The Ukraine Humanitarian Fund (UHF) recently achieved a historic milestone, with nearly 60% of its funding directed to local partners. In almost any other emergency, this would be cause for celebration. However, in the context of Ukraine, it produces mixed feelings: it highlights a glaring missed opportunity in how we define “localization.”
Traditionally, the fundamental purpose of this type of funding has been to empower local civil society NGOs rather than governmental entities. While this makes sense in many crises, applying a blanket approach to all sectors in Ukraine misses a critical structural nuance—particularly in health.
Under the country’s ambitious decentralization reform, Ukrainian health facilities have transitioned into Communal Non-Profit Enterprises (CNPEs). These are not rigid state organs; they are autonomous, community-owned entities with independent financial management and managerial freedom. Failing to count these local health facilities within our localization goals is a fundamental mistake.
Yet, major donors, including ECHO and the UHF, continue to insist on supporting only traditional local NGOs regardless of the context. By strictly excluding CNPEs from localization metrics, donors are relegating humanitarian health assistance to the periphery of the population’s actual needs.
This creates a perverse incentive system where specialized medical NGOs are essentially coerced into tailoring their programming simply to meet rigid “localization” requirements. Often, this forces them to pivot away from direct clinical assistance—which is rightfully led by the local health facilities—and tilts their efforts toward general protection services just to tick the right boxes.
What are the Community Non-Profit Enterprises (CNPE)
The fundamental argument for direct partnership lies in the legal transformation of these facilities into Communal Non-Profit Enterprises (CNPEs). This isn’t just a name change; it’s a structural twist:
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Financial Independence: Unlike old budgetary institutions, a CNPE manages its own accounts outside the State Treasury. This allows them to retain funds for reinvestment and manage humanitarian grants with the fiduciary independence required by international donors.
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Managerial Freedom: General Directors now have the authority to optimize staffing and internal structures based on actual demand—a critical capability when responding to the shifting needs of a war zone.
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Corporate Governance: The bifurcation of leadership into a General Director (CEO) for business management and a Medical Director for clinical quality mimics modern corporate standards. This is where medical organizations could provide a great added value to accompany.
The Transparency of the “Unified Medical Space”
A common hesitation for Country-Based Pooled Funds (CBPFs) is the risk of aid diversion within state systems. However, Ukraine’s eHealth (EHCS) infrastructure provides a level of digital oversight that exceeds many international NGOs.
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Digital Truth: Every service, referral, and patient interaction is recorded in a central database, ensuring the “money follows the patient”.
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Accountability: The mandate for Supervisory Boards—comprising local council reps, NGOs, and independent experts—adds a layer of community oversight that prevents political interference.
The “Capable Network” (Spromozhna Merezha) has already done the hard work of identifying which hospitals are equipped to handle the most critical loads. From Super-Cluster regional hubs to General Hospitals serving smaller districts, the hierarchy is clear.
Conclusion.
In a more personal note, It is somewhat ironic that I am pointing this out myself. At 15 years old, I joined a volunteer group in my local town to which I am still attached. At 16, I was performing my first services in an emergency ambulance (in the nineties this was somehow possible). I literally grew up within a volunteer group, and I will never underestimate the contribution they make to complementing the health system. Yet, here I am arguing that funding them now is—I repeat—a major oversight.
The legal context of Communal Non-Profit Enterprises (CNPEs)