Developing the capacity of CCM members representing civil society in Central Asia: a two-day workshop took place in Almaty, Kazakstan

On February 13-14, 2019 in Almaty, Kazakhstan, the Eurasian Harm Reduction Association (EHRA), within the framework of the Regional Communication and Coordination Platform project in the EECA region, with the support of the Global Fund, held a two-day workshop on “Developing the capacity of CCM members representatives civil society in Central Asia” for CCM representatives from the non-governmental sector from 4 countries of Central Asia – Kazakhstan, Kyrgyzstan, Tajikistan and Uzbekistan.

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EHRA and the Alliance for Public Health call to join the Valentine’s Day Global Action in support of the Global Fund’s efforts to ensure the necessary level of investment within the Sixth Replenishment

On the 11th January 2019, the Global Fund announced its fundraising target for the next three-year cycle for 2020 – 2022. The Executive Summary of the Sixth Replenishment Investment Case describes how a minimum of US$14 billion will help save 16 million lives, cut the mortality rate from HIV, TB and malaria in half, and build stronger health systems by 2023. The Global Fund’s Sixth Replenishment Conference will take place in Lyon (France) on 10 October 2019.

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Budget Advocacy. A guide for community activists

This guide is intended to inform community activists from key affected populations (KAPs), civil society organizations (CSOs), and community-based organizations (CBOs) on how to engage in meaningful, transparent, and accountable budget advocacy towards domestic government at national or subnational level. The regional focus of this guide is Eastern Europe and Central Asia (EECA), although it can also be used by individuals from other regions.

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Status of transitions in the EECA region

Eastern Europe and Central Asia (EECA) is one of two regions, along with Latin America and the Caribbean, where planning for the transition away from Global Fund support is most advanced. The following table shows components in the various categories of transition from Global Fund support

* In the first column, only components still active as recently as 2015 are listed.

More information in the article

Connecting NGO and communities representatives from Eastern Europe and Central Asia with 3 Delegations to the Global Fund Board

The session on “Connecting NGO and communities representatives from Eastern Europe and Central Asia with 3 Delegations to the Global Fund Board” was held in the The Global Fund Community Zone of the Global Village at the XXII International AIDS Conference (AIDS 2018) on 25 July, 2018.

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Global Fund grant to Belarus in 2015 was conditional on the government developing a social contracting mechanism

Author: Ivan Varentsov

A social contracting mechanism which would allow the government to contract with NGOs to deliver prevention programs to key affected populations in Belarus is “under construction.” It is a slow process and there are still some uncertainties about how well it will function.

Background

A mechanism allowing the government to co-finance social services and projects being implemented by NGOs has existed in the Republic of Belarus for a number of years and has been regulated under the Social Services Law. However, under this law, it is not possible to financially support the provision of NGO-based HIV prevention services among key affected populations.

An analysis carried out by Belorussian NGO “ACT” in 2016 (on file with the author) identified the following barriers to government financing of NGO-based HIV prevention activities imposed by the Social Services Law:

  • subsidies are provided only for salaries;
  • subsidies for social projects are provided only where the government commits to paying 50% of the costs (or less); the NGO commits to paying at least 50% of the costs; and the NGO possesses funds to cover its share;
  • subsidies were available only for services to be provided to “citizens in difficult life situations”; people who inject drugs (PWID), sex workers and men who have sex with men (MSM) are not considered to fit this definition under the legislation;
  • the Social Services Law does not cover health care; there is no legislation covering social contracting for health care and, therefore, HIV prevention services;
  • “outreach worker” is not among the types of jobs listed in the Belorussian official job classifier, so it is not possible to include salaries for them within social contracting under the Social Services Law; and
  • under the Social Services Law, services can be provided only upon the written consent of the recipient of the services, so services cannot be accessed anonymously, which effectively makes it impossible to provide services to key affected populations.
 In November 2015, a grant agreement in the amount of $12,309,479 to support the HIV response was signed between the Global Fund and the Republic of Belarus for the period 1 January 2016 to 31 December 2018. According to the Grant Confirmation document (on file with the author) signed between the Global Fund and the Government of Belarus, among other matters, the parties agreed that in order to support prevention services for key populations before 30 September 2016 the Government of Belarus has to ensure the development of a social contracting or other relevant financial mechanism allowing NGOs to receive governmental funding for these purposes.

It is important to mention here that under the new funding model introduced by the Global Fund in 2013, before the grant confirmation (previously called the grant agreement) is signed, a Framework Agreement outlining all of the terms and conditions of the grant has to be signed between the Global Fund and the relevant government. The grant confirmation becomes an integral part of the Framework Agreement.

“Introduction of the social contracting mechanism for HIV prevention into legislation became possible mainly due to the fact that the Framework Agreement signed between the Global Fund and the Belorussian Government in October 2015 has the status of law in the Republic of Belarus. The grant agreement which was signed by the Global Fund and the principal recipient on behalf of the Ministry of Health is an integral part of the Framework Agreement. Therefore, the obligation to establish the relevant social contracting mechanism was confirmed by the Belorussian government legislatively,” explained Elena Fisenko, Head of the HIV division of the Global Fund Grants Management Department in the Republican Theoretical and Practical Centre for Medical Technologies, Informatization, Management and Economics of Healthcare of the Republic of Belarus.

This obligation on the part of the government resulted in the inclusion in early 2016 of a number of HIV-related activities, including those focused on key affected populations (KAPS), into Sub-Program 5 (“HIV prevention”) of the Governmental Program “Health of Nation and Demographic Security of the Republic of Belarus” for 2016–2020 –– implying that the provision of governmental subsidies to NGOs for implementation of the activities would start in 2017. Necessary funds were budgeted for these purposes, but this was done before the legislation to allow for social contracting was actually being developed.

Protracted process of the mechanism introduction

To ensure the development and introduction of the proper social contracting mechanism in the health care sphere allowing NGOs to receive governmental funding for HIV prevention activities among KAPs, the process of changing the relevant legislation (The Law on Prevention of Socially Communicable Diseases and HIVwas initiated in 2016. It took more than a year to adopt the necessary amendments and pass the new version of the law –– the process was completed only in July 2017. Moreover, an additional six months were needed to prepare and enact all necessary subordinate legislation once the law comes into effect on 19 January 2018.

Initially, this mechanism was expected to start working by the end of 2016, but this never happened.

“Changes in legislation happen very slowly. It is really fast that in two years we managed to have legislation changed and prepare all regulations and procedures for approval of the social contracting mechanism in health care. It could have been done in 2016 only if relevant changes in legislation had been launched in 2014–2015,” said Valery Zhurakovski, an expert in the NGO “ACT,” a local organization advocating for introduction of the social contracting mechanism in health care, and particularly in the sphere of HIV prevention since 2010.

Consequences of the delay for HIV prevention programs

The government’s Program for HIV Prevention 2016–2020 included a plan to start funding NGOs to deliver services through a social contracting mechanism starting in 2017. It was expected that the Global Fund would remain the main donor of these programs in 2016, and that its share of the funding would then start to decline, finally ending by 2019 –– whereas government funding through the social contracting mechanism would start increasing in 2017, and would continue to grow, thus ensuring a smooth transition from the Global Fund’s support of HIV prevention programs among key affected populations to full government funding by 2020 (see table). But this didn’t happen in reality.

Table: Planned budget of the Governmental Program of HIV Prevention for 2016–2020

Objectives of the program: Reduction of HIV transmission among populations with high risk of infection (injection drug users and their sexual partners; male and female sex workers; MSM; prisoners; adolescence practicing high risk behaviors.
Ordering party Sources of funding Amount of funding (Belarus rubles)
Total 2016 2017 2018 2019 2020
Global Fund 81,300,200 35,925,200 27,713,400 19,661,600 0 0
Oblast government, Minsk government Local budgets 162,641,400 548,300 17,087,400 33.612,800 53,804,900 57,598,000

 

Because the social contracting mechanism was not yet developed, the funds being planned for 2017 under the Governmental Program on HIV Prevention for 2016–2020 for support of NGO-based HIV prevention activities were spent on other needs that the regional governments deemed important.

Nevertheless, a government financial contribution to prevention services for key populations in 2017 was partly ensured through supporting the work of 10 HIV prevention units based in government healthcare facilities that provided anonymous counselling to people who use drugs. This partially reduced the additional financial burden on the Global Fund grant in 2017 caused by the necessity to ensure the provision of a decent level of prevention services in the absence of government funding through the social contracting mechanism.

“As it is clear that in 2018 prevention services will again not be fully covered by government funding through the social contracting mechanism, the Ministry of Health decided to considerably increase its purchase of ARVs from the governmental budget in 2018. Thus, funds initially budgeted for that purpose within the Global Fund grant could be reprogrammed to support prevention services among affected populations,” Fisenko said.

Social contracting mechanism

According to the government’s draft “Regulations on the conditions and procedures of social contracting in the area of socially communicable diseases and HIV prevention” (on file with the author), social contracting will be implemented by providing NGOs with “subsidies” from local budgets for services and (or) projects aimed at preventing socially communicable diseases and HIV. (In Belarus, all official documents use the term “subsidies” to describe the funding available through social contracting.) Subsidies for the implementation of projects will be granted under condition of partial co-financing by the NGOs, likely at the level of 20%. The subsidies may cover a wide range of expenses, including: NGO employees’ salaries; administrative expenses (i.e. rent, stationery, bank expenses, office equipment maintenance); project activities; and the purchase of items to be distributed (such as syringes, needles, sterile napkins, motivation packs, lubricants, condoms and information materials).

Social contracting will be implemented on the local (oblast) level. The contracting will be managed by the oblasts, particularly the health care committees which will be responsible for announcing tenders. Funds will be provided via the relevant government programs –– in the case of HIV prevention, the Governmental Program on HIV Prevention for 2016–2020. For each tender, the process will produce a winning bid (or bids) from among the NGOs that participated, after which the oblast will arrange for contracts to be signed and the subsidies to be provided.

It is expected that contracts with the implementers could be for a period of up to five years, depending on the framework and timelines of the government programs. However, Fisenko told Aidspan that funding will most likely be provided one year at a time.

The draft regulations do not mention specific target groups. ACT’s Valery Zhurakovski explained: “The epidemiology can vary from oblast to oblast and thus it will be up to each oblast to determine what the target groups are for the funding.”

According to the draft criteria for evaluating the tender proposals (on file with the author), among the factors to be considered are (a) the work experience of the organization in the area of socially communicable diseases and HIV prevention; and (b) experience working with the representatives of the target groups –– i.e. the intended recipients of the service.

Potential obstacles for the introduction of the social contracting mechanism

Experts outlined some of the problems that may be encountered when introducing the social contracting mechanism. One potential problem is related to decision to implement the mechanism at the oblast level rather than the republican (i.e. central government) level. “In local budgets, funds are allocated first to certain obligatory budget lines,” explained Irina Statkevich, CCM member, and Head of the local NGO “Positive Movement.” “Social contracting is not one of those lines. Thus, in the event of a budget deficit, funding within the local budget would be spent first on the priority areas, and the activities to be supported within the social contracting mechanism can appear to have no financing at all if there are not enough funds left over.”

Another possible problem is that the majority of the local bureaucrats have no previous experience with social contracting, especially in the area of HIV prevention for key affected populations. And the idea to allocate funds to support the work among such groups as PWID, MSM and sex workers may seem as a quite a revolutionary idea for most of them.

“I am not sure about authorities’ readiness to name in tendering specifications the target groups in a way we do,” Zhurakovski said. “There was no precedent up to now to have them in official documents.”

Zhurakovski added: “Also, in some places, local authorities consider the grown-up working population to be the target group for HIV prevention programs. In such cases, workplace interventions to prevent HIV may become the priority for them. That’s why some local bureaucrats may decide to allocate part of funds planned within the government program for these purposes.”

According to Elena Fisenko, an additional problem is that the budget for 2018 has already been set, based on laws and regulations already in effect. The amendments to the law introducing social contracting in prevention of socially communicable diseases and HIV are effective only as of January 2018. Thus, no oblast government has budgeted funding for social contracting for 2018. “In practice, it will mean that approximately in February or March 2018, oblast governments will have to change their already approved budgets which, in any case, can be done only on a quarterly basis. And the best-case scenario is that money for social contracting will appear in local budgets starting from the second quarter of 2018,” said Fisenko.

The role of civil society

The importance of the role of civil society representatives in the introduction of the social contracting mechanism for socially communicable diseases and HIV prevention in Belarus deserves to be mentioned separately. On the one hand, experts who contributed to this article highlighted the transparency of the process of developing the social contracting mechanism by the authorities, as well as the possibility for NGO representatives to participate in this process. On the other hand, for a number of years, civil society representatives were actively advocating for adoption of this law and also for keeping to the principles of NGOs work in providing prevention services to key affected populations within the framework of this mechanism. The NGO “ACT” merits a special mention as it has been leading the advocacy work on social contracting in HIV prevention for many years and had vast experience in dealing with the Ministry of Labour and Social Protection in the context of social contracting implementation under the Law on Social Services. For this reason, the representatives of ACT took an active part in development of all key documentation on social contracting in Belarus, including the development of relevant legislation, bylaws, drafts of resolutions of the Council of Ministers, and so on.

It should also be mentioned that advocacy activities of ACT with respect to a social contracting mechanism have been financed for a number of years from Global Fund grants. This can serve as a good example for how the Global Fund could successfully contribute in middle-income countries to the transition from donors’ support of HIV prevention services for key affected populations to national funding.

“Our work is focused not only on the social contracting. We are also advocating for the creation of the enabling environment for the work of NGOs in the country in general, including exploring other options for attracting funding –– such as foreign grants or donations, charity and also changes in the approach for the taxation in this sphere,” Zhurakovski said. “We are in active on-going communication with the relevant department regarding the possibility of changing the procedure for NGOs for registration of foreign grants or donations in Belarus by lowering the threshold. We work closely with the Ministry of Finance, the revenue authority and Parliament regarding changes in the approach to taxation of local fundraising. We understand that a social contracting mechanism is not able to solve all the problems and cover all needs. Organizations will nevertheless need other resources and it is necessary to make it easier for them to get the access to the resources needed as well as to facilitate this process.”

Original publication on aidspan.org

The Global Fund is supporting stakeholders in Montenegro to develop a social contracting mechanism

This article is the authors original version of the one published at Aidspan earlier this month

Author: Ivan Varentsov

The economic growth of developing countries coupled with the slow recovery of developed (donor) countries after the recent economic crisis has changed traditional development assistance models. As a result, in recent years a clear tendency has been observed in a decrease of funding available from international and bilateral donors to middle income countries (MICs) for health-related responses, including for HIV and TB programs, and the Global Fund is no exception. Consequently, there is a widespread concern as to how to ensure the successful transition from Global Fund support of HIV and TB responses to national funding in MICs and the sustainability of such programs, especially those targeted at KAPs. The majority of countries transitioning from donors‘ support have certain mechanisms for government support of NGOs working in a social sphere. But in most cases such mechanisms are not applicable for support of HIV/TB prevention services targeted on KAPs. This problem among another issues related to the so called „social contracting mechanisms“ was discussed at a „Global consultation on social contracting: working toward sustainable responses to HIV, TB, and malaria through government financing of programs implemented by civil society“ convened by the Open Society Foundations, the United Nations Development Programme, and The Global Fund to Fight AIDS, Tuberculosis and Malaria, which took place at the beginning of October 2017 in New York (USA). A case of Montenegro as the country with a positive and to some extent pioneering experience in developing enabling environment for social contracting in a short time period due to the joint efforts of all key stakeholders involved: government, donors, technical partners and civil society, was presented at that consultation. We decided to study this case more precisely.

Brief overview of HIV epidemiological situation in county and the history of Montenegro‘s eligibility for the Global Fund‘s HIV related support

Montenegro is a low HIV prevalence rate country (0.02%) with a population of about 623 thousand people facing challenges with possible growth in concentrated epidemic, especially among population of MSM. According to the Institute of Public Health (presentation at the National HIV/AIDS Conference, March 2017) 228 HIV positive people were registered in Montenegro since 1989, which is approximately 50% of the estimated total number. According to the 2015 HIV/AIDS Report by the Montenegrin Institute of Public Health the prevailing mode of transmission of HIV in Montenegro is unprotected sex (85%), and retains this increasing trend since the beginning of the epidemic. Parenteral way of HIV transmission still remains very rare – only 4% of all registered HIV cases, out of which 1% were infected inside medical institutions outside of Montenegro, and 3% due to the sharing of contaminated injecting equipment. According to the data from the Institute of Public Health zero new infections among people who inject drugs were diagnosed since 2012.

By now the total Global Fund HIV related investment in Montenegro is US$8,765,158.  This includes Round 5 grant started in 2006 and Round 9 grant started in 2010. The implementation of both grants came to an end by June 2015 while the support of the work of CCM was ensured for two following years.

After introduction by the Global Fund in 2011 of the new eligibility criteria Montenegro – being classified as a UMIC with a low disease burden – became one of the countries ineligible for further Global Fund HIV suppor and zero funding was allocated for the country in 2014 when the New Funding Model was introduced. However in 2016, Montenegro’s HIV disease burden categorization changed from ‘Moderate’ to ‘High’ based on the data from the 2014 integrated bio-behavioral survey that showed the increased disease burden among MSM and in accordance with the Global Fund Board’s decision in November 2016 on the allocation of resources for the 2017-2019 allocation period, Montenegro has been allocated €556,938 for HIV. According to the Allocation letter sent by the Global Fund Secretariat to Montenegrin CCM in December 2016 one of the conditions for accessing by the country of the full allocation amount is that “the 2017-2019 allocation amount is dependent on the functionality, in form and substance acceptable to the Global Fund, of a social contracting mechanism for engagement of non-governmental organizations, through which the Montenegro governmental institution(s) and the Global Fund will finance HIV prevention, care and support activities”. “Montenegro’s re-eligibility for Global Fund financing is an opportunity to learn from the dynamic of the epidemic and to catalyze sustainable government funding for key and vulnerable population services, while developing a stable mechanism for operationalizing those funds. We expect that the funding request to the Global Fund will build on this country mechanism”, says Gyongyver Jakab, the Global Fund Portfolio Manager, EECA.

Consequences of termination of Global Fund support in 2015

According to the case study on transition processes in Montenegro (EHRN, 2016), although after the end of the Round 9 HIV grant the government did absorb a significant part of the HIV treatment, diagnostic and OST services, as well as continued to fund general prevention, and also the buffer stock of prevention commodities (e.g. needles and syringes), procured under the Global Fund financed Round 9 grant, enabled the NGOs to continue to some extent service delivery – after June 2015 HIV prevention programs being implemented by NGOs and focused on KAPs have been significantly reduced to a minimum due to the lack of funding. For example, by the middle of 2016 two of three NSPs – in Podgorica and Bar – operated by two local harm reduction focused NGOs CAZAS and Juventas were forcedly closed until the first available funding opportunity.

The only funding to support the prevention services was available at a national level through the Commission on Allocation of Games on Chance Revenue, but it was not sufficient to provide comprehensive services to any of the key affected populations. According to the OSF case study draft on the transition processes in Montenegro (on file with the author) the 2016 disbursements through the National Lottery/Games of Chance Fund covered approximately one-third of what Global Fund had previously contributed for MSM interventions, and one-quarter of the support which had been received for prison-based prevention programs. Programs targeting sex workers received lottery funds for the first time in 2017, but at a rate of only 13% of previous Global Fund funding, says the report. The decrease of funding available also affected the coverage of clients by the prevention services: according to OSF case study draft Juventas experienced almost 50% decrease in reach of unique MSM clients in the first half of 2017, in comparison to the same period in 2015. The need for new sources of funding for HIV prevention programs in Montenegro was evident.

New funding opportunities for HIV prevention in Montenegro and related challenges

According to EHRN case study, as a result of a strong advocacy activity of local civil society representatives and NGOs, Juventas in particular, at the end of 2015 the Parliament of Montenegro adopted the Law on the Budget of Montenegro for 2016, accepting the amendment submitted by the members of a political party Pozitivna. This amendment allowed for the first time the allocation of funds (€100,000) specifically for, ‘non-governmental organizations who provide services for support to people living with HIV/AIDS and affected populations’.

Although this decision was made at the end of 2015 the actual open call for applications for this funding was announced only on the last week of December 2016.  According to Vladan Golubovic, Secretary of the Montenegrin CCM, such delay had multiple reasons – starting with the unstable political situation and elections of the new government at that year, change of 3 Directors in one year of the National Health Insurance Fund which was supposed to become the main source of funding for such support of NGOs activities and also unclarity on the particular funding mechanism and procedures to be used.

Finally, the mechanism and procedures were arranged and agreed between the Ministry of Finance, Ministry of Health, Institute for Public Health and National Health Insurance Fund, as well as the budget rebalanced and it was the Institute for Public Health who announced the call and organized the process. The mechanism used for disbursement of these funds in the equivalent of €100,000 was public tender announced in accordance with the Montenegrin Law on Public Procurement but only NGOs were eligible to apply. The contracts with 3 NGO winners – Juventas, CAZAS and Montenegrin HIV Foundation – were signed at the end of February and the funds were disbursed at the beginning of March 2017. Juventas and CAZAS got funding for provision of institutional support for drop in centers for IDUs and sex workers, and delivery of outreach harm reduction services among IDUs, MSM and Roma population. Montenegro HIV Foundation was responsible for the component of providing psychosocial support to people living with HIV.

Development of the new social contracting mechanism

Although the distribution of the allocated funding to NGOs through the public tender went successfully it became clear that this mechanism for a number of reasons is more applicable for the private sector organizations rather than for NGOs, says Vladan Golubovic. According to Mr. Golubovic, the rough requirements for the application documentation and its volumer, requirement to provide a bank guarantee which was one of the key challenges faced by NGOs within the application process, impossibility to purchase by NGOs the needed medical commodities including syringes and needles – all that evidentiated the need to develop another mechanism, more accessible and low threshold for NGOs taking into account that another 100k were allocated under the Ministry of Health budget for 2017 to support HIV prevention services among KAPs through NGOs. The condition of the Global Fund for accessing by the country of the new funding also played its role in this decision.

In September 2017 a working group was established under the CCM to coordinate the process of development of the sustainable social contracting mechanism. According its ToR (on file with the author) the members of CCM working group are representatives of the following institutions/organizations: Ministry of Health, Institute for Public Health, National Health Insurance Fund and NGOs Juventas and CAZAS. Among the expected deliverables from this group are:

  • defining the needs and scope of services for calls for proposals;
  • developing clear procedures and guidelines on social contracting for provision of HIV services (the package of the 14 documents altogether);
  • conducting a detailed legal assessment and analysis of the environment to support government contracting of NGOs to implement HIV treatment, care and/or prevention activities in Montenegro, and detailed recommendations to address potential barriers; and
  • defining quality standards for service provision; minimal and optimal services and coverage packages; and costs for NGOs to provide the services.

 “It is expected that the working group should complete its work in early November. The results of the working group should be approved by the CCM and adopted by MoH. The mechanism should be put in operation by the end of this year including the contracts to be signed and money to be distributed before the end of December otherwise the funding allocated for these purposes for 2017 could be lost”, – says Ivana Vujovic, the Executive Director of NGO Juventas.

The work of the working group is being supported by the Global Fund through the CCM Funding project. To complete all these tasks the technical assistance is being provided to CCM and the working group: earlier in May this year two NGOs, Juventas and CAZAS, received funding from the Open Society Foundations to support the process of development of this new social contracting mechanism. Juventas is being responsible for managing the development of the rules and procedures of the NGO contracting mechanism including the call for proposals and contracts (on file with the author), and CAZAS is focused on building the capacity of NGOs and government agencies to participate and manage social contracting including the organization of the capacity building workshop, study tour to Estonia to study best practices, etc. The experience of the implementation of the social contracting mechanisms in Croatia is being analyzed and used within this process with the involvement of the relevant Croatian experts. Another part of technical assistance is coming through the UNDP Istanbul Regional Hub in a form of consultant who is responsible for the legal assessment and analysis of the environment to support government contracting of NGOs to provide HIV services. “The positive developments we have been seeing in Montenegro over the last year are a reflection of the extraordinary commitment and collaboration of government and civil society stakeholders in the country. We have been privileged to work in partnership with OSF and UNDP in supporting these ground-breaking efforts”, – says Gyongyver Jakab.

Another recent development related to the work of NGOs in Montenegro is the adoption of the new version of the NGO Law in summer this year. One of the implications of this new version of law is that the funding through the Lottery Fund will not be available for NGOs anymore. According to Mr. Golubovic this mechanism was not very effective as it was functioning on the basic principle that everyone who fulfils the criteria of the call gets a small piece of the funding available. From the experiences of local NGOs, fully requested amounts have never been received by NGOs, it was always not more then 25 – 30 % of the requested amount to be granted. In 2015, approximately 25% of the total planned budget for the NSP was covered by this fund (only fees for outreach workers and other staff, as well as their additional training) which was not enough and required further actions by the relevant decision makers, especially the Ministry of Health (EHRN case study, 2016).

But the key change to be brought by the new law is the decentralized funding of NGOs on the national level which means that now each Ministry could allocate a certain budget to support NGO activities in the priority areas, says Ms. Vujovic. For that purpose, the Ministry should each year make the “sectoral analysis” to identify the priority areas to be covered. According to Vladan Golubovic this analysis should be the main instrument for the Ministries to request the financial support from the Ministry of Finances which makes a decision on the final allocations to each Ministry for the next year. Such decentralization approach was also adopted from the Croatian experience. For the MoH such “sectoral analysis” for HIV\AIDS area was done by the CCM Secretariat this year. “The planned budget for 2018 to support HIV prevention services among KAPs through NGOs is about 300 000 EUR if to matching funds to become available from the Global Fund for that year which is 3 times bigger than in the previous two years. This law also provides more security for a long-term sustainability, as Law on NGOs prescribes that 0,3% of National budget has to be used for funding NGOs’ projects (plus additional 0,1% is dedicated to protecting of people with disabilities, and 0,1% for co-funding EU funded projects)”, – says Ivana Vujovic. The only problem, according to both experts is that this new version of the NGO Law will come fully into a force only starting from 1st of January 2018. So, it is not clear yet if it will be the Ministry of Health to announce the open call for proposals or some other institution. There is an opinion that most likely it cannot be and will not be published by MoH this year.

“This is a great example of multisectoral cooperation in order to ensure the continuation of HIV prevention services for most at risk populations in country”, – says Vladan Golubovic. “All the parties involved – from the Global Fund, OSF, UNDP and CCM to the governmental structures and NGOs – each of them has their specific role. I believe it Is the best way to succeed for such work, you just have to go jointly, you have to go together, find appropriate allies and success is guaranteed”.

“This social contracting mechanism we are developing now – it will allow us to have a sustainable system of NGO funding in place and not to be dependent on any personalities in the government. This should allow NGOs to do their work every year without any interruptions”, – says Ivana Vujovic.

“The Government of Montenegro understands the need to ensure the access for key affected by HIV populations to the prevention services and the important role of NGOs in provision of such services. That is why Ministry of Health is fully supportive to the development of the appropriate social contracting mechanism to become a sustainable and long term solution for ensuring the provision by NGOs of HIV prevention services to KAPs in Montenegro.  Such progress on that matter within a short time became possible also due to the support provided by the Global Fund Secretariat and OSF as well as due to the active involvement of local NGOs into these processes“, – says Nikola Antovic, the Secretary of the Ministry of Health of Montenegro.