Number of private medical institutions involved in Ukraine's state Medical Guarantees Program steadily declining – association

The number of private medical institutions engaged in the Medical Guarantees Program (MGP) is steadily declining, with a particularly sharp drop observed in specialized medical care, the Association of Private Medical Institutions (APMI) told Interfax-Ukraine.

Commenting on information provided to Interfax-Ukraine by the National Health Service of Ukraine (NHSU) regarding a reduction in the contracting of private clinics to participate in the MGP, the APMI said that "the data cited by the NHSU confirm a trend that the association has been recording for several years: the number of private institutions involved in the Medical Guarantees Program (MGP) is systematically decreasing."

"In specialized care, the decline is especially sharp, from 264 private institutions and 85 individual entrepreneurs in 2025 to 221 institutions and 16 individual entrepreneurs in 2026. This is not a natural market process but the result of a targeted policy of selective contracting," the association stated.

The APMI reported that cases of refusal to contract have also affected its members.

"Some of our members received refusals to contract precisely for packages where the Ministry of Health introduced direct restrictions on the participation of private institutions or established additional conditions that did not exist in previous years. In effect, this means a change in the rules of the game after private institutions have already invested in equipment, personnel, and processes to meet MGP requirements," the APMI said.

Commenting on the reasons for refusals, the association noted that "the NHSU itself acknowledges that 74% of rejected proposals relate to four packages with direct restrictions for private providers, and another 5% concern packages reserved exclusively for municipal and state institutions."

"That is, nearly 80% of refusals are not due to quality issues or non-compliance with requirements, but due to regulatory restrictions based on ownership form. This is the key point: refusals are not because private institutions provide worse care, but because they are private," the APMI stated.

The association emphasized that the share of revenue from participation in the MGP in total revenues for private institutions that were actively engaged in the program could range from 15% to 40%, depending on profile and region.

"For primary care, this share is typically higher (some individual physicians worked almost exclusively under the MGP), while for specialized care it is lower but still significant. Losing a contract with the NHSU for such institutions is not simply a reduction in income, but the destruction of a business model they have been restructuring for over the past five to six years," the APMI said.

The association noted that "private institutions that lose NHSU contracts are forced to fully switch to direct out-of-pocket payments from patients, develop voluntary health insurance programs, or seek corporate clients; however, in wartime conditions, household purchasing power is declining, while the voluntary health insurance market in Ukraine remains underdeveloped."

"The association's strategic vision is that the MGP should be accessible to all institutions that meet quality standards, regardless of ownership form. Competition should be based on the quality of services, not on legal status," the APMI believes.

The association also stated that "the reduction in contracting directly affects staffing, as when an institution loses a stable source of funding, it is forced to optimize its workforce."

The APMI further noted that "the policy of selective contracting sends a clear signal to the market: state funding is an unreliable source for private medicine."

"An investor considering investment in the healthcare business in Ukraine sees that the rules can change within a single contracting cycle, without a transition period and without compensation for investments already made. This significantly reduces the sector's attractiveness and contradicts the course toward European integration, where the private sector in healthcare plays an important role in most EU countries," the APMI stated.

In addition, the association emphasized that "institutions that have lost contracts or received reduced contracting volumes are recording lower utilization of equipment, a higher share of fixed costs in their cost structure, and declining profitability." At the same time, "some private medical institutions are forced to scale down areas developed specifically to meet MGP needs."

"We believe that the policy of restricting the participation of private institutions in the MGP based on ownership form is counterproductive. It contradicts the 'money follows the patient' principle underpinning the reform and reduces access to medical care for patients, especially in regions where private institutions are often the only alternative to overloaded municipal hospitals," the APMI said.

"This policy undermines business trust in the state as a partner. We call on the Ministry of Health and the NHSU to return to the principle of equal access to contracting for all institutions that meet quality and safety requirements, and to consider the private sector not as a competitor to public medicine, but as its systemic partner," the APMI said.

As reported, during the 2026 contracting campaign, private healthcare institutions submitted 770 proposals to the NHSU to conclude contracts across 34 packages for the provision of specialized medical care. Of these, the NHSU rejected 146 proposals (19% of submitted proposals) across 17 packages.

Overall, the NHSU states that "in 2026, compared to 2025, a decrease has been recorded in the number of private healthcare institutions and individual entrepreneurs providing specialized medical care within the MGP." The NHSU explained this dynamic by updated approaches to forming a capable network of healthcare providers.

According to NHSU data, for primary healthcare, 226 private clinics and 594 individual entrepreneurs were contracted in 2021; 302 private clinics and 680 entrepreneurs in 2022; 386 private institutions and 835 entrepreneurs in 2023; 444 private clinics and 909 entrepreneurs in 2024; 473 private institutions and 963 entrepreneurs in 2025; and 476 private institutions and 950 entrepreneurs in 2026.

For specialized medical care, the figures were: 166 private clinics and 38 entrepreneurs in 2021; 178 private clinics and 46 entrepreneurs in 2022; 139 private clinics and 16 entrepreneurs in 2023; 240 private clinics and 46 entrepreneurs in 2024; 264 private institutions and 85 entrepreneurs in 2025; and 221 private institutions and 16 entrepreneurs in 2026.