Private healthcare providers in Ukraine have called for the establishment of fair and transparent rules for participation in the Medical Guarantees Programme. They are challenging Government Resolution No. 1808, which, in their view, creates discriminatory conditions and funding inequality between public and private healthcare facilities. This could affect the quality and accessibility of healthcare services for patients.
- Private healthcare providers have lodged complaints with the AMCU, the courts and the European Commission over unfair conditions in the Public Healthcare System.
- Cabinet of Ministers Resolution No. 1808 introduced discriminatory coefficients and limits for private laboratories.
- Sinevo and CSD LAB have raised concerns about a lack of transparency in funding and lower reimbursements.
- Around 700 private healthcare providers operate in the PMG, treating hundreds of thousands of patients.
- The lack of a level playing field threatens patients’ access to high-quality, free diagnostic services.
The issue of unequal conditions for private healthcare facilities in the PMG
Private healthcare providers, including the laboratories Sinevo Ukraine and CSD LAB, have lodged a complaint with the Antimonopoly Committee of Ukraine, filed an administrative claim with the Kyiv District Court, and appealed to the European Commissioner regarding Cabinet of Ministers Resolution No. 1808 of 31 December 2025. This resolution, which governs the implementation of the Medical Guarantees Programme in 2026, establishes, in the applicants’ view, non-competitive and discriminatory rules for private healthcare providers.
Lawyer Serhiy Dzis stressed that these are systemic issues that prevent private healthcare facilities from operating on an equal footing with their public counterparts. He emphasised that this issue affects every patient, doctor and private laboratory, all of whom are entitled to high-quality treatment and the freedom to choose where they receive care.
Financial challenges and a lack of transparency regarding compensation
Deputy Managing Director of Sinevo Mykola Skavronsky reported that since the start of 2024, their network had treated around 1.6 million patients and carried out over 8 million tests, amounting to more than 1.8 billion hryvnias. However, the National Health Service of Ukraine reimbursed only around 250 million hryvnias; the company covered the rest of the costs itself so that patients would not suffer any negative consequences.
He emphasised that Resolution No. 1808 effectively stipulates that only patients who seek treatment at state or municipal facilities are guaranteed full reimbursement, which runs counter to the principle of “funds following the patient” and creates inequality between different forms of ownership of healthcare facilities.
Reduction factors and service volume limits
From 2025, the National Health Service of Ukraine (NSZU) has introduced a reduction factor of 0.6 for laboratories that have increased their service volumes by more than 80% compared to the base period. This creates an incentive to restrict patients’ access to diagnostics. Sinevo could perform 10–15 times more tests under the PMG scheme than the limits allow, as these limits do not apply to state-run institutions.
Representatives of private laboratories have also criticised the retroactive nature of the changes: the compensation rates and conditions were altered after the contracts had been signed, without consulting the providers and without any public consultation. This breaches the terms of the contracts and legal requirements.
The Position of the Association of Private Healthcare Facilities of Ukraine
Chair of the association Sergei But noted that around 700 private healthcare providers are participating in the PMG and provide medical care to hundreds of thousands of patients across the country. In 2025, 23 million Ukrainians used the services of the Primary Healthcare System.
He emphasised that the healthcare system must operate in the patient’s best interests, ensuring freedom of choice and high-quality services. Experience in Europe shows that the best results are achieved in countries where the public and private sectors operate on an equal footing.
Medical experts on discriminatory regulations
Medical Director of CSD LAB Oksana Sulaeva She described the provisions of Resolution 1808 as discriminatory and unfounded. She pointed out that the new coefficients had been introduced without any technical or economic justification, and that changing the rules after the contract had expired breached the contractual terms.
According to her, this approach contravenes the law and creates inequality between public and private healthcare facilities.
Implications for patients and the healthcare system
The involvement of private laboratories in the PMG scheme has enabled patients to access free and convenient diagnostic services, which were previously available either at their own expense or through state-run facilities, where they faced long waiting lists and delays. A reduction in the number of private participants in the programme will lead to a deterioration in access to high-quality services.
The lack of transparent and fair rules could deprive millions of Ukrainians of the opportunity to choose where to undergo diagnostic tests, and lead to a decline in the quality of healthcare.
The private sector is calling for a systematic solution to the problem, as only consistent, stable and transparent conditions will enable it to remain a genuine partner to the state in healthcare reform.
