The fight against corruption is gradually turning into an important priority for our state. In addition to internal motives, for most citizens, fighting corruption has been a homework assigned to us by international donors and partner countries. It became even more urgent once Ukraine took the steadfast course towards Euro-Atlantic and European integration, and this gave rise to the implementation of many social processes and reforms, such as the open declaration of incomes of certain categories of citizens, the creation of the National Agency on Corruption Prevention, the launch of PROZORRO, the National Anti-Corruption Bureau of Ukraine, the Specialised Anti-Corruption Prosecutor’s Office, the High Anti-Corruption Court, etc.
The full-scale invasion of the Russian Federation in February 2022 and strong international financial support to our country caused another push for the development of the transparency system. Foreign donors demand further progress on the way to overcoming corruption.
The economic activities of healthcare facilities (hereinafter HCFs), in particular after they become more autonomous, may be wrought with many corruption risks. A fairly wide range of employees can use their official position for personal gain, such as demanding money from patients for providing medical care or selling medicines that were purchased by the state or a hospital and should be provided free of charge, demanding bribes in exchange of employment, receiving interest from purchases made by the HCFs, and much more. Unfortunately, cases like these were quite widespread, corruption begat corruption and ties to controlling services freed the hands of unscrupulous officials.
As the financing of the health care system began to change, the specific corporate culture, which was formed for dozens of years, started gradually changing. Many managers, doctors and medical professionals with higher moral values came into the picture. The new generation of medical professionals, the drive to fight corruption and the results of the medical reform have begun to transform the social contract that existed before. Therefore, cases of transparent functioning of HCFs are becoming more and more common.
How can you ensure the transparent functioning of your hospital?
Firstly, focus on the creation of functional systems. It is vital that the processes are standardised by approving regulations, orders and other regulatory documents. Think them through from beginning to end. For example, the uninterrupted supply of medicines to patients in a hospital requires a summary of the processes from determining your procurement needs, delivery, receiving into the warehouse, redistribution to departments and supply directly to the patient. Keep in mind that systems that work are not about employees but processes and regulations that lead to changes in the approaches to the work of the same employees.
Secondly, favour corporate governance over autocratic one. The formation of a management team and team discussions increase the effectiveness of the decisions made and their prudence, even though sometimes it can slow things down. An autocratic leader will resent that a decision can be made based on an alternative opinion of one of his colleagues, while their own idea is rejected. But this is the only way for a democratic corporate culture to be formed, which will yield its results later, in the long term. An important element here is the creation of various committees with different powers. For instance, the Needs Assessment Committee addresses procurement needs, discusses procurement requirements and determines the approximate cost and urgency of the procurement. The Hiring Committee evaluates potential candidates and makes employment decisions by voting. The Ethics Committee evaluates the work of employees when violations are detected in the ethical or medical activities of colleagues, etc.
Thirdly, prioritise anti-corruption activities. There are a number of effective laws that provide express obligations to work on this. In particular, in accordance with Part 2 of Article 62 of the Law of Ukraine “On Prevention of Corruption”, the heads of municipal non-profit enterprises (MNEs) shall approve the MNE’s anti-corruption programme if the average number of employees for the reporting (financial) year is over fifty people, and the amount of gross income from the sale of products (services) for this period exceeds UAH 70,000,000, as well as in case that the MNE participates in the procurement procedure in accordance with the Law of Ukraine “On Public Procurement” if the cost of the procurement of the goods, service(s) or works is at least UAH 20,000,000. If your MNE meets the above requirements, a separate authorised official shall be appointed to implement the anti-corruption programme, whose legal status is determined by Article 64 of the Law of Ukraine “On Prevention of Corruption”. Please note that the MNE officials have the status of officials of legal entities under public law, obliging them to annually submit a declaration of a person authorised to perform the functions of the state or local self-government. According to Law of Ukraine No. 3384-IX “On Amendments to Certain Laws of Ukraine on Determining the Procedure for Submitting Declarations of Persons Authorized to Perform State or Local Government Functions under Martial Law” dated 20 September 2023, these categories of persons include, inter alia, the head, deputy head and chief accountant of the MNE. Furthermore, Law No. 3384-IX includes the chairperson and members of the medical-consultative and medical-social expert committees, as well as the chairpersons, their deputies, members and secretaries of the permanent non-staff military-medical and medical-aviation committees as subjects of declaration.
Ensure the settlement of conflicts of interest among employees. Often, medical managers service the work of members of their families and relatives, both directly and indirectly. This applies to a wide range of individuals, from the director to any position that involves reporting, such as a senior nurse or manager. Working despite the conflict of interest is being prosecuted more and more often. To prevent this, start with a written notification of a real or potential conflict of interests to the direct manager (or, if it concerns the director, to the head of the authorised management body that appointed the director to the position, in accordance with the MNE’s Charter) and take steps to resolve it (transfer relatives from under the direct subordination, dismiss one of them or apply external control).
The anti-corruption laws are quite extensive and cover many regulations, so it is recommended to hire an anti-corruption commissioner. Entrusting these duties to the medical officer-in-charge or someone from the medical team is insufficient to ensure the appropriate level of transparency to your enterprise’s activities. Read a case of anti-corruption activities in an HCF, an example of a programme, at this link.
Another important issue is the attitude and approaches to the work of medical professionals.
Patient-centred approach, empathy and openness should be the cornerstone of patient care. It is very difficult to change a person’s attitude, but you need to lead by example, look for like-minded people and develop a new culture in the team. This is the hardest and longest part of the work, and there are no shortcuts. It is recommended to develop and approve a Code of Ethics that will guide medical professionals in their work (such as this one). To monitor the work of medical workers, introduce a patient feedback system. This communication should be easily accessible and reliable. A chatbot, questionnaires via QR codes, messengers, a call centre, patient surveys in the hospital conducted by individual employees and much more will be very helpful here. Patients can become the catalyst for the changes in corporate culture that are desirable for your enterprise.
Summing up, we should note that the fastest way to change is the codifying of processes and regulations that describe and shape the relevant systems. Long-term results depend, first and foremost, on a change in the attitude of medical workers and the formation of a new corporate culture in healthcare facilities.
