Problem

2.7.3. The electronic healthcare system is not sufficiently integrated with other databases, which creates opportunities for abuse during the use of specific functions (including the awarding of disability benefits, preventive and compulsory medical examinations, and assignment of the disability group)

General information about the problem

In recent years, there have been a number of systemic changes and digital transformations in the healthcare sector of Ukraine that mitigate corruption risks in it. In particular, the electronic healthcare system, an information and communication system that allows automating the workflows of healthcare entities, creating, reviewing, and exchanging medical information in electronic form, has been launched.
Given the need to ensure patient access to the management of their own medical data, as well as the quality, safety and accessibility of medical services, and to reduce the number of corruption risks, the electronic healthcare system should be improved.
First of all, the electronic healthcare system should be integrated with other information systems and state information resources, as otherwise it will lead to consolidation of unverified information in the register, as well as to the need for cooperation in manual mode, which carries risks of subjective interference and errors, as well as slow data exchange. In addition, as the Accounting Chamber found that the inadequate integration created conditions for payments in respect of declarations of citizens who did not actually have the opportunity to see a primary care doctor (due to conviction, staying abroad, enlistment for military service, etc.)
In addition, medical professionals and healthcare facilities are forced to use inefficient tools related to maintaining a large number of hardcopy forms of medical records, including medical charts, and collecting statistical information. This leads not only to the parallel existence of hardcopy and electronic forms, including two routes for a patient – the old one (paper-based) and the new one (electronic), which often contradict each other, but also to the continued existence of other sources of information about medical services provided in Ukraine, besides the electronic healthcare system.
It is worth separately mentioning the need to implement tools for assessing the functional status of a person according to the adapted International Classification of Functioning, Disability and Health in the electronic healthcare system. The main advantage of the classification developed by the World Health Organization is a conceptually new approach to health assessment: looking at a patient not from the point of view of a diagnosis, but from the point of view of the potential for recovery and needs (surgical interventions, rehabilitation, etc.) in order to improve the patient's productivity.
For a long time, one of the most common corrupt practices in the healthcare sector has been making unofficial payments to a healthcare worker (cash or gifts) or providing services to them for issuing medical certificates. For example, the Internet and bulletin boards are full of information about the availability of such certificates through intermediaries without having to undergoing a medical examination (falsified or valid, but definitely issued without legal grounds).
The problem of corruption in medical and social examination procedures has long been recognized as an important task in the complex of health care reforms. For example, the current procedure allows dishonest members of medical and social expert commissions to subjectively vary which disability group to establish and for how long.
The process of issuing sick leave certificates is accompanied by unfair practices and corruption (e.g., the "sale" of forged documents by third parties, or doctors entering false information to simulate a person’s incapacity for work). They are facilitated by the hardcopy form of sick leave certificates, which is easier to reproduce by third parties and does not record the time of their issuance.
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Implementation of SACP measures within the limits of the problem

The total number of OSR – 5
All measures of the SACP
measures, the implementation of which as of 30.09.2024
is about to begin to be completed
4 7 2 4 12
29
Implemented Partially implemented In progress Not implemented Not started
Measures implemented (fully and partially) - 11 (37.9%)

Deadlines for all measures

01.03.2023 - 31.12.2025

Implementation of SACP measures within the scope of the Problem by main main performers

Ministry of Health of Ukraine

44%
25

Ministry of Social Policy of Ukraine

0%
4

Achievement of ESR within the limits of the Problem

The total number of OSR – 5

SUMMARIZED GENERAL INFORMATION ON THE IMPLEMENTATION OF THE PROGRAM MEASURES IN TERMS OF DIRECTIONS, PROBLEMS AND EXPECTED STRATEGIC RESULTS

Name of the ESR Name of the measure The main implementer Monitoring results (latest) Performance note % виконаних заходів (fully and partially)
1.1. ESR 2.7.3.1 The electronic healthcare system is integrated with other state databases outside the healthcare sector, which ensures completeness, consistency and additional data verification, as well as functionality for automation of processes; the electronic healthcare system is the primary source of information about medical services provided in Ukraine, which serves as a basis for decisions to perform calculations for the medical guarantees program, make managerial decisions, and generate the relevant statistics 2.7.3.1.1. Drafting and submitting to the Cabinet of Ministers of Ukraine the draft resolution of the Cabinet of Ministers of Ukraine on amendments to the procedure of operation of the electronic healthcare system to the effect that: 1) the electronic healthcare system is the primary source of information about medical services provided in Ukraine, which serves as a basis for decisions to perform calculations for the medical guarantees program, make managerial decisions, and generate the relevant statistics; 2) the electronic healthcare system is used for electronic document exchange among healthcare institutions; 3) medical charts of patients shall be maintained exclusively through the electronic healthcare system. Ministry of Health of Ukraine The measure was implemented on time, but partially Partially implemented
0% 0/ 2
1.2. 2.7.3.1.2. Ensuring the interaction and interoperability of the electronic healthcare system with: 1) the Unified State Demographic Register; 2) the State Register of Vital Records of Citizens; 3) the State Register of Individual Taxpayers; 4) information systems of the Ministry of Social Policy and the register of insured persons within the State Register of Compulsory State Social Insurance; 5) the Unified State Electronic Database in Matters of Education; 6) the Unified State Register of the Ministry of Internal Affairs; 7) the informational and analytical platform of electronic verification and monitoring; 8) the State Register of Medications of Ukraine. Ministry of Health of Ukraine There is no progress in the implementation of the measure In progress
2.1. ESR 2.7.3.2 The electronic healthcare system contains the results of preventative and compulsory medical checkups 2.7.3.2.1. Developing a draft order of the Ministry of Health on amendments to the Procedure for Conducting Medical Examinations of Employees of Specific Categories, according to which the results of all previous compulsory and periodic preventative medical examinations must be recorded exclusively in the electronic healthcare system Ministry of Health of Ukraine The measure was implemented late and partially Partially implemented
100% 7/ 7
2.2. 2.7.3.2.2. Holding a public discussion of the draft order indicated in subclause 2.7.3.2.1, and ensuring its revision (if needed) Ministry of Health of Ukraine The measure was implemented on time, but partially Partially implemented
2.3. 2.7.3.2.3. Issuing the revised order indicated in subclause 2.7.3.2.1, supporting its state registration with the Ministry of Justice Ministry of Health of Ukraine The measure was implemented on time, but partially Partially implemented
2.4. 2.7.3.2.4. Developing and submitting to the Cabinet of Ministers of Ukraine a draft resolution of the Cabinet of Ministers of Ukraine on amendments to the Operating Procedure of the Electronic Healthcare System pertaining to the integration of data and electronic documents reflecting the results of previous compulsory and periodic preventative medical examinations into the electronic healthcare system Ministry of Health of Ukraine The measure was implemented on time and in full Implemented
2.5. 2.7.3.2.5. Drafting and approving the statement of work (“technical assignment”) for the expansion of the functionality of the electronic healthcare system with respect to: 1) gathering, processing, and storing data and electronic documents reflecting the results of previous compulsory and periodic preventative medical examinations; 2) generating electronic extracts reflecting the results of previous compulsory and periodic preventative medical examinations. Ministry of Health of Ukraine The measure has not been implemented Not implemented
2.6. 2.7.3.2.6. Developing software for expansion of the functionality of the electronic healthcare system in accordance with subclause 2.7.3.2.5 Ministry of Health of Ukraine The measure has not been implemented Not implemented
2.7. 2.7.3.2.7. Putting into operation the expanded functionality of the electronic healthcare system in accordance with subclause 2.7.3.2.5 Ministry of Health of Ukraine Implementation of the measure has not started Not started
3.1. ESR 2.7.3.3 Tools for assessing the functional status of a person according to the adapted International Classification of Functioning, Disability and Health have been introduced into the electronic healthcare system 2.7.3.3.1. Drafting and submitting to the Cabinet of Ministers of Ukraine the draft resolution of the Cabinet of Ministers of Ukraine on amendments to the procedure of operation of the electronic healthcare system to the effect that: 1) the electronic healthcare system shall be updated with information and medical documents (electronic medical records) required for establishing a person’s disability group, exclusively with the use of the adapted International Classification of Functioning, Disability and Health; 2) when a person is receiving services defined using the adapted International Classification of Functioning, Disability and Health, the electronic healthcare system forms approved by the Ministry of Health shall be used. Ministry of Health of Ukraine The measure was implemented on time and in full Implemented
300% 18/ 6
3.2. 2.7.3.3.2. Developing a draft order of the Ministry of Health on approval of the forms to be filled out by service providers when assessing the functional status of a person according to the adapted International Classification of Functioning, Disability and Health Ministry of Health of Ukraine The measure was implemented on time and in full Implemented
3.3. 2.7.3.3.3. Issuing the order indicated in subclause 2.7.3.3.2, supporting its state registration with the Ministry of Justice Ministry of Health of Ukraine The measure was implemented on time and in full Implemented
3.4. 2.7.3.3.4. Approving the statement of work (“technical assignment”) for the expansion of the functionality of the electronic healthcare system with respect to: 1) the list of all classifications of each component during the assessment of the functional status of a person according to the adapted International Classification of Functioning, Disability and Health; 2) the assignment of domain codes of all levels to each component during the assessment of the functional status of a person according to the adapted International Classification of Functioning, Disability and Health; 3) the creation of electronic forms to be filled out by service providers when assessing the functional status of a person according to the adapted International Classification of Functioning, Disability and Health; 4) automatic initiation of a question relating to the establishment of the disability group. Ministry of Health of Ukraine The measure was implemented on time, but partially Partially implemented
3.5. 2.7.3.3.5. Developing software for expansion of the functionality of the electronic healthcare system in accordance with subclause 2.7.3.3.4 Ministry of Health of Ukraine The measure was implemented on time, but partially Partially implemented
3.6. 2.7.3.3.6. Putting into operation the expanded functionality of the electronic healthcare system in accordance with subclause 2.7.3.3.4 Ministry of Health of Ukraine The measure was implemented on time, but partially Partially implemented
4.1. ESR 2.7.3.4 The functions of issuing a relevant medical opinion on the determination of the disability group and social aid based on this opinion are segregated between government agencies as a way to minimize corruption risks 2.7.3.4.1. Drafting and submitting to the Cabinet of Ministers of Ukraine a draft law on amendments to the Laws of Ukraine On the Fundamentals of Social Security for Individuals Living with Disabilities in Ukraine, On the Rehabilitation of Individuals Living with Disabilities in Ukraine, which stipulates: 1) that disability shall be determined exclusively with the use of the adapted International Classification of Functioning, Disability and Health; 2) that if a disability group has been assigned without justification, the individual shall have the disability status revoked along with the right to the relevant social aid and benefits; 3) that the functions of issuing a relevant medical opinion on the determination of the disability group and social aid based on this opinion are segregated between government agencies as a way to minimize corruption risks; 4) agencies issuing a medical opinion on the determination of the disability group and social aid are obligated to maintain electronic records while using the functional capabilities of the electronic healthcare system and other relevant software products; 5) the procedure for maintaining electronic records while performing the functions of determining the degree of impairment of vital functions, the causes of disability, the time when it manifested itself, and the disability group, determining the compensatory and adaptive capabilities of the individual, preparing (adjusting) the individual rehabilitation program of the person living with a disability, determining the needs of individuals living with disabilities for technical and other means of rehabilitation, medical devices, and other social aid; 6) the obligation of all healthcare institutions to enter into the electronic healthcare system by January 1, 2025, all of the archived electronic medical records pertaining to the assignment of a disability group based on original medical records according to the list prescribed by the Cabinet of Ministers of Ukraine, followed by the publication of all materials in a depersonalized format; 7) the obligation to publish in a depersonalized format all materials of medical-social expert committees (entities that are performing or will be performing their functions) pertaining to the assignment or prolongation of the disability status; 8) requirements with respect to the composition of bodies that perform the function of issuing a relevant medical opinion pertaining to the assignment of the disability group and social aid based on this opinion, the authorized officers of such bodies, in particular the qualification requirements, the procedure for selecting and appointing them, the term for which the members (authorized officers) are elected (appointed) to the bodies that perform the function of issuing a relevant medical opinion pertaining to the assignment of the disability group and social aid based on this opinion; 9) a ban on serving as a member (authorized officer) of bodies that perform the function of issuing a relevant medical opinion pertaining to the assignment of the disability group and social aid based on this opinion for more than two consecutive terms from the date of appointment (election); 10) a ban on simultaneously serving as a member (authorized officer) of the body that performs the function of issuing a relevant medical opinion pertaining to the assignment of the disability group and the body that performs the function of granting social aid on the basis of this opinion; 11) a ban on serving as a member (authorized officer) of bodies that perform the function of issuing a relevant medical opinion pertaining to the assignment of the disability group and social aid based on this opinion applicable to individuals in respect of whom there is a legally binding court verdict that imposed on them a criminal penalty for committing corruption or a corruption-related offense, a court ruling that relieves them of criminal liability or a court decision to hold them administratively liable for committing a corruption-related offense, where this ruling or decision has imposed a penalty in the form of disqualification from occupying specific positions or engaging in specific activities associated with the performance of functions of state or local self-government; 12) a ban for next of kin (as defined by the Law) from serving as members (authorized officers) of one and the same body that performs the function of issuing a relevant medical opinion pertaining to the assignment of the disability group or social aid on the basis of this opinion; 13) instances in which the person applying for disability status or having this status participates in the meeting of the body that performs the function of issuing a relevant medical opinion pertaining to the assignment of the disability group, during deliberation of the issue of issuing a medical opinion on the assignment of a disability group; 14) the right of a person living with a disability to file an application with the body that performs the function of granting social aid on the basis of a medical opinion pertaining to the assignment of the disability group, irrespective of the location where the person resides or is undergoing treatment, with the option to have application reviewed remotely; 15) the principles of transparency and openness in matters of determining the degree of impairment of vital functions and rehabilitation of individuals living with disabilities, including: the documenting of the proceedings of the body that performs the function of issuing a relevant medical opinion pertaining to the assignment of the disability group or social aid on the basis of this opinion using video and audio recordings (if this meeting is held in person), and establishing the minimum period of at least 10 years during which such records must be stored in a system protected against unauthorized deletion. Ministry of Health of Ukraine The measure has not been implemented Not implemented
0% 0/ 13
4.2.(1) 2.7.3.4.2.(1) Drafting and submitting to the Cabinet of Ministers of Ukraine the draft normative legal acts proposing amendments to the normative legal acts of the Cabinet of Ministers of Ukraine in order to align them with the law indicated in subclause 2.7.3.4.1 Ministry of Health of Ukraine Not started
4.2.(2) 2.7.3.4.2.(2) Drafting and submitting to the Cabinet of Ministers of Ukraine the draft normative legal acts proposing amendments to the normative legal acts of the Cabinet of Ministers of Ukraine in order to align them with the law indicated in subclause 2.7.3.4.1 Ministry of Social Policy of Ukraine Not started
4.3.(1) 2.7.3.4.3.(1) Drafting normative legal acts that propose amendments to the normative legal acts of the Ministry of Social Policy and the Ministry of Health in order to align them with the law indicated in subclause 2.7.3.4.1 Ministry of Health of Ukraine Not started
4.3.(2) 2.7.3.4.3.(2) Drafting normative legal acts that propose amendments to the normative legal acts of the Ministry of Social Policy and the Ministry of Health in order to align them with the law indicated in subclause 2.7.3.4.1 Ministry of Social Policy of Ukraine Not started
4.4.(1) 2.7.3.4.4.(1) Holding a public discussion of the draft normative legal acts indicated in subclause 2.7.3.4.3, and ensuring their revision (if needed), issuance, and submission for state registration Ministry of Health of Ukraine Not started
4.4.(2) 2.7.3.4.4.(2) Holding a public discussion of the draft normative legal acts indicated in subclause 2.7.3.4.3, and ensuring their revision (if needed), issuance, and submission for state registration Ministry of Social Policy of Ukraine Not started
4.5.(1) 2.7.3.4.5.(1) Supporting the state registration of draft normative legal acts indicated in subclause 2.7.3.4.3 and their official publication Ministry of Health of Ukraine Not started
4.5.(2) 2.7.3.4.5.(2) Supporting the state registration of draft normative legal acts indicated in subclause 2.7.3.4.3 and their official publication Ministry of Social Policy of Ukraine Not started
4.6. 2.7.3.4.6. Drafting and submitting to the Cabinet of Ministers of Ukraine the draft resolution of the Cabinet of Ministers of Ukraine on amendments to the procedure of operation of the electronic healthcare system to the effect that: 1) it incorporates a subsystem for granting disability status; 2) the subsystem for granting disability status involves generating and automatically publishing depersonalized records of the bodies that perform the function of issuing a relevant medical opinion pertaining to the assignment of the disability group and social aid based on this opinion, in electronic form; 3) the subsystem for granting disability status fully interacts with the central database of the electronic healthcare system and other state registers and databases in real-time mode in the “request-response” format; 4) the subsystem for granting disability status involves automatic initiation of procedures to determine the disability group (after the electronic system has received a medical record about the health component that entitles the person to disability status in accordance with the adapted International Classification of Functioning, Disability and Health) and determine the compensatory and adaptive capabilities of the individual, prepare (adjust) the individual rehabilitation program of the person living with a disability, and determine the needs of individuals living with disabilities after filling out the electronic form for assessment of the person’s functional status according to the adapted International Classification of Functioning, Disability and Health; 5) it incorporates an electronic register of individuals living with disabilities and a register of agencies and officials operating within the system for assigning disability status; 6) the electronic register of individuals living with disabilities and the register of agencies and officials operating within the system for assigning disability status involve additional identity verification using the BankID system and a photo. Ministry of Health of Ukraine The measure has not been implemented Not implemented
4.7. 2.7.3.4.7. Drafting and approving the statement of work (“technical assignment”) for the expansion of the functionality of the electronic healthcare system indicated in subclause 2.7.3.4.6 Ministry of Health of Ukraine Implementation of the measure has not started Not started
4.8. 2.7.3.4.8. Developing software for expansion of the functionality of the electronic healthcare system indicated in subclause 2.7.3.4.6 Ministry of Health of Ukraine Implementation of the measure has not started Not started
4.9. 2.7.3.4.9. Putting into operation the expanded functionality of the electronic healthcare system indicated in subclause 2.7.3.4.6 Ministry of Health of Ukraine Implementation of the measure has not started Not started
5.1. ESR 2.7.3.5 The electronic register of sick leaves has been put into commercial operation 2.7.3.5.1. Holding a semiannual monitoring of the proper functioning of the electronic register of sick leaves, which must necessarily involve studying the status of compliance with the requirements pertaining to: 1) issuance of sick leaves of insured persons in electronic form only; 2) issuance of an extract from the electronic register of sick leaves as the sole proof of the insured person’s incapacity for work. Ministry of Health of Ukraine There is progress in the implementation of the measure In progress
0% 0/ 1

Key sources on the state of the problem:

Assessment of the situation by international monitoring mechanisms and organizations: