I am writing to request your urgent intervention in matters concerning the governance, accountability, transparency, and effective utilization of Global Fund resources in Nepal, particularly the HIV prevention and treatment programmes serving men who have sex with men (MSM), third-gender/transgender (TG), sex workers, people who inject drugs, people living with HIV, and people in prisons and other closed settings.
These concerns are not simply about which organization should serve as Principal Recipient (PR). They concern Nepal's national sovereignty over its public health response, the responsible use of international public-health funding, the accountability of institutions entrusted with those funds, and the risk that vulnerable communities will lose essential services while administrative decisions are delayed or disputed.
I respectfully request a formal, time-bound review by the Ministry of Health and Population, supported by NCASC and the appropriate government oversight bodies, with written explanations and documentary evidence sought from the Global Fund, UNDP, CCM Nepal, and Save the Children International.
1. Principal Recipient Selection: Transparency, National Ownership, and Due Process
Publicly available Global Fund data confirms that UNDP assumed a Principal Recipient role in Nepal's Global Fund programme for the implementation cycle. UNDP's published project details describe a multi-year budget exceeding US$40 million across components.
However, serious questions remain concerning the process by which the PR arrangement was decided and whether all relevant national procedures and decisions were respected.
I request clarification on the following:
What was the original CCM decision concerning the nomination of candidate entities like UNOPS, UNDP, or other potential Principal Recipients? Please provide the signed resolution, minutes, voting record, and any documented assessment of the candidates.
What precisely happened after Save the Children raised its complaint and the CCM requested that the Global Fund determine or intervene in the PR arrangement?
What legal, policy, or procedural authority did the Global Fund rely upon when determining or approving UNDP's appointment? Was this a decision made under the ordinary CCM nomination process or an exceptional directive?
Was a transparent comparative assessment of UNOPS, UNDP, the Government of Nepal, and other eligible entities undertaken? If so, please release the assessment criteria, findings, and decision rationale.
What is the documented position of the Government of Nepal regarding UNDP serving as PR, and what formal response has the Global Fund provided?
If the Government proposed to assume the PR role (under NCASC/MoHP), what specific conditions, pre-grant assessments, and safeguard policies were demanded by the Global Fund? Why were these safeguards applied to the government, and how do they compare with the requirements applied to UN agencies like UNDP?
The Global Fund's guidelines assign CCMs the primary responsibility for nominating PRs and overseeing grant implementation. Global Fund and UN policies also emphasize that international interim PR arrangements should build national capacity for direct implementation by government or local entities.
I request that the Ministry obtain all relevant written decisions and ensure that current and future PR arrangements align with Global Fund governance policies, Nepal's national sovereignty in health, and transparent, documented decision-making.
2. Performance Assessment, Oversight Findings, and Proposed Grant Cycle 8 (GC8) Arrangements
Concrete findings from the CCM Nepal Oversight Committee's site visits and compliance reviews raise severe concerns regarding UNDP’s performance as a PR:
Zero Progress in Closed Settings: Official oversight reviews recorded zero progress on critical grant indicators, including HIV and TB screening in prisons, representing a major failure to deliver for vulnerable key populations.
Withholding of Critical Audit Data (PUDRs): The Oversight Committee documented that UNDP failed to invite committee members to official Progress Update and Disbursement Request (PUDR) debriefings conducted with the Global Fund’s Local Fund Agent (LFA) and routinely delayed or withheld vital management letters, staff qualification registers, and compliance evaluations.
Sub-Recipient (SR) Management Bottlenecks: Delays in issuing compliance evaluations and management letters for SRs disrupted communication channels, hampering community-level risk assessments and implementation.
Discrepancy in Performance Ratings: Despite documented performance deficiencies and a low compliance score (reported as a "D" rating) on the CCM Oversight scorecard, the Global Fund Secretariat has continued to qualify and endorse UNDP for PR roles into upcoming grant cycles.
Please request the following from CCM Nepal and the Global Fund:
The complete signed oversight assessments of UNDP, including rating scales, period assessed, financial management findings, procurement performance, and documented operational bottlenecks.
All corrective-action plans, compliance deadlines, follow-up assessments, and records demonstrating whether required operational improvements were fulfilled.
The Global Fund's written assessment of UNDP's performance and the specific reasons for any discrepancy between the CCM Oversight Committee's findings and the Global Fund Secretariat’s funding decisions.
The explicit criteria used to assess UNDP's eligibility for Grant Cycle 8 (GC8), including how past performance, national capacity transfer, and direct national ownership options were evaluated.
3. Dual HIV–Syphilis Test-Kit Procurement: Urgent Independent Verification
Reports published in health media outlets (such as Swasthya Live) have raised severe allegations regarding UNDP's procurement of approximately 900,000 dual HIV–syphilis test kits valued at upwards of NPR 1.2 billion, alleging non-alignment with national diagnostic algorithms, issues with NCASC supply chain integration, lack of MoHP consultation, and the risk of mass expiration.
These serious claims demand an independent technical, supply-chain, and financial audit. It is vital to establish the exact factual record before assessing institutional financial liability.
I request that the Ministry obtain:
The procurement request, needs assessment, technical specifications, tender process, vendor contracts, unit pricing, and total procurement outlay.
Official approvals obtained from UNDP, the Global Fund, NCASC, and the Department of Health Services (DoHS).
Technical clearance demonstrating whether the procured dual test kits matched Nepal's national HIV/STI testing guidelines and obtained necessary regulatory clearances from the Department of Drug Administration (DDA).
Detailed inventory logs showing delivered quantities, accepted batches, rejected shipments, distributed stock, current warehouse balances, and expired quantities (including batch numbers and expiration dates).
Financial reconciliations detailing any refunds, supplier liability claims, credit notes, insurance coverage, or written-off losses associated with expired or unusable stock.
An independent determination of administrative responsibility if financial or public health waste is substantiated.
Immediate steps must be taken to clarify the current stock status, salvage usable diagnostic kits, and prevent future supply-chain misalignments.
4. Direct Challenge on National Leadership, Administrative Costs, and Comparative Unit Costs
After more than 20 years of Global Fund support in Nepal, serious systemic questions must be asked regarding national health leadership and institutional reliance on external bodies:
Why is the Government not yet 100% PR, not even 50%? After two decades of capacity-building investments, why does the Global Fund continue to bypass or restrict the Government of Nepal from full PR status while continually endorsing high-cost UN agencies (like UNDP) and INGOs through the CCM?
Comparative Unit Cost & Salary Analysis: What is the exact unit cost difference between running grant administration through the Government versus through UNDP or INGOs? The Ministry must demand full financial disaggregation from the Global Fund showing:
Corporate Overhead & Management Fees: General Management Support (GMS) fees (typically 7–8% deducted off the top) alongside Direct Project Support Costs (DPC) and procurement transaction fees absorbed by UNDP and international PRs/SRs.
International Staff Expenditure Structure: Total budgeted costs for foreign personnel and advisors under international pay scales (ICSC). Reports indicate total monthly cost packages for senior foreign personnel reach approximately NPR 30 lakh per month per person (~US$ 22,000/month) when factoring base salary, post-adjustments, hardship allowances, rental subsidies, pension contributions, insurance, education grants, and duty post overheads. A single such international position costs the equivalent of 35 to 40 senior Nepali health officers combined.
National Project Payroll Disparities: High national personnel payrolls under PR, SR, and SSR project units (where senior national project staff receive NPR 2.5 lakh to 5 lakh per month), creating vast distortions compared to civil service rates.
Value-for-Money Disparity: A direct comparative analysis demonstrating how much more funding would reach frontline key populations, local clinics, and community outreach workers if management overheads were minimized through direct government PR execution.
Demand for Integration & Government Ownership: When will the Ministry of Health and Population take a decisive stand, assert full national ownership, and integrate HIV, Tuberculosis, and Malaria programming into the core national health system? Why does the Government remain a silent spectator while external entities drive national health priorities and absorb significant management funds?
Nepal's public health system cannot remain permanently reliant on intermediary institutions. The Government must demand transparency, demonstrate readiness, and take full stewardship of these national health programmes.
5. Remaining Grant Balances (GC6/GC7) and Immediate Bridge Funding for Affected Communities
A critical concern facing key population networks is the transition of funds from prior grant structures (including GC6 grant funds handed over from Save the Children to UNDP) and the availability of unspent balances.
The current available budget data does not clarify what unspent funds remain legally and operationally available to prevent service disruptions prior to full GC8 implementation.
I request a reconciled financial statement from Save the Children, UNDP, and the Global Fund showing:
The final closed/audited budgets of preceding grants and exact funds transferred between PRs.
The exact cash balances currently held, committed purchase orders, unpaid vendor invoices, and reprogrammable surplus funds.
Funding specifically designated for services targeting MSM/TG, sex workers, and prisoners.
The exact administrative procedure and timeline required to release reprogrammed funds directly to civil society service providers.
Immediate Bridge Plan:
The Ministry must urgently convene NCASC, CCM Nepal, UNDP, Save the Children, and community networks to establish a time-bound bridge plan. Administrative disputes between agencies must not lead to stockouts or interruptions in essential health commodities, community outreach, and antiretroviral therapy (ART) linkages.
6. CCM Governance: Term Limits, Donor Representation, and Secretariat Accountability
The CCM Nepal Rules of Business define clear parameters for membership, representation, and term limits (members serve defined terms, typically eligible for a maximum of two consecutive terms / up to 6 years).
However, reports indicate that while civil society members are strictly held to term limits and rotation enforcement, certain bilateral and multilateral donor representatives have maintained permanent or extended presence on the CCM for 10 to 15 years, often represented by the same individual.
I request a complete governance review of CCM Nepal:
A published roster of all current and past CCM members across constituencies (Government, Civil Society, Key Populations, Donors, Multilaterals) detailing appointment dates, term lengths, and voting status.
Verification of whether term limit rules are being applied equally across all constituencies, eliminating double standards between donor agencies and national civil society organizations.
Full disclosure regarding the CCM Secretariat: the recruitment process for the CCM Coordinator, contract extensions, approval authorities, annual operational budgets, staffing costs, and funding sources.
7. CCM Oversight Committee: Independence and Conflict of Interest Management
Effective governance requires an active, independent Oversight Committee capable of enforcing compliance without fear or favor.
I request public disclosure of:
CCM Oversight Committee meeting minutes, site visit reports, and risk dashboards from 2024 to the present.
Formal conflict-of-interest (CoI) declarations filed prior to PR selection, grant reallocation, and Sub-Recipient (SR) shortlist decisions.
Documentation showing whether members affiliated with prospective PRs, SRs, or UN agencies recused themselves from voting or oversight evaluations in accordance with CCM Rules of Business Section 6.12.
8. GC8 Proposal Development, Regional Consultations, and Funding Conflicts of Interest
Concerns have been raised regarding the funding and facilitation of Grant Cycle 8 (GC8) regional consultations and needs assessments. Reports suggest that NGOs and UN entities that operate as existing or prospective SRs/SSRs/PRs funded and conducted these consultation processes directly.
While community dialogue is vital, funding or controlling country dialogue by entities that stand to receive downstream grant awards creates an inherent Conflict of Interest (CoI).
I request complete disclosure on:
The exact source of funds, total budgets, and financial instruments used to pay for GC8 consultations, regional workshops, and proposal-drafting consultants.
Contracting lists showing which NGOs, consulting firms, or UN agencies received funds to execute these consultations.
CoI management protocols applied during country dialogue meetings to ensure funding priorities reflect uncompromised community needs rather than institutional budgeting priorities.
9. Immediate Action Call and Formal Inter-Agency Meeting
To address these interconnected governance, financial, and national ownership challenges, I respectfully request that you direct the Ministry of Health and Population to convene an urgent, formal inter-agency meeting.
Proposed Meeting Agenda:
Bridge Funding & Service Continuity: Reconcile unspent grant balances and approve an immediate bridge plan for MSM/TG, sex worker, and prison health services.
National Ownership & PR Transition Strategy: Demand a clear roadmap from the Global Fund for the Government of Nepal to assume full PR status, accompanied by a unit-cost comparison between UN/INGO PR management vs. direct national management.
Dual Test-Kit Audit: Mandate an independent joint technical/financial audit into the dual HIV–syphilis test kit procurement.
Performance & Governance Review: Examine CCM Oversight scorecards and documented performance gaps (including non-sharing of PUDRs and zero progress in closed settings), review CCM term-limit compliance, and verify Conflict of Interest recusals across all committees.
GC8 Transparency: Ensure full public accounting of all funds used for GC8 consultations and proposal writing.
I propose that the Ministry acknowledge receipt of this submission and establish a clear, public action plan with accountable officials.
Honourable Minister, the Global Fund partnership is indispensable to Nepal’s national health response. Protecting this partnership requires uncompromising transparency, strong national stewardship, financial efficiency, and genuine integration into our national health system.
Thank you for your leadership and prompt attention to this urgent matter of public health importance.
Yours sincerely,
Sunil Babu Pant,
