Following the CCM TB/AIDS extraordinary meeting held on June 29, 2017 and the decisions adopted during the meeting, a group of 6 NGOs, CCM members, initiated an active campaign of: 1) contesting the CCM procedures, 3) unilateral misinformation of public opinion, the donor (GF), the development partners, and 4) manipulation of civil society organizations represented in CCM, thus discrediting and intimidating those who do not support their position.
Based on all messages, positions papers, letters sent to CCM members, the Global Fund (GF), development partners – bearing a clearly negative character, as well as unilaterally positioned articles published by www.e-sanatate.md – we would like to present the following clarifications:
Contextual, procedural and process related considerations:
1. The TB and HIV grant-making stage was organized within the framework of a country
dialogue – inclusive, multisectorial and transparent – appreciated by all CCM stakeholders groups and monitored by the GF. The six NGOs signing the letter have attended plenipotentiary all meetings, discussions and debates held in the CCM working groups dedicated to grant making. Being aware of the financial limitations of the grant to be provided by the GF for the continuation of the HIV program in 2018-2020, the six NGOs found consensus on most of the activities and budget lines part of the grant, including the need to adjust / decrease the budget for costs directly related to the treatment, support and care services. The exception was made by the grant management costs, for which the government sector proposed a 7% share of the grant, while one of the two Principal Recipients (RP), the PAS Center, insisted on 14%. It is worth mentioning, that the PAS Center retains its PR status for the implementation of the TB grant, where the Working Group responsible for the grant making has reached consensus on all budget lines.
2. The participatory dialogue and compromise search continued until 28/06/17, when the
parties met in two sessions. Those meetings, however, were not conclusive.
3. In this situation, the Coordinating team of the National HIV Program (PHN) informed the
CCM members about the impasse and presented for the CCM consideration 3 solutions: a) 7%; b) 14%; or c) optimization of management costs and implementation of the HIV grant by one RP- PI CIMU HRP/IP UCIMP DS (which complied with the 7% limit), yet maintaining all current sub-recipients.
4. Taking into account the need to prepare the country for the unavoidable transition from
the GF to the state budget funding, and understanding of the need to consolidate the capacities of the state, which will have to take over all costs and program management at the end of the GF funding, the CCM voted for cost optimization and implementation of the grant by the PR IP UCIMP DS – public institution.
5. Questioning the competences of the PR UCIMP – is neither a justified nor a right approach.
Its competence and professionalism have been confirmed by both the donor and the LFA (Local Agent of the FG) – PricewaterhouseCoopers, including the ratings granted for the implementation of TB & HIV grants — B +, A, A +, over the years 2003-1017.
6. The Republic of Moldova has followed for many years (since 2008) the FG
recommendation to apply the dual-track funding mechanism (a recommendation, not a requirement) – with a governmental PR + a non-governmental RP. In the context of the transition to local funding – the optimization approved by the CCM is justified. This action to optimize administrative costs – does not imply, in any way, a change in the grant implementation mechanism (wrongly invoked by the group of 6 NGOs), but an optimization of grants. This optimization is specified by the FG application procedure for the continuation of grants (see Application Instructions: p.5)
7. Furthermore, the participation of the GF Portfolio Manager for the Republic of Moldova
at the CCM meeting in March, this year, the explanations provided on procedures and the request for the development, at the grant making stage, of a Program management Transition Plan from the GF implementing entities to the state, confirms this. The same approach was reiterated by the GF Regional Manager for EEAC at its meetings with the CCM Chair in May and June this year. Both, the donor and the government sector, represented in the CCM, expected a mature attitude and a smooth transmission of these functions and capacities, developed and sustained over the years by the CCM from GF sources. Even more unfortunate is the attitude shown by some NGOs with reference to this topic.
8. At the same time, the letter of the GF Portfolio Manager for Moldova, dated March 1,
2017, addressed to all CCM members, expressly states that “in order to be able to apply for Program Continuation, it is not obligatory to keep the implementation arrangements the same.” This very letter reiterates the position of GF “raised on many occasions: in the context of (a) decreasing funding; (b) Program Continuation request, which should reflect the strategies of the transition plan; (c) the recent MOU with UNDP on State procurement of ARVs; (d) the Global Fund’s new requirement on progressively increased share of the state funding in preventive programs, and hence, inclusion of the new state actors/implementers into the program, it is critical that the implementation arrangements are reconsidered in order to establish more cost-effective and forward looking implementation mechanisms. We expect that the Program Continuation request will provide the Global Fund Secretariat with clear understanding on how the Program Management transition from the GF implementing entities to the State HIV and TB Program Coordinating entities, and other potential state players will be implemented.”
9. At the CCM meeting on June 29, the draft Plan for the Transition of Program Management
/ PR-Ship capacities presented by the coordination team of the NHP was not challenged, amended or complemented by any of the CCM members. Moreover, this plan is NOT a new one. It is part of the National programmatic transition plan adopted by the CCM on March 15. The PHN Coordination Team would not have presented a draft plan without having been consulted in advance.
10. The equal, assumed and transparent involvement of each of the 6 NGOs – at all stages of
the development of the program continuation funding request for 2018-2020, and later in the grant-making process, does not justify, in any way, allegations of lack of transparency, marginalization of civil society, or exclusion from the decision-making process.
11. In order to avoid such situations and to ensure procedures appropriate to the current day,
but also with a future vision on CCM development and integration, all the CCM constituent groups are invited to actively participate in the CCM integration process, including the updating of the governing documents, initiated with the support of Euro Health Group experts, as part of the international TA project for CCMs (supported by the German Agency for International Development (GIZ)).
12. Organization of the extraordinary CCM meeting on June 29, 2017:
• It was convened by the CCM Chair – because the Working Group responsible for the development of the program continuation request and the grant-making could not reach consensus on the administrative costs (the organization of Extraordinary meetings procedure is described in the CCM governing documents);
• The Extraordinary meeting and its agenda were announced 1 week before the meeting (Procedure described by CCM governing documents);
• The meeting, the deliberations and the voting procedure were ensured by the quorum of 2/3 CCM members – with the participation of 28 members with the right to vote;
• The updated CCM membership list – which has not changed since the previous meeting – otherwise, those changes would had been announced at the 29/06 meeting – is published on the CCM website. The list of CCM members appears transparently set out in the CCM invitation message sent by the Secretariat on June 23 and 28, 2017.
• CCM members who could not be present at the meeting – nominated another person entitled to vote – as reiterated in written form by the CCM Secretariat before the meeting, and according to the procedure described in the CCM’s governing documents. Before the meeting, this was communicated electronically and by phone by the following CCM members:
Igor Chilcevschi (League of PLWH)
Ala Iatco (UORN)
Victor Ursu (SOROS Moldova Foundation)
Viorel Soltan (PAS Center)
Due to the overlapping of several activities on the deputy-ministers’ agenda – the Ministry of Labor, Social Protection and Family was represented by Djulieta Popescu (member of the WG responsible for the program continuation request and grant-making, Ministry of Internal Affairs – by Sandu Nicolae (head of the Medical Department of the Ministry) and the CCM member from the ATU Gagauzia – by Iurie Bucinschi (head of the WG responsible for the program continuation request and grant-making; head of the Public Health Programs Department in the Ministry of Health and former CCM vice-chair on behalf of the State Chancellery). They have announced by telephone and in writing the Minister of Health team and the CCM Secretariat about the person who will represent them with the right to vote.
• The voting procedure, specified in the CCM activity documents, requires the presence of 2/3 of the members with equal voting rights – ensured at the meeting of 29/06. Each member (except for the two PRs) had the equal right to vote pro, against, or to abstain from voting. The CCM members did not challenge the counted and publicly announced votes during the meeting.
• Conflict of Interest Policy (CoI): The participation of CCM members in the decision-making process implies their responsibility to know and comply with this document adopted by the CCM (see p.1.1 of the Conflict of Interest Policy).
• At all previous CCM meetings, members in conflict of interest used to declare the conflict, that being documented and reflected in the meeting minutes (see minutes of the CCM meetings published on the CCM website http://www.ccm.md/minute.
• Although the CoI Policy does not invoke the responsibility of the Secretariat to explain / interpret the document at each meeting, however, in order to avoid interpretations, and taking into account the sensitivity of topics subject to discussion and voting, the CCM Secretariat outlined the express provisions of the CoI policy, and called on CCM members to assume responsibility for the vote and decision.
• The minutes of the CCM meeting are not a “transcript”, aka “stenogram” – but an objective summary of the discussions, positions and decisions. After the CCM meetings, the Secretariat elaborates and consults the draft minutes – not the transcript! Likewise, this was equally respected in the case of the CCM meeting of 29/06/17. At the request of the 6 NGOs, the record of the meeting will be made public by the CCM Secretariat for access to all members.
13. The CCM TB/AIDS of the Republic of Moldova has always been an example of equal and multi-sectorial involvement with a constructive civil society, guided by the priority interests of people affected by TB and HIV. The arguments put forward, the attitude and approach of the 6 NGOs, after the decisions were taken at the CCM meeting of 29/06 – denote a struggle for resources on the beneficiaries’ account.
14. In the petitions, intimations, and publications made by the six NGOs, no reference is made to the priority interest of the beneficiary. Moreover, they are not even based on pertinent assessments and evidence of the risks invoked, but merely the insistence on some costs that are inadmissible for austerity budget, and which could not be taken over by the state, and populist affirmations that target – the veiled interest for administration costs.
15. It is important to note that the position of the six NGOs is not supported by the entire community of affected people. The member organizations of the Public Association “old.positive Initiative” have already publicly disagreed with the position of the 6 NGOs, calling for maturity of the partners and participation in the processes related to the approval and implementation of the grant.
16. The current situation has caused a split among members of the civil society and a discrediting of the common goal – a truly regrettable thing that must be assumed by those who have provoked, interestedly, this split.
In the context of the above, we want to ensure the affected populations that all activities agreed in the working group and submitted for the approval of the GF Secretariat will be implemented making a transparent and efficient use of the funding.
We also call upon civil society, in which the donor has invested capacity building and the affected populations have invested a mandate of representation and advocacy to ensure comprehensive services, to show maturity, collaboration, engagement and participation in the interest of those who need now support and help, and to not fall victim to tight games of interest.
• Negotiation and signing of the HIV grant with the Global Fund – August;
• Establishment of a contracting mechanism for prevention and support services in a broad format, involving everyone in several workshops – September;
• Tender launch for grants – November.
For the efficient implementation of the grant, we will maintain the open, transparent and participative format of the national dialogue, aiming at providing efficient services to those who need them.
CCM TB/AIDS CHAIR