Montenegro’s Healthcare System Struggles with Anti-Corruption Measures

The healthcare system in Montenegro is facing significant challenges in effectively implementing anti-corruption measures. According to a report titled “Integrity in Action – Assessment of Anti-Corruption Measures in Healthcare,” compiled by the Agency for Prevention of Corruption, the overall effectiveness of the institutions analyzed stands at only 47.85%. This indicates that more than half of the required measures are either not fully implemented or are applied merely at a procedural level, lacking measurable outcomes.

The assessment included 30 healthcare institutions that provided necessary data, while seven institutions failed to participate, not responding to requests from the agency. The report utilized a combination of self-assessments, documentation checks, and analyses of publicly available information, revealing stark discrepancies between stated policies and actual practices in preventing corruption.

Plans Exist, but Implementation Lags

The report highlights that healthcare institutions achieve the highest compliance in establishing an institutional framework for combating corruption. Almost all institutions analyzed have adopted integrity plans, appointed integrity managers, and defined formal procedures for reporting irregularities. This segment demonstrates the highest average performance within the system.

Nevertheless, the report notes that the effects of these measures often remain limited to administrative compliance. In practice, integrity plans are seldom utilized as active documents for risk management, with the activities of integrity managers primarily reduced to formal reporting. Among the best-performing institutions in terms of criteria fulfillment are the health centers in Berane and Bijelo Polje, both achieving 68.82%, followed by the health center in Andrijevica with 67.65%, and the Medicines and Medical Devices Institute at 65.13%. Despite these figures, none of these institutions fully met all criteria, categorizing them as having moderate performance.

Transparency Issues Remain Pervasive

A glaring gap exists between regulations and practices, particularly concerning transparency and access to information. The report indicates that a significant number of healthcare institutions do not publish complete and up-to-date data concerning budgets, public procurements, contracts, employment, and staff structure, despite legal obligations to do so.

The report emphasizes the issue of selective responses to requests for access to information. In some cases, responses are delayed, incomplete, or requests are not properly recorded. Specific deficiencies have been identified in institutions such as the Emergency Medical Services of Montenegro, the Health Insurance Fund, Montefarma, and the Medical Chamber of Montenegro. Similar weaknesses have also been noted in health centers and general hospitals with lower overall performance.

The Agency asserts that the lack of transparency is a critical factor that enables the emergence of corruption risks, as effective public oversight cannot exist without complete access to information.

Another area of concern is the internal control mechanisms within the healthcare system. The report reveals that the weakest performance is noted in internal control and auditing, which is essential for early detection of irregularities. Internal audits have been established in only five healthcare institutions, while others either lack this mechanism or have it non-operational. As a result, many institutions lose significant points in this area, despite partial achievements in others.

The report further highlights that without functional internal controls, there cannot be a realistic assessment of risks, nor the ability to identify problems before they escalate into serious abuses.

Ethical Culture and Accountability Lacking

In terms of ethical culture, most institutions have adopted ethical codes and established quality control committees. However, the report indicates that these bodies are rarely utilized as active mechanisms for preventing corruption. Their operations are poorly documented, and their influence on daily decision-making among employees is limited.

Particular issues arise regarding conflicts of interest, reporting of gifts, and additional employment engagements. The rules in these areas are either insufficiently precise or inconsistently applied, creating opportunities for non-transparent decisions, especially in institutions with the lowest overall results, such as the Health Center in Rožaje, the Emergency Medical Services of Montenegro, and the Medical Chamber.

The report also highlights that seven healthcare institutions did not provide any data for evaluation, including the Clinical Hospital Center in Kotor and health centers in Budva, Kotor, Niksic, Plav, and Tivat. The Agency notes that this lack of response to legal requests indicates a low level of institutional accountability and hampers any assessment of the actual level of corruption risk within these institutions.

Critical Areas for Improvement Identified

The report dedicates special attention to public procurement and employment, recognized internationally as high-risk areas for corruption in the healthcare sector. Although the regulatory framework in Montenegro is relatively clear, the analysis reveals that the application of rules in these segments is inconsistent and often non-transparent.

In public procurement, the Agency observes that many healthcare institutions fail to publish complete information about procurement procedures, concluded contracts, and their implementation. In some instances, data is fragmented, difficult to access, or not updated, which hinders transparency regarding the expenditure of public funds. The report specifically notes that procurement plans are often published formally but lack clear monitoring of their execution, while modifications to these plans are insufficiently justified.

Additionally, the majority of institutions lack established internal control mechanisms over procurement processes, further increasing the risk of irregularities. The absence of internal audits, identified as a systemic problem, means that procurement oversight frequently reduces to formal documentation checks without substantial evaluations of cost justification and economic efficiency.

The report also assesses employment practices as equally risky, pointing out that many institutions do not maintain fully transparent hiring procedures or clearly published criteria for candidate selection. Notable issues arise in the hiring process based on contracts for specific jobs, temporary and occasional employment, and additional employee engagements, where rules are not always precisely defined or consistently applied.

The Agency warns that overlaps with conflict of interest issues are common, as institutions often lack clear procedures for reporting and verifying potential connections between candidates and decision-makers. The lack of transparency in hiring practices exacerbates problems in institutions that already exhibit low overall performance in implementing anti-corruption measures, indicating a cumulative effect of poor integrity management.

The report concludes that public procurement and employment are areas where formal compliance often fails to translate into genuine oversight. Without enhancing transparency, internal monitoring, and accountability among leaders, these segments will remain the most vulnerable parts of Montenegro’s healthcare system.

Based on all findings, a total of 717 recommendations have been issued to healthcare institutions aimed at improving transparency, strengthening internal controls, clearly defining ethical guidelines, and providing additional employee training. The report concludes that the key issue lies not in the lack of a regulatory framework but rather in its selective and formal application, leaving the fight against corruption in healthcare incomplete.