10 years after: ICPC, CSJ report exposes cracks in Nigeria’s Primary Healthcare anti-corruption wall

The Independent Corrupt Practices and Other Related Offences Commission (ICPC), in collaboration with the Centre for Social Justice (CSJ) conducted a review of the implementation of the recommendations arising from the 2015 Corruption Risk Assessment (CRA) and Integrity Plan of the National Primary Health Care Development Agency (NPHCDA). Blueprint.ng reports on some the findings.

A decade after Nigeria’s anti-graft agency first sounded the alarm over corruption risks in the country’s primary healthcare system; a fresh review has returned a sobering verdict: progress has been made, but not really enough.

The National Primary Health Care Development Agency (NPHCDA), the federal body at the heart of Nigeria’s drive for Universal Health Coverage (UHC), has implemented only 58 per cent of the reforms recommended a decade ago, according to a new follow-up assessment jointly conducted by the Independent Corrupt Practices and Other Related Offences Commission (ICPC) and the Centre for Social Justice (CSJ).

The report, which covers the ten-year period between 2015 and 2025, revisits the landmark 2015 Corruption Risk Assessment (CRA) and Integrity Plan that first mapped out the operational, financial, and governance vulnerabilities inside the NPHCDA. It was carried out under the ICPC’s preventive mandate, spelt out in Sections 6(b)–(d) of the Corrupt Practices and Other Related Offences Act, 2000, which empowers the commission to examine the systems and procedures of public bodies and recommend reforms that shut the door on corruption before it happens.

What the reviewers found was a mixed picture: a system that has taken important steps forward in some respects, stalled in others, and one where new service delivery concerns have crept in even as old ones lingered.

A Law overtaken by time

Perhaps the most fundamental problem the report identifies is a structural one. NPHCDA was established under an enabling law, Cap. N69 of the Laws of the Federation of Nigeria 2004, that reviewers say is now outdated and out of step with the realities of modern primary healthcare delivery. Despite the existence of solid national policies and guidelines, the report found that weak enforcement and a fragmented sub-national governance structure continue to dilute accountability across the system.

Compounding this is the incomplete rollout of the Primary Health Care Under One Roof (PHCUOR) policy, a framework designed to harmonise the historically scattered administration of primary healthcare across federal, state, and local governments. Where PHCUOR has not been fully implemented, the report notes, overlapping mandates persist, and with them, opportunities for corruption to thrive. Nigeria’s federal structure itself compounds the problem, the reviewers found, since NPHCDA’s regulatory authority over the states remains constrained, limiting the agency’s ability to enforce even minimum standards nationwide.

States hold the cards

The assessment devotes significant attention to NPHCDA’s oversight of State Primary Health Care Development Boards (SPHCBs), describing the relationship as critical but uneven. In practice, some regulatory functions that ought to rest with the federal agency have effectively been ceded to state authorities, producing wide variation in autonomy, capacity, and political commitment from one state to another. That inconsistency, the report warns, translates directly into uneven compliance with national standards and sustains what it calls governance fragmentation, a polite term for the gaps corrupt actors exploit.

At the very frontline of service delivery, primary healthcare centres themselves remain, in the words of the report, the most vulnerable point for both corruption and service failure. Absenteeism among health workers, poor work ethics, inadequate supervision, and weak community involvement in facility management were flagged as recurring risks. The reviewers suggest that fixing this will depend less on new policy documents and more on routine supervision, stable facility leadership, and stronger community accountability structures.

Money Matters: Funds, delays, and idle balances

On the financial side, the report credits NPHCDA with putting in place financial standard operating procedures, performance-based financing manuals, and guidelines for the Basic Health Care Provision Fund (BHCPF), all of which have strengthened procedural controls on paper. But the persistent risks are familiar to anyone who has followed Nigeria’s public finance troubles: late disbursement of funds, pressure on officials to approve expenditures that do not meet eligibility criteria, idle cash balances sitting at facility level instead of being put to use, and inconsistent retirement of funds already released. The report also flags a more physical risk, noting that gaps in infrastructure at outsourced storage facilities expose public health assets to loss and deterioration.

The BHCPF, described in the report as a core financing instrument for strengthening primary healthcare and advancing universal coverage, receives particular scrutiny. While NPHCDA provides technical guidance and oversight for the fund’s implementation, delays in the release of quarterly tranches and limited capacity at facility level have blunted its effectiveness. Safeguarding the fund, the reviewers argue, will require continuous sensitisation of stakeholders, tighter supervision, and stronger accountability mechanisms.

One bright spot the report highlights is the Performance and Financial Management Officers (PFMO) initiative, a reform designed to embed financial accountability and transparency directly at facility level. Early signs of the programme’s impact are promising, the assessment found, but its long-term success will hinge on how far it is scaled, how deeply it becomes institutionalised, and whether funding for it is sustained.

A workforce under strain

Human resources emerged as another pressure point. Chronic understaffing at the zonal, state, and facility levels was found to undermine supervision, continuity of service, and internal controls more broadly. Leadership absenteeism at facility level, paired with weak succession and onboarding mechanisms, has created accountability gaps that persist even where staff are present. The report notes that while promotion processes within the agency appear to function regularly, the criteria guiding staff transfers and deployments lack transparency and stakeholder participation. Ethical codes and instruments exist within the system, the reviewers observe, but the internalisation of anti-corruption values among staff remains uneven.

Digital progress, data gaps

On technology, the picture is more encouraging, if incomplete. Gradual digitalisation, including tools such as Open LMIS and BHCPF dashboards, has improved transparency and visibility into how resources move through the system. Yet the report cautions that facility-level integration of these systems remains patchy, and that weak data integrity continues to hamper forecasting, resource allocation, and performance monitoring. Realising the full benefit of these digital reforms, the reviewers conclude, will require stronger governance and supervision to match the technology already in place.

What comes next

The report does not stop at diagnosis. It lays out a set of recommended actions organised across three time horizons. In the short term, spanning the next twelve months, it calls for fixed calendars for BHCPF disbursement, mandatory compliance directives for state boards and facilities, faster onboarding protocols for facility leadership, intensified supervisory visits, and urgent fixes to storage and cold-chain infrastructure.

Over the medium term, one to three years, the report envisions the PFMO programme being fully institutionalised nationwide, financial and procurement reporting systems standardised across states, and ICT systems achieving full integration at facility level. It also calls for stronger SPHCB governance capacity and the introduction of performance-linked incentives and sanctions.

The long-term agenda, stretching three to five years, is the most ambitious: a full legislative overhaul of the NPHCDA Act, consolidated regulatory authority for the agency over the states, and the entrenchment of a data-driven, ethically grounded culture across all levels of primary healthcare administration. The ultimate goal, as the report frames it, is to position NPHCDA as a high-trust, high-performing regulator capable of anchoring Nigeria’s journey toward universal health coverage.

A decade of uneven gains

In their concluding remarks, the ICPC and CSJ reviewers strike a measured tone. They acknowledge that NPHCDA has recorded measurable progress since 2015, even if that progress has been uneven and, on average, only partial. Foundational systems, they note, have been built in several areas, but their actual operationalisation on the ground remains inconsistent, leaving a number of high-risk areas unaddressed a full ten years after they were first identified.

For a country still working to extend basic healthcare to millions of its citizens, the report’s message is unambiguous: the frameworks for a corruption-resilient primary healthcare system are largely in place. What is missing, still, is the consistent will and capacity to enforce them.