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How the Ministry of Health of Ukraine is trying to shift responsibility for its mistakes to the Ukrainian Parliament


The Verkhovna Rada Committee for Public Health has rejected an inadequate draft National Targeted Social Programme for TB Control for 2018-2021.


The Ministry of Health of Ukraine developed and in January 2019 submitted draft Law of Ukraine on approving the National Targeted Social Programme for TB Control for 2018-2021 (No. 9467) to the Ukrainian Parliament.

On 24 April 2019, this draft Law of Ukraine was reviewed at a meeting of the Verkhovna Rada Committee for Public Health.

Having reviewed the draft law, people's deputies of Ukraine serving on the Committee noted a number of its shortcomings that make it impossible for the Verkhovna Rada of Ukraine to approve the draft law with the proposed content of the National Programme.

"Stop TB Together" Coalition of Organisations also carried out detailed analysis of the draft programme that had been provided for the Committee's members.

Participating in the meeting of the Committee was co-head of the Coalition Igor Gorbasenko who, based on the results of analysis of the draft programme, said that the programme must be returned to the Cabinet of Ministers and Ministry of Health of Ukraine so that they revise and improve it and gave a number of important remarks regarding the draft law.

The main shortcomings of the draft programme, based on the results of its analysis by the community dealing with TB:

  • for the first time in the history of drawing up TB programmes, the almost three-year-long work by the MoH of Ukraine of developing the new Programme is no more than a declaration of intentions.
  • The proposed draft TB Programme is full of manifestative and declarative phrases (such as "comprehensive coverage", "rational use", "successful external control", "proper access", "of the entire set of services... in full", "optimisation ... of the effect of programmes" etc.) that aren't concretised into criteria and indicators.
  • The Programme includes items and measures that were planned for or already carried out in 2018, but the Ministry of Health of Ukraine is seeking to get financing for them from the State Budget of Ukraine starting from 2019, which will lead to possible double financing of certain items of the Programme and misuse of funds.
  • Since the Programme was submitted to the Parliament for approval in 2019, it should be re-developed taking account of changed period for its implementation and financing and should be named the Programme for 2019-2022.
  • The proposed Programme is based on statistical TB incidence figures for 2016 that don't reflect today's situation with the TB epidemic and are unacceptable for such a document.
  • The financial and programmatic calculations underlying the proposed draft Programme are based on distorted data that doesn't correspond with the real official results of the MoH's activity in the previous programme period (according to the materials by the Auditing Chamber of Ukraine).

In particular, the section "Purpose of the Programme" says:

"As a result of implementation of the National Targeted Social Programme for TB Control for 2012-2016, TB incidence among the population decreased by 9 per cent".

However, an audit carried out by the Auditing Chamber of Ukraine (Decision No. 9-1 of 11 April 2017) showed that:

"almost 82% of the measures provided for by this programme that had expired as of 1 January 2017 were implemented partially or weren't implemented at all.

Overall more than 3.2 bln UAH were allocated for its implementation, including 2.1 bln from the state budget and 1.1 bln UAH as international assistance".

That is, the more funds are allocated and the less measures provided for by financed plans are implemented, the better the indicators are?

According to the WHO, the average estimated TB incidence among children in Ukraine is 37.4 per 100,000, or 2,500 children, i.e. it is 4.5 times the official statistical figure, while in economically developed countries cases of TB in children are very rare (Tuberculosis surveillance and monitoring in Europe, WHO 2017, 162 p.).

The inadequacy and declarative nature of the programme unprecedented in all the years the TB epidemic has existed in Ukraine are apparent, first and foremost, from the content of the section "Decisive political measures and support systems (systemic support for and reform of services provision)".

A clear proof of the lack of political will to overcome the TB epidemic in Ukraine is that there are:

  • No obligatory inclusion of expenditures related to the National Programme in the category of protected items of the State Budget of Ukraine.
  • No need to fulfil the promise made by the MoH of Ukraine and the Government to let TB establishments use funds saved on shortening of their bed capacity to ensure effective infection control, do repairs, raise salaries and improve treatment and laboratory facilities and equipment.

(Because in the section "Purpose of the Programme" the Ministry of Health declares the following: "Ineffective use of funds to finance TB control measures which are spent on supporting the existing network of TB establishments with an excessive number of beds that are in an unsatisfactory condition, without proper adherence to the principles of infection control...").

  • No detailed strategy for infection control developed in implementation of the Law of Ukraine "On Ensuring Sanitary and Epidemiological Well-Being of the Population" that would include:
  • Approval of a new edition of the Standard for Infection Control over TB.
  • Development of a National Infection Control Plan.
  • Development of a system of monitoring and assessment of TB infection control.
  • Definition of principal country coordinator for "infection safety".
  • Taking account of inclusion in the "patient-oriented approach" declared in the National Programme of obligatory provision of patients, at the expense of the State Budget or other sources, with symptomatic drugs to protect them from irreversible side reactions affecting their liver, hearing, eyesight, nervous system etc. that could result from administration of a priori toxic TB drugs. Intolerance of side reactions is one of the main reasons for giving up treatment and, as a consequence, spread of the infection reservoir among the population.
  • Taking account of the WHO recommendations regarding the TB-diabetes comorbidity, including keeping record of comorbidities.
  • Ensuring reform of the state policy in the area of TB control based on a multidepartmental and multisectoral approach.
  • Ensuring reduction in TB incidence and mortality among children that includes:
  • Setting up a system of thorough TB screening for Ukraine's children population.
  • Development and inclusion in the Programme of a set of measures aimed at drastic reduction in TB incidence among children.
  • Introduction of an effective system for TB detection, prevention and treatment of active military men in the eastern part of the country and those who left military service, as well as internally displaced persons.
  • Development by the MoH of Ukraine of an action plan to make sure that the infection reservoir doesn't spread among the population as a consequence of active bacteria releasers being among people.

Based on the results of review of the draft Law of Ukraine on approving the National Targeted Social Programme for TB Control for 2018-2021 (No. 9467), the Verkhovna Rada Committee for Public Health took the decision to return the draft law to the Cabinet of Ministers of Ukraine so that they improve it.

Documents that are highest-level road maps, such as a law, must not look like they were drawn up "just to be" and be submitted poorly prepared to 450 people's deputies of Ukraine for approval. For more than two years, since the previous TB control programme had expired, the country didn't have a new national TB programme through the fault of the Ministry of Health of Ukraine and the Cabinet of Ministers of Ukraine amid the TB epidemic.

To sum up the aforesaid: both the absence of such a programme for two years and the very low quality of the submitted draft Programme show that, contrary to the needs of Ukraine's people, the senior officials of the Ministry of Health of Ukraine and the Cabinet of Ministers of Ukraine just don't need a National Programme that provides for allocating strictly controlled funds from the state budget, or perceive such a programme as a hindrance.

The reason for this is that for many years the Ministry of Health of Ukraine and the Cabinet of Ministers of Ukraine have uncontrolledly and irresponsibly used international donor assistance funds, first of all funds allocated by the Global Fund to Fight AIDS, Tuberculosis and Malaria.

A kind of "replacement therapy" or, more precisely, living off money provided by donor countries' taxpayers.

Although international assistance programmes should just be a complementary supplement to certain items of a national programme.

This strategy by the Ministry of Health of Ukraine and its upsetting results have already attracted the attention of both authorised state bodies, in particular, the Auditing Chamber of Ukraine, and Ukrainian journalists who conduct independent journalist investigations.

And we'd like to express gratitude to the Verkhovna Rada Committee for their principled position that once again made it impossible to defile and compromise Ukrainian lawmaking in the area of public health.

Co-head of "Stop TB Together" Coalition of Organisations, member of the National Journalist Association of Ukraine    Igor Gorbasenko

Head of the Board of the Charitable Organisation "The Ukrainians Against Tuberculosis" Foundation" Vitalii Rudenko

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