Montenegro’s Health System Faces Corruption Challenges, Report Finds

Montenegro’s health system is struggling with corruption, as highlighted in the report titled “Integrity in Action – Assessment of Anti-Corruption Measures in Healthcare,” prepared by the Agency for Prevention of Corruption. The report reveals that the system relies more on formal compliance than on effective implementation of anti-corruption measures. The overall effectiveness of the health institutions assessed stands at 47.85%, indicating that more than half of the prescribed measures are either not fully implemented or applied only at a procedural level, lacking measurable effects.

The assessment examined 30 health institutions that provided data, while seven institutions did not respond to the agency’s requests, thus missing from the evaluation process. The report utilized a combination of self-assessments, documentation checks, and analysis of publicly available information to identify discrepancies between declared and actual conditions in corruption prevention.

Plans Exist but Lack Practical Impact

Among the institutions, the highest compliance was observed in establishing an institutional framework to combat corruption. Almost all analyzed institutions have adopted integrity plans, appointed integrity managers, and defined formal procedures for reporting irregularities. This segment recorded the highest average performance in the system.

Despite this, the report notes that the effects of these measures often remain at the administrative level. In practice, integrity plans are seldom utilized as living documents for risk management, and the activities of integrity managers tend to reduce to formal reporting. The best-performing institutions included health centers in Berane and Bijelo Polje, each achieving 68.82% compliance, followed by the Health Center in Andrijevica with 67.65%, the Institute for Medicines and Medical Devices with 65.13%, and the Clinical Center of Montenegro at 64.94%. Nevertheless, even these institutions did not meet all criteria, categorizing them as moderate performers according to the methodology.

Transparency Issues Persist

One clear area of concern highlighted in the report is the transparency of operations and access to information. A significant number of health institutions fail to publish complete and updated data on budgets, public procurements, contracts, employment, and staff structure, despite legal obligations to do so.

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

The agency asserts that the lack of transparency is a key factor enabling corruption risks, as effective public oversight cannot exist without full access to information.

Internal control mechanisms are another area where the health system is performing poorly. The report indicates that internal audits are established in only five health institutions, while in all others, this mechanism is either non-existent or not operational. Many institutions lost significant points in the assessment due to this weakness, regardless of their performance in other areas.

The report emphasizes that without functional internal controls, real risk assessment is impossible, and issues cannot be identified before they escalate into serious abuses.

Recommendations for Improvement

In the realm of ethical culture, most institutions have adopted ethical codes and established quality control committees. However, the report notes that these bodies are seldom used as active mechanisms for preventing corruption. Their work is poorly documented, and their influence on daily decision-making is limited.

Specific issues were identified in conflict of interest management, gift reporting, and additional employment disclosures. The rules in these areas are often vague or inconsistently applied, creating opportunities for non-transparent decisions, particularly in institutions with the lowest overall results, such as the Health Center in Rožaje, the Emergency Medical Services, and the Medical Chamber of Montenegro.

The report also highlights that seven health institutions did not submit data for the assessment at all. This includes the Clinical Hospital Center in Kotor and health centers in Budva, Kotor, Nikšić, Plav, and Tivat, as well as the Pharmaceutical Chamber of Montenegro. The agency states that such non-responsiveness indicates a low level of institutional accountability and hinders any assessment of the actual level of corruption risk in those institutions.

Particular attention was directed at public procurement and staffing, recognized internationally as high-risk areas for corruption in the health sector. Although Montenegro has a relatively clear regulatory framework, the application of rules in these areas is often inconsistent and opaque.

The agency found that many health institutions do not provide complete information about procurement processes, concluded contracts, and their execution. In some instances, data are fragmented, difficult to access, or not updated, making it impossible to see how public money is spent. The report particularly notes that procurement plans are frequently published formally but without clear tracking of their implementation, and changes to these plans are not sufficiently justified.

Most institutions lack developed internal control mechanisms over procurement processes, further increasing the risk of irregularities. The absence of internal audits, identified as a systemic issue, means that procurement control often reduces to formal documentation checks without substantive assessments of the justification and economy of expenditures.

The report concludes that public procurement and employment are areas where formal compliance with regulations rarely translates into real control, and without enhancing transparency, internal oversight, and managerial accountability, these segments remain the most vulnerable part of the health system.

In light of these findings, the agency issued a total of 717 recommendations aimed at improving transparency, strengthening internal controls, precisely defining ethical rules, and providing additional training for employees. The report concludes that the key issue lies not in the lack of a regulatory framework, but in its selective and formal implementation, which leaves the fight against corruption in healthcare unfinished.