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A Global Fund regional program amid the war in Eastern Europe
GFO Issue 414

A Global Fund regional program amid the war in Eastern Europe



Article Type:

Article Number: 7

Can we still achieve results if we ignore the grim realities? Is the Secretariat ignoring the non-government organization rule approved by the Board?

ABSTRACT This article investigates the operational realities of the implementation of a Global Fund multicountry grant in the Eastern Europe and Central Asia region, during the war in Ukraine. The multicountry grant includes funding for the Russian Federation and Ukraine


At its 47th meeting, the Global Fund Board approved the catalytic funding stream for the next funding cycle. This funding stream is addition to the country grants and is usually described as funding for interventions that cannot be covered by the regular country grants (e.g., human rights-related initiatives addressing restrictive legal environments) endorsed by the Country Coordinating Mechanisms (CCMs). They have the potential to unlock additional funds (for example, advocacy grants might encourage other donors to invest, promoting a sustainable response to three diseases) and have been supported by the Global Fund for some years now.

Accountability and transparency have become even more important given the ongoing conflict

These grants should also be subject to the Global Fund’s transparency principles; however, it is not an easy task to find details on multicountry grants on the Global Fund’s data portal, including data on the approved funding, Principal Recipients (PRs), and core programmatic areas.

For example, our team went to the Data Explorer webpage to look for details on the regional grant in the Eastern Europe and Central Asia (EECA) region. The Global Fund previously approved funding for a multicountry grant in the EECA, the “Sustainability of services for key populations in the EECA region” (SOS) program led by the Ukrainian Alliance for Public Health (APH). The grant was approved in 2021. However, it is still not available for view on the Data Explorer.

While the update of the web page is pending approval of the PR’s reports, as confirmed by the Secretariat, this is not a reason that justifies the absence of basic information on the Data Portal on approved program funding, its goals, objectives and implementing partners ¾ data that should have been made available soon after the grant was approved. The Secretariat confirmed that “APH recently submitted its progress update for 2021 reflecting the grant program’s solid performance over the first period of implementation. These results will be reflected in the Data Explorer once validated by the Global Fund Secretariat.” Hopefully, therefore, these data will be provided sooner rather than later: especially given that we will soon be into the second half of 2022.

Since the grant was approved in 2021, this region has become heavily affected by the war between Russia and Ukraine, forcing millions of people (including those living with HIV and TB) to flee their homes. This has given rise to influxes of displaced people and a humanitarian crisis in Europe on a scale not seen since the Second Word War, affecting not just Ukraine but its surrounding countries that are having to deal with migrants fleeing Ukraine. Furthermore, this significant conflict in EECA, affecting not just the entire region but also the world, has impacted the implementation of the regional program.

The EECA multicountry grant

APH continues to lead a consortium of 20 civil society organizations across the region, including 100% Life (All-Ukrainian Network of PLWH), the Central Asian HIV Association and the Eurasian Key Populations Health Network. The consortium collaborates with national government and non-governmental organizations (NGOs), regional key population networks, international agencies, and technical partners.

The SOS program was designed with three broad goals in mind:

  1. Institutionalizing effective HIV response models and processes to impact the HIV care cascade.
  2. Removing barriers to services for key populations to promote quality health interventions based on human rights principles and address gender barriers.
  3. Budget advocacy for sustainable services for key populations.

Activities are planned and/or underway in 15 countries in Eastern and South-eastern Europe and Central Asia (Albania, Armenia, Azerbaijan, Belarus, Bosnia and Herzegovina, Georgia, Kazakhstan, Kyrgyzstan, Moldova, Montenegro, North Macedonia, Serbia, Ukraine, Uzbekistan, and Tajikistan).

The NGO Rule regarding eligibility

The regional multicountry grant has a program component that supports civil society organizations (CSOs) and key and vulnerable populations (KVPs) in the Russian Federation. This program component was approved on basis of the NGO rule following considerable advocacy to the Board to support people living with HI (PLHIV) and affected communities in the Russian Federation.

The Global Fund’s ‘Policy on Eligibility Criteria, Counterpart Financing Requirements, and Prioritization of Proposals’, otherwise known as the Global Fund Eligibility Policy, allows NGOs from Upper Middle Income Countries (UMIC) not listed on the Organization for Economic Co-operation and Development’s Development Assistance Committee (OECD-DAC) list of overseas development aid (ODA) recipients to apply for HIV/AIDS funding. It is otherwise known as the NGO Rule. The rule states that such NGOs are eligible to receive an allocation for HIV and AIDS funding only if they have a reported disease burden of ‘High’, ‘Severe’ or ‘Extreme’ and are eligible to apply for such funds only if the following conditions are met:

  1. Confirmation that the allocation will be used to fund interventions that are not being provided due to political barriers and are supported by the country’s epidemiology.
  2. Confirmation that: (i) the application will be submitted by a non-CCM or other multi- stakeholder coordinating body; and (ii) the program will be managed by a non- governmental organization (NGO) within the country in which activities would be implemented.
  3. The government of such country shall not directly receive any funding; and
  4. Applicants meet all other applicable requirements as set forth in the Sustainability, Transition and Co-financing Policy, as amended from time to time.

It is no secret that the PLHIV, KVPs, and communities live in a repressive environment in the Russian Federation. The situation has deteriorated further with the introduction of the “foreign agent law” that requires CSOs and individuals in the Russian Federation receiving donations from abroad to register and declare themselves as “foreign agents.”

Sanctions mean that the Global Fund has ceased to fund CSOs in the Russian Federation when they are most in need

The Global Fund’s support, even throughout the small funding available through the regional grant, is precious ¾ representing one of the last funding options available to PLHIV and communities in the Russian Federation. However, we were informed by the Global Fund Secretariat that this funding support is no longer available. The Secretariat stated that: “The Global Fund is not at present able to disburse funds through sanctioned Russian banks. Russian implementers are constrained from cooperating with partners in Ukraine and elsewhere in the region. UNAIDS, the Global Fund-supported program’s main provider of technical support has closed its Russia office. Inevitably, these factors have had a negative impact on the ability of affected communities to implement needed programs.”

While we recognize the difficulties in transferring the funds, we need to consider that the Global Fund has programs in place in other countries under sanctions (such as the Democratic People’s Republic of Korea, Iran, and Venezuela). These programs were/are being implemented with the support of UN partners, including the Pan-American Health Organization (the Latin American arm of the World Health Organization), the United Nations Development Programme, and the United Nations Children’s Fund. Have these options been considered in the case of supporting communities in the Russian Federation? If that was not the case, why has the Secretariat opted out of continuing to execute the Board’s approved decision on funding support for KVPs and PLHIV, who lack any other type of support, in a country with the largest HIV epidemic in the region? Iit should be noted that the Joint United Nations Programme UNAIDS regional office still has some team members working in the Moscow office.

Responding to the war in Ukraine, the Global Fund reacted within its mission and approved the Emergency Funding support, aiming to provide continuity of ARV and TB treatment to the people of Ukraine, including the internally displaced, and refugees fleeing to Moldova and other neighboring countries whose health systems are not able to sustain this pressure.  Additionally, the Secretariat must make sure that multicountry grants can operate under new circumstances and deliver its planned results.  Working in a challenging operating environment setting, as Ukraine is right now, presents a set of new challenges to organizations receiving and further distributing the GF’s funding across the region.  The banks in the country are also functioning under a constrained environment, which led the GF’s Secretariat to take over a part of the administrative work from the PR.  Secretariat informed us that “The consortium led by APH quickly adapted the SoS program, implementing a business continuity plan that saw a partial relocation of staff and office from Kyiv to L’viv while maintaining its presence throughout Ukraine and expanding access to service delivery siCAtes – now focused on risk groups among an unprecedented number of refugees – across the region. Alternate implementation and payment flows were arranged with the Global Fund to ensure that program activities could be maintained (and expanded as necessary) in Ukraine and the other countries in which grant implementers were operating.  To date, the Global Fund has released five tranches of funds to support ongoing grant implementation.”  While this is a commendable act of solidarity, there is a huge risk of program implementation delays, disruptions and cost increase at the TGF’s Secretariat that should be captured with the TGF Risk register, with the mitigation measures.

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