Civil society organisations (CSOs) and advocates for key population endorse the basic thrust of the new funding model (NFM), but are concerned about several aspects, according to a new report from the International Council of AIDS Service Organisations (ICASO).

The report, entitled “Civil Society and Key Populations: Considerations for the Global Fund’s New Funding Model,” is based on a literature review and several key informant interviews. This article summarises the main concerns expressed in the report.

Concern No. 1 – Blunt measures of “ability to pay” and “disease burden” will disadvantage middle-income countries with concentrated epidemics among key populations and small but growing epidemics.

“By focusing exclusively on national level income and disease information, much about need in a country can be missed – such as concentrated epidemics and pockets of poverty, stigma and discrimination; and human rights violations of key populations,” the report said.

The report said that harm reduction services and programmes for sexual minorities have the highest risk of being cut under the NFM, and that the Global Fund has yet to articulate a strategy for addressing this expected gap.

Concern No. 2 – There is no clear guidance concerning how the country dialogues should be conducted.

“There is no formal policy requiring civil society or key population participation, nor is there guidance on what meaningful involvement looks like,” the report said.

Although most advocates believe that the Global Fund is sincere in wanting key populations to be involved in the country dialogues, the report said, “many questions remain as to how well a vaguely defined process with no strong accountability measures can guarantee meaningful involvement.”

According to the report, it is unclear who is responsible for ensuring the participation of civil society and key populations in the country dialogues, or what the penalties will be imposed if they aren’t involved. “If a country were to outright disregard civil society, or not engage key population advocates in a meaningful way, would funding be withheld or diminished?” the report asks.

Concern No. 3 – Indicative funding amounts may serve as default “ceilings” for proposals, discouraging full expressions of demand.

“This may be a casualty of ‘improved predictability,’ a core principle of the NFM,” the report said.

In addition, the report said, in countries with more generalised epidemics, CSOs are concerned that government-dominated CCMs may relegate key populations to the incentive portions of their funding. (The indicative portions will be larger and more likely to be funded.)

Concern No. 4 – Fund portfolio managers (FPMs), at least initially, may not have the experience or the qualifications to take on the civil society and human rights components of their positions.

“FPMs’ understanding of key population vulnerabilities and civil society organizations, and their sensitivity to human rights concerns, will need to be strengthened,” the report said. “FPMs will need to be held accountable for their performance in these areas.”