by implementation agencies will be considered for subsidy and can

get 100% subsidy of about Rs 1million/project with limit of 10 projects per year per state. Buy-back

intervention subsidy is given to the industry. Procurement cost subsidy is provided to the industry

which can be up to 10% of the procurement cost with 75% subsidy given to cultivator and 25% given

to industry. However, the procurement cost definition and process of release of the funds to the

cultivator and to the industry is not clarified by the document. The issue of weaker section support inindustrial activities (Issue No. 54) was addressed while addressing Issue No. 18 by allowingfarmer groups to set-up units outside the cluster.

All the issues related to the segment of the mission monitoring and assessment has been addressed in

the 1st

amendments along with increased responsibility of not just monitoring the status but also

mentoring the people to improve the status shared between state, FC and centre. The issue of onetime monitoring (Issue No. 57) has been addressed by including continuous monitoring by States andprovide mentoring to people as per the need. In addition, NMPB is aiming to provide focused field

monitoring and mentoring once in every six months through selected national level experts and/or FC

in the relevant fields along with the help of the state. The issue of clarity on consultants employed atstate and centre level (Issue No. 58) was addressed in limited manner with states allowed to havetheir own consultants and field experts for continuous monitoring and mentoring activities. However,

in light of this, the role of Project Monitoring Committee (PMC) at the state level becomes limited, as

the group which does the continuous monitoring can also provide mid-term and end term conclusions.

The issue of Consultant Selection Criteria (Issue No. 59) was addressed in limited manner byproviding information that the experts chosen as consultants by state for continuous monitoring and

mentoring should be retired officers/scientists from allied fields. However, the eligibility of

consultants for PMC is not provided. The issue of third party monitoring (Issue No. 60) is addressedby modifying the document to incorporate hiring consultants or company but preferably NLA to do

such monitoring as NLA are expected to collect very detailed level data involving the use of GIS

based systems for helping the selected agency and NMPB with temporal and spatial analysis.

Conclusion

The study focused on the assessment of the original document of NMMP which identified several

issues (sixty) segregated into eight segments namely current status/issues, mission objectives, mission

targets, mission strategy, mission governance, mission financing, mission stakeholder and mission

monitoring, mentoring and regulation. Subsequently, two amendments were reviewed for addressal of

identified issues. Majority of the issues required clarification and remaining needed modification for

avoiding the risk of mission failure. The issues identified in four segments namely current

status/issues, mission objective, mission target and mission stakeholders have not been addressed,

while 6% to 100% addressal has been observed for other four segments namely strategy, governance,

financing and regulation. The inadequate addressal of issues by the two amendments indicatespotential system inefficiency with risk of collectors livelihood and continued unsustainable supply ofplants. The lack of synchronization between different parts of document makes understanding of the

documents difficult and decision-making process behind the document unreliable. The lack of

accountability in the mission structure as well as of functionaries makes mission functioning

questionable. Despite several issues, focus of the amendments on the regulation and mentoring

indicates the intent of the mission to learn quickly which is reflected in the short time gap between 1st

and 2nd

amendment. The mission is a good strategy for addressing the resource challenges faced by

the medicinal plants based drug industry. The critical analysis performed in this study can form basis

for 3rd

set of amendment to avoid mission failure. Finally, this document provides the systematic

analysis of all three documents which could be proposed to be taken up with the NMMP for review.

The future study needs to focus on determining effect of document issues on mission operations using

the field based analysis as well as determining interventions and recommendations to the mission for

improving the implementation efficiency.


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48

Subsidies is provided to various planting

material units setup but clarification is notadequately provided for giving unequal

benefits (financial and non-financial) to

different planting material units.No response

Subsidy to seed

production and plant

tissue based production

with easier sanctioning

process.

Modification

Nurseries have lower

sanctioning standards.

49

A state level cap is put on the cultivation

subsidy for which no clarification is

provided.

Cap limit changed Modification No cap limit Modification

50

Subsidy for marketing activities is provided

but no adequate clarity is provided about the

eligible applicants and number of projects

limits in certain cases.

Implementation agencies will be eligible

for market intelligence with limit on the

number of project and amount. Clarification

No Change

Buy back intervention subsidy can also

involve procurement cost subsidy.No Change

54

Mission intends to promote weaker section,but there is lack of clarification for no

additional incentive for those people in the

activities other than cultivation, some postharvest management and marketing

infrastructure.

Permission to setup processing unit

outside clusterClarification No Change

Mission Monitoring

57

The monitoring is important to learn from

mistakes but no reason is provided for only

single monitoring during the implementation

of whole plan.

State need to do continuous monitoring

and mentoring, with focused monitoring

and mentoring by NMPB after every 6

months.

Modification No Change

58

Consultants are needed for mission

monitoring and assessment both for state andcentre but no clarity provided about whether

the consultant for state and centre has to be

same or different.

State need to have their own consultants

for the continuous monitoring and

mentoring.

Clarification No Change

59The selection of process of consultants is notclarified in mission.

National Level Agency should be

preferred for third level monitoringClarification No Change


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Content Analysis of India’SNational Mision on Medicinal Plants

Documents

Transcript of Content Analysis of India’SNational Mision on Medicinal Plants