The Cabinet of Ministers of Ukraine has approved an updated procedure for interaction between medical institutions and the National Health Service of Ukraine (NHSU). The changes affect three key areas: the procedure for auditing hospitals before signing agreements under the Medical Guarantees Program, the mechanism for returning funds received in excess of the established amount, and the rules for paying for medical services that institutions were unable to include in their 2026 reports. The document enters into force upon its official publication and applies to all levels of medical care covered by the Medical Guarantees Program.
Preliminary audits: when and on what grounds
The main innovation concerns the NHSU's right to conduct audits of medical institutions' readiness to provide care before the contract is signed. To initiate such an audit, an institution must submit separate consent to be audited along with its contract proposal. Audits are not mandatory for everyone: they are conducted in specific cases. First, if during preliminary monitoring, the NHSU identifies a discrepancy in requirements regarding the qualifications of medical personnel or the condition of equipment. Second, a report from a state authority overseeing the institution's activities can be grounds—for example, if the Ministry of Health recorded equipment malfunctions that prevented the hospital from performing services stipulated by the agreement. Institutions submitting a proposal for a specific medical service package for the first time are audited separately. However, lawmakers provided exceptions: new Medical Guarantees Program packages and institutions created as a result of the division of a previously existing medical facility are not subject to preliminary audits.
Repayment of excess funds: five-day deadline and repayment plan
The government has revised the procedure for returning funds that a medical institution received in excess of the amount due under the NHSU contract. If a hospital is unable to return the entire amount within five calendar days, it gains the right to coordinate a phased repayment with the NHSU. For this, the parties sign a fund repayment plan, which fixes the amount, procedure, and payment schedule. This plan becomes an integral part of the contract and remains in effect until the funds are fully returned. Thus, instead of automatic penalties and possible sanctions, a structured mechanism is established, allowing both parties to build a payment schedule.
Payment for 2026 services not included in the December report
A separate block of changes concerns medical care that hospitals actually provided to patients in 2026 but were unable to include in the December report due to exceeding the planned contract value. Now, such institutions will be able to include the corresponding services in the first report under the 2027 contract and receive payment for them. This rule applies to packages for which the NHSU pays for actually treated cases or individual medical services. A cap has been set: the additional payment amount for each institution cannot exceed the average monthly cost of services provided under the relevant package from January to November 2026. This restriction is intended to prevent unjustified inflation of reporting figures.
Reporting and integration with the Licensing Registry
Medical institutions have also been given additional time to submit monthly information on payments and expenses under the Medical Guarantees Program: the reporting deadline has been moved from the 15th to the 25th of the following month. Furthermore, starting August 1, 2027, the NHSU is required to consider data from the Licensing Registry of Medical Practice when working with medical institutions. This requirement does not apply to institutions located in territories of active hostilities where the end dates of such hostilities have not been determined. The totality of these changes is aimed at increasing transparency in the interaction between the insurer and medical organizations, as well as reducing the administrative burden on hospitals while maintaining control over the quality of care provided.
