The Ukraine Humanitarian Fund (UHF) recently achieved a historic milestone, with nearly 60% of funding directed to local partners. In almost any other emergency, I would celebrate this success; however, in the case of Ukraine, it represents a missed opportunity to directly support local health facilities.
The fundamental comparative advantage of this type of funding is typically to support local NGOs from civil society rather than governmental entities. Yet, by applying a “blanket approach” to all sectors, we have missed a critical nuance. In the specific case of the health sector—and within the context of an ambitious reform seeking deep decentralization—this exclusion is increasingly unfitting.
Under the current 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 their own financial management and managerial freedom.
Insisting on supporting only traditional local NGOs, regardless of the context, relegates humanitarian health assistance to the periphery of the population’s actual needs. This creates a situation where specialized medical NGOs are essentially coerced into tailoring their programming to meet “localization” requirements. Often, this forces them to provide services that move away from direct clinical assistance—which is already led by the local health facilities—and tilt into general protection services.
Meet 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.
A Special Situation Demands Special Modalities
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.
The humanitarian community often speaks about “working ourselves out of a job.” In Ukraine, the job is being done by CNPEs every day, and yet we prefer to prioritize funding for organizations that (sometimes) have little track record of their own.
The legal context of Communal Non-Profit Enterprises (CNPEs)