ATTACHMENT_J.6_DCN_2017_UKR_020_Health_Reform_CE_NDWC.pdf

DCN: 2017-UKR-020

Ukraine / Health Reform Support EE.BEU Standard Form: IEE.v3

Initial Environmental Examinations (IEE)

US Agency for International Development (USAID) USAID Ukraine, Belarus, and Moldova

Initial Environmental Examination (IEE) Program/Project/Activity Data

Activity/Project Name: Health Reform Support

Assistance Objective:

MO I. 1 Enhanced anti-corruption and rule of law processes result in improved democratic governance, economic growth, and trust between society and the state.

MO1.3 Improved governance processes and outcomes cement Ukraine's democratic trajectory and movement toward European integration

Program Area: Health

Country(ies) and/or Operating Unit: USAID/Ukraine Originating Office: Office of Health Date: June 12, 2017 PAD Level IEE: Yes No Supplemental IEE: Yes No RCE/IEE Amendment: Yes No

DCN of Original RCE/IEE:

DCN of Amendment(s):

If Yes, Purpose of Amendment (AMD):

DCN(s) of All Related EA/IEE/RCE/ER(s):

2014-UKR-010 (DG DOAG IEE)

Other supplemental IEE/RCEss: 2017-UKR-007; 2017-

UKR-008; 2017-UKR-009; 2017-UKR-006; 2017-UKR-

005; 2017-UKR-001

Implementation Start/End: LOP: FY2017-FY 2022

Funding Amount: LOP Amount: $ 20,000,000

Contract/Award Number (if known):

Recommended Environmental Determination:

Categorical Exclusion: Positive Determination:

Negative Determination: Deferral:

Additional Elements:

Conditions: Local Procurement:

Government to Government: Donor Co-Funded:

Sustainability Analysis (included): Climate Change Vulnerability Analysis (included):

1. Background and Project Description

1.1. Purpose and Scope of IEE.

The subject of this Supplemental IEE, is a new 5-year, $20 Million, Health Reform Support project program. The activities anticipated under the Health Reform Support project, shown in Table 2, are assessed for potential environmental impacts, identification of needed mitigation measures, and climate risk management. This IEE will be amended (as needed) when new Health Reform Support activities, not covered below, are developed or an extension of time or budget increase is required.

1.2. Project Overview.

This activity will address pervasive corruption in the health sector. Corruption results in the inefficient spending of a significant portion of limited health care resources and ultimately contributes to poor health outcomes.

Radical reforms launched by the Ministry of Health (MOH) are facing numerous challenges, including heavy resistance from medical personnel at all levels. The new health financing arrangement requires staff to learn new professional qualities and skillsets, including independent judgement, strategic planning, marketing, and human resource management. Regional health administrators and chief doctors fear losing their existing influence and formal or informal benefits. Local doctors, dependent on those administrators, are being mobilized to resist reforms. Incomplete information about planned changes cultivates numerous myths, which MOH attempts to tackle in a reactive mode. Overall, there is a need to better structure and intensify communication in support of the ongoing reforms, with better targeting of the messaging to particular groups, identifying champions and change agents, and multiplying allies of this process.

With all these challenges, clear opportunities exist for reforms to accelerate and MOH leadership is motivated to implement such reforms. The Acting Minister currently has strong political backing from the Cabinet of Ministers, Prime Minster, and the President. A fast approaching new election cycle calls for the ruling party politicians to demonstrate tangible results to the public. Decentralization reforms, implemented in parallel with health care reform, create fertile ground for moving the health reform agenda forward.

The purpose of this activity is to support a transparent, accountable, and effective health care system that is capable of meeting the health care needs of the Ukrainian people. Advancing health sector reforms, tackling corruption, and enhancing transparency will improve access and availability of high quality health care services for Ukrainians, and will give a boost to the health system as a significant sector of Ukraine’s economy. This will be achieved under the leadership of the MOH through a collaborative effort with USAID and other donor agencies.

1.3. Project Description

The Health Reform activity, to be implemented under contract is intended to support a transparent, accountable, and effective health care system that is capable of meeting the health needs of the Ukrainian people. Advancing health sector reforms, enhancing transparency, and tackling corruption will reduce out-of-pocket payments and improve access and availability of high quality, evidence-based health care services for Ukrainians. Elimination of corruption is a cross-cutting theme across all six objectives to be achieved by this activity. The project is focused at the national level primarily; regional operations will be identified during the project based on need and commitment. The six components of the Health Reform activity are presented below with additional activity level descriptions presented in Section 3.

Component 1: Improving health sector governance and stewardship will focus on strengthening of the MOH role and technical capabilities to lead the ongoing reforms, as well as supporting the institutional strengthening of the newly formed NHS.

Component 2: Implementing the new health care financing model will focus on introduction of the new payment methods that will drive efficiency, competition and choice, and will allow for procurement of services from non-public providers.

Component 3: Strengthening the health workforce will focus on improving health workforce planning, training, and streamlining the regulatory framework.

Component 4: Enhancing transparency, accountability and responsiveness of the health care system will focus on designing the systems and mechanisms, which ensure that real-time, reliable health and administrative data is available for the MOH and other interested parties; that transactions between different players of the health care market are transparent and the amount of covert deals is dramatically reduced; that civil society and watchdog organizations are empowered to monitor the reforms process; and patients are empowered to exercise their health care rights and entitlements.

Component 5: Strategically planned, effective and targeted information and communication campaign will increase the likelihood of successful reform implementation through increasing health sector transformation support by various stakeholders, including medical professionals, general public, patient groups, politicians, media, and others.

Component 6: Improving service delivery system at all levels will focus on enhancing competition and choice in health care to improve patient satisfaction through better quality of services. This component goes beyond standard technical assistance and will include minor renovations (e.g. refurbishment and paining) of selected health care facilities when needed. The total value of renovation activities is anticipated to be approximately $100,000 of the $20,000,000 project. This will be undertaken in compliance with ADS Chapter 303 mandatory reference for USAID Implementation of Construction Activities which defines renovation and refurbishment as:

“Improvements, renovation, alteration and refurbishment” for purposes of this policy includes any betterment or change to an existing property to allow its continued or more efficient use within its designed purpose (renovation), or for the use of a different purpose or function (alteration). Improvements also include improvements to or upgrading of primary mechanical, electrical, or other building systems.

“Improvements, renovation, alteration and refurbishment” does NOT include non-structural, cosmetic work, including painting, floor covering, wall coverings, window replacement that does not include changing the size of the window opening, replacement of plumbing or conduits that does not affect structural elements, and non-load bearing walls or fixtures (e.g., shelves, signs, lighting, etc.).”1

2. Baseline Environmental Information

2.1. Locations Affected and Environmental Context

Ukraine inherited from the Soviet Union an extensive, centralized, command-and-control type health care system, which struggles to meet the needs of its population. The system has not changed much in the 25 years since independence, with the exception of incremental changes in decentralization and delegation of limited functional and managerial powers to the 27 regions.

According to the State Statistics Service of Ukraine, the average life expectancy in Ukraine in 2015 was

71.1 years (76.2 for women and 66.3 for men), well below the European Union average of 84 years for women and 79 years for men. Non-communicable diseases (mostly cardiovascular diseases and cancers) and injuries are the leading causes of death and disability. Nevertheless, Ukraine also suffers from a concomitant burden of infectious diseases such as HIV/AIDS and tuberculosis. Ukraine has one of the fastest growing HIV/AIDS epidemics in the world. Ukraine also has one of the highest DR TB rates in Europe. Child routine immunization coverage rates are significantly below both average European figures and world figures largely due to misbeliefs and myths about the harms of vaccination, in many instances cultivated by medical personnel. The Maternal Mortality Ratio has steadily declined after a rapid spike in the early 1990s and has stagnated at the level of 24 for the last several years, which is about three times higher than the European average. The Infant Mortality Rate, at the level of 8, is twice as high as in the European Union. Ukraine has 3.5 physicians per 1000 population – equivalent to the average in the European Union.

1 https://www.usaid.gov/sites/default/files/documents/1868/303maw.pdf

Corruption across all sectors, including health, is a pervasive and persisting problem in Ukraine. Public procurement has been considered for years as one of the most corrupt areas. Lack of transparency in the state procurement of medicines, supplies and medical equipment created opportunities for complex and highly lucrative schemes to pocket funds from the state budget. According to Ukraine’s Security Service estimates, up to 40% of public funds allocated annually for the medicines and equipment procurement were misappropriated through artificially inflated prices.

Responding to the challenges above, GOU and MOH, with the support of international donors, implemented several waves of Ukrainian health care sector transformation. In the past most of these reforms were of incremental value and left the old system practically intact. The current wave of reforms was initiated after the 2014 Revolution of Dignity and intensified with the appointment of the new Acting Minster of Health in September 2016.

2.2. Description of Applicable Environmental and Natural Resource Legal Requirements Policies, Laws, and Regulations:

Natural Environment Protection Law (1991), Health Protection Fundamentals Law (1993), Public Sanitary and Epidemic Safety Law (1994), Ecological Expertise Law (1995), Medicines Law (1996), Waste Law (1998), Public Infection Protection Law (2000), Unsafe Product Disposal Law (2000), Drinking Water and the Drinking Water Supply Law (2002), Land Protection Law (2003), Environmental Audit Law (2004), Ecological Policy Fundamentals Law (2010), Urban Development Law (2011), SanPiN 2.1.7.728-99, SanPin 2.1.7.2790-10, and HIV/AIDS Prevention Law (1992).

2.3. Country/Ministry/Municipality Environmental Capacity Analysis

The Ministry of Ecology and Natural Resources (MENR) has 234 full-time positions at the national level.

There are also central offices of the State Ecological Inspectorate (SEI, 54 employees), State Agency for Ecological Investments (SAEI, 71 employee), State Water Agency (SWA, 78 employees), and State Geological & Bowels Service (136 employees). These agencies are subordinated to the MENR. The MENR also manages the State (Chernobyl) Exclusion Zone Management Agency, State Ecological Academy for Postgraduate Studies & Management, as well as three research institutions and 10 government-controlled companies, which are often involved in mandatory Government of Ukraine (GOU) environmental impact reviews (EIRs).

At the regional (oblast) level, the MENR is represented by Ecology & Natural Resources Departments of Oblast State Administrations. There are also regional (oblast) offices of each MENR-subordinated agency;

for instance, the SEI has 2,746 full-time positions at the regional level, i.e. over 100 full-time positions in every oblast of Ukraine. The Ecology & Natural Resources Department of Lviv Oblast State Administration includes, for instance, two divisions: Natural Resource Use Division and Natural Resource Protection & Monitoring Division. Many municipalities also have Ecology Divisions.

The GOU has some capacity to conduct EIAs/EIRs; however, its capacity is likely limited to basic concepts and, most importantly, any significant progress in GOU capacity building in this area is thwarted by the lack of GOU political will to promote the sustainable development in Ukraine.

Ukrainian NGOs and private sector companies also have some capacity to conduct EIAs/EIRs; however, in most cases, their capacity is limited and any significant improvements can only occur when either the GOU or private sector start demanding application of modern approaches to an EIA/EIR. The Ministry of Health maintains waste management policies which health facilities are supposed to abide by.

2.4. Sustainability Analysis

It is anticipated that most project activities will not have any effect on the environment and human health.

In case of a physical intervention or any other activity with a threshold determination of negative determination with conditions, no support will be provided without initial assessment of its environmental sustainability using the ERC/EMMP template.

2.5. Climate Change Vulnerability Analysis

It is anticipated that any climate changes caused by project activities will be insignificant. However, any additional activities (and their anticipated effects) will be discussed with the Mission prior to being funded by the USG. This approach will allow avoiding any significant climate change associated with USAID assistance. The implementing partner (IP) will consider the effects of climate in their design and how future impacts may influence their designs, such as screening facilities that may be subject to flooding or other poor location issues.

3. Analysis of Potential Environmental Impact

3.1.

Component One - Improving health sector governance and stewardship

Defined or illustrative activities Potential Impacts

Potential Climate Risk Climate Risk Rating*

Recommended Threshold Determination

1.1. Supporting MOH restructuring, redefining of its vision, mission and functions, and its human and institutional capacity development via consultations, meetings and technical review of procedural documents

N/A

Damage to Health Infrastructure and Water, Sanitation, and Hygiene (WASH) Infrastructure, increased energy demands due to hot summers.

Inefficient buildings and operations of hospital infrastructure/systems require more energy and financial resources to operate.

Low

Categorical Exclusion

1.2. Supporting NHS (and its regional branches)

establishment and its human and institutional capacity development via consultations, meetings and technical review of procedural documents

Categorical Exclusion

1.3. Supporting MOH in leading and steering the donor

coordination effort via consultations and meetings and providing comments and recommendations on materials

Categorical Exclusion

1.4. Supporting selected health administrations (regions and

cities) in re-structuring and adjusting to their new governance roles via consultative meetings (including site visits and roundtables) and document review;

Selection of the pilot regions will be made based on the criteria defined by the Mission

Categorical Exclusion

1.5. Supporting the review and streamlining of the regulatory framework of health service providers by providing technical review and comment on framework documents

Categorical Exclusion

1.6. Working with the MOH and its agencies and departments

on strategic planning of communication campaign in support of reforms, its implementation, and measurement of its impact. This will be accomplished by providing

Categorical

Component One - Improving health sector governance and stewardship

Potential Impacts

Potential Climate Risk Climate Risk Rating*

Recommended Threshold Determination technical assistance, including consultations and planning and campaign document design and review.

1.7. Collaborating with the SDC to support MOH in

developing the national mental health strategy and improving the existing mental health services framework by rolling-out the IASC guideline across Ukraine and in line with international evidence-based guidelines. This will be accomplished by providing technical assistance that includes consultations with the SDC, strategy document design and review, and other technical support for IASC guideline rollout.

Low

Component Two - Implementing the new health care financing model

Potential Impacts

Potential Climate Risk Climate Risk Rating*

Recommended Threshold Determinations

2.1. In coordination with other donors, supporting the MOH

in designing of the guaranteed benefits package, as well as planning and implementation of the new provider payment mechanisms such as capitation for PHC and DRG for inpatient services. This will be accomplished by consultations and working group meetings, plus benefits package and provider payment mechanism document design and review.

N/A Damage to Health Infrastructure and Water, Sanitation, and Hygiene (WASH) Infrastructure, increased energy demands due to hot summers.

Inefficient buildings and operations of hospital infrastructure/systems require more energy and financial resources to operate while also contributing to GHG

Low Categorical Exclusion

2.2. Designing systems for monitoring of intended and

unintended responses to the new provider payment methods from providers in order to refine those payment mechanisms and design policy and regulatory responses.

N/A Low Categorical

Component Two - Implementing the new health care financing model

Potential Impacts

Potential Climate Risk Climate Risk Rating*

Recommended Threshold Determinations

Consultations will be provided and systems reviewed. emissions

2.3. Working with the relevant departments of the Ministry of Finance to optimize the allocation and management of financial resources, allocated for health care services, through working group meetings and consultations.

N/A Low Categorical Exclusion

2.4. Building provider (public and private) capacity to operate in the new health financing model through consultations with providers

N/A Low Categorical Exclusion

2.5. Consultation and technical assistance to develop

alternative health financial models, if needed, for mental health services in case these are not included in the guaranteed benefits package and public health services.

N/A Low Categorical Exclusion

2.6. Provision of technical support/oversight for piloting the Pay for Performance / Results Based Financing models where appropriate.

N/A Low Categorical Exclusion

2.7. In collaboration with other donors, supporting

implementation of the periodic Health Expenditure and Utilization Surveys (HUES) to measure the impact of new health financing policies on access and affordability of health care services through meetings with stakeholders.

Component Three - Strengthening health workforce

Potential Impacts

Potential Climate Risk Climate Risk Rating*

Recommended Threshold Determination

Potential Impacts

Potential Climate Risk Climate Risk Rating*

Recommended Threshold Determination

3.1 Assisting the MOH in developing and implementing the

longer term, evidence-based Health Workforce Strategy.

This will be accomplished by conducting consultations with the MOH and reviewing strategy documents.

N/A N/A Low Categorical Exclusion

3.2. Improving qualification, competitiveness, and

employability of health workforce, including doctors, nurses, health administrators, psychiatrists, psychologists and other allied health workers through round table discussions, workshops and study tours.

N/A Low Categorical Exclusion

3.3. Working with the MOH and the MOES in reforming and

harmonizing with the Western European standards the undergraduate and post-graduate education for doctors, including the standards of education for psychiatrists and psychologists through round table discussions and workshops

N/A Low Categorical Exclusion

3.4. Supporting MOH in streamlining the health workforce

regulatory framework, enhancing its transparency, and reducing space for corruption at all levels of medical education system through workshops and round table discussions.

N/A Low Categorical Exclusion

3.5. Supporting the comprehensive nursing education reform

planning and implementation by conducting round tables and workshops.

N/A Low Categorical Exclusion

3.6. Where feasible, supporting longer term partnerships of

selected medical schools in Ukraine with their U.S.

counterparts with the aim of creation of centers of excellence in medical education through consultations.

The selection of the Ukrainian medical schools will be made in coordination with the Mission, based on jointly

Potential Impacts

Potential Climate Risk Climate Risk Rating*

Recommended Threshold Determination agreed criteria.

3.7. Creating and strengthening the training opportunities for a degree and professional training for health administrators at various levels, through fostering partnerships with relevant U.S. universities.

Component Four - Enhancing transparency, accountability and responsiveness of the health care system

Potential Impacts

Potential Climate Risk Climate Risk Rating*

Recommended Threshold Determination

4.1. Strengthening civil society and watchdog oversight of the ongoing reforms via trainings and technical assistance.

N/A Shifting climatic conditions may result in the return of vector borne illnesses such as malaria, increase in heat related conditions (heat stroke, etc.), increased respiratory illness due to smog

Low Categorical Exclusion

4.2. Building capacity of patients’ groups to empower and

inform patients about their health care rights and entitlements, including ability to navigate publicly available information through eHealth, through trainings and technical assistance.

N/A Low Categorical Exclusion

4.3. Contributing to the development of national, integrated

health information system (eHealth) in coordination with other donor agencies by conducting trainings and technical assistance.

4.4 Building the analytical capability of the MOH and its

relevant divisions to use and interpret data for evidence based policy decision making by providing trainings and technical assistance

N/A Low Categorical

4.4. Building capacity of health service providers and in N/A Low Categorical

Component Four - Enhancing transparency, accountability and responsiveness of the health care system

Potential Impacts

Potential Climate Risk Climate Risk Rating*

Recommended Threshold Determination operating of the new eHealth system through trainings and technical assistance.

Exclusion

4.6. Collaborating with professional associations including

the National Association of Psychiatrists to strengthen their capacity to provide training and methodological services to their members;

N/A Low Categorical Exclusion

4.7. Building the analytical capability of the MOH and its

relevant divisions to use and interpret data for evidence based policy decision making through training and technical assistance.

Defined or illustrative activities under Component Five - Strategically planned, effective and targeted information and communication campaign

Potential Impacts

Potential Climate Risk Climate Risk Rating*

Recommended Threshold Determination

5.1. Assisting the MOH in developing the proactive and

systematically planned communications strategy with its implementation plan in support of the ongoing health reforms by providing technical assistance.

N/A N/A Low Categorical Exclusion

5.2. Assisting the MOH in implementation of the

communications strategy and continuously measuring its effectiveness and impact by providing strategy document review and technical monitoring assistance.

N/A Low Categorical Exclusion

5.3. Assisting MOH in identifying and consulting with the

change agents / allies in each of the significant stakeholder groups of the health care reform process.

Defined or illustrative activities under Component Six - Improving service delivery system at all levels

Potential Impacts

Potential Climate Risk Climate Risk Rating*

Recommended Threshold Determination

6.1. Supporting public-private partnership models and

changes in the legal status of publicly owned clinics with technical assistance;

N/A Damage to Health Infrastructure and Water, Sanitation, and Hygiene (WASH) Infrastructure, increased energy demands due to hot summers, shifting climatic conditions may result in the return of vector borne illnesses such as malaria, increase in heat related conditions (heat stroke, etc.), increased respiratory illness due to smog

Low Categorical Exclusion

6.2. Providing technical assistance to the MOH and other

stakeholders to enable procurement of health services from private providers;

N/A Low Categorical Exclusion

6.3. Enabling NHS to contract private providers of health care by equipping them with necessary skills and tools to monitor quality and execution of contracts through trainings;

N/A Low Categorical Exclusion

6.4. Assessing feasibility and needs for the USAID

Development Credit Authority (DCA) guarantees in Ukraine’s health sector.

N/A Low Categorical Exclusion

6.5. Providing technical assistance in the design of public

health and mental health preventive and treatment service delivery models that would fit new realities, i.e., continuing armed conflict and Russian aggression in the East of Ukraine, with a special focus on the affected population and combatants, and incentivizing providers;

N/A Low Categorical Exclusion

6.6. Supporting modernization of health service delivery

systems in the GOU controlled territories in Donetsk and Luhansk Oblasts, including improving quality, efficiency, and access to the services through technical assistance and trainings for stakeholders.

N/A Low Categorical Exclusion

6.7. Supporting modernization of health service delivery

systems, including improving quality, efficiency, and access to services, as well as renovations of the primary health care facilities when needed.

Potential adverse impact on human health and/or the environment

Lack of capacity of health service administrators and providers in procurement of health services from private providers and supporting modernization of health

Low Negative with Conditions

Defined or illustrative activities under Component Six - Improving service delivery system at all levels

Potential Impacts

Potential Climate Risk Climate Risk Rating*

Recommended Threshold Determination service delivery systems that can lead to waste management risk and biologically hazard, contamination of soil related to drugs and commodities use and disposal, as well as renovation materials use and disposal

4. Recommended Environmental Actions

4.1. Recommended Mitigation Measures

Defined/Illustrative Activities Potential Impacts Mitigation Measures Recommended Threshold

6.7 Supporting modernization of

health service delivery systems, including improving quality, efficiency, and access to services, as well as renovations of the primary health care facilities when needed.

Potential adverse impact on human health and/or the environment

The Implementing Partner (IP) will help find qualified provider(s) of equipment and services.

The IP will implement all renovation activities in accordance with the projects’ general Environmental Mitigation and Monitoring Plan (EMMP) (Annex 1), certify no significant impacts (Annex 2), and submit a Record of Compliance (Annex 3) for each location where renovation activities are undertaken. As the IP selects the subcontractors they need to match the work with the qualifications of the subcontractors and not perform work that the contractors can’t do.

The IP or the subcontractor’s selected for this work should be familiar with renovation activities. If possible the areas should be screened for hazards such as lead paint and asbestos. This can be based on the history of the building, interviews with knowledgeable personnel or testing.

The Contracting Officer’s Representative (COR) and Mission Environmental Officer (MEO) and/or E&E Bureau Environmental Officer (BEO) shall approve the ERC/EMMP prior to the start of any works that may result in a significant adverse human health and/or safety impact.

The IP will involve qualified engineer(s) and public health/environmental expert(s) to consult on/oversee the planned improvements.

If new equipment is procured, it must be installed by qualified professionals and include applicable warranties and training of personnel on proper use and maintenance of equipment.

Negative Determination with Conditions

4.2. Recommended Environmental Determination:

Categorical Exclusions:

A categorical exclusion is recommended for the following identified activities under 22 CFR 216.2(c)(2):

Activity 1.1-1.7, 2.1-2.7, 3.1-3.7, 4.1-4.7, 5.1-5.3, 6.1-6.3, and 6.6 under §216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.).

Activity 1.1-1.7, 2.1-2.7, 3.1-3.7, 5.1-5.3, 6.4, and 6.5 under §216.2(c)(2)(iii) analysis, studies, academic or research workshops and meetings

Negative Determination with Conditions: [

Under §216.3(a)(2)(iii), a negative determination with conditions is recommended for activity 6.7. Specific terms and conditions are presented below in Section 4.3.

4.3. Terms and Conditions:

4.3.1. Generally appropriate EMMPs have been developed and are attached (see IEE Annex 1).

Prior to any new activities at a specific site, the attached EMMPs shall be reviewed by the Implementing Partner (IP) for suitability, adequacy, and comprehensive inclusion of necessary environmental, health and safety safeguards. When necessary, a revised EMMP shall be sent to the Contract Officer’s Representative (COR), prior to the start of work. For each site-specific activity, the EMMP attached to this IEE, or (the revised version, if appropriate) shall be attached to the signed Certification of No Adverse or Significant Effects on the Environment (See Annex 2) and sent by the implementer to the COR for his or her records and copied to the Mission Environmental Officer (MEO) and Europe and Eurasia Bureau Environmental Officer (BEO). After the IP has finalized its activities at a specific site, the IP shall sign a Record of Compliance with the EMMP (see Annex 3) certifying that the organization met all applicable EMMP and submit it to the COR. The COR shall keep the original for the project files and provide a copy to the MEO and BEO.

4.3.2. EMMPs shall be captured in annual work plans, and therefore budgeted for and reviewed for adequacy at least annually.

4.3.3. Changes in activities beyond those covered by the EMMPs shall necessitate amending the IEE or issuing a Memo to the File (depending on extent and potential impact of the changes).

4.4. USAID Monitoring and Reporting

4.4.1. The COR, with the support of the MEO, is responsible for monitoring compliance of activities by means of desktop reviews and site visits.

4.4.2. If at any time the project is found to be out of compliance with the IEE, the COR or MEO shall immediately notify the BEO.

4.4.3. A summary report of Mission’s compliance relative to this IEE shall be sent to the BEO on an annual basis, normally in connection with preparation of the Mission’s annual environmental compliance report required under ADS 203.3.8.5 and 204.3.3.

4.4.4. The BEO or his/her designated representative may conduct site visits or request additional information for compliance monitoring purposes to ensure compliance with this IEE, as necessary.

4.5. Implementing Partner (IP) Monitoring and reporting

4.5.1. If an individual activity is found to pose significant adverse environmental effects that have not been identified and addressed in the attached EMMP(s), or EMMPs that were subsequently approved for the project, new EMMPs shall be developed to include environmental safeguards for such effects.

4.5.2. IPs shall report on environmental compliance requirements as part of their routine project reporting to USAID.

5. Mandatory Inclusion of Requirements in Solicitations, Awards, Budgets and Workplans

5.1. Appropriate environmental compliance language, including limitations defined in Section 6, shall be incorporated into solicitations and awards for this activity and projects budgets shall provide for adequate funding and human resources to comply with requirements of this IEE.

5.2. The solicitation should include the proper qualifications for the IP to hire the subcontractors and what type of work the subcontractors may be required to perform such as the abatement of lead paint, safe work operations, proper clean-up of lead dust and proper packaging and disposal of the waste.

5.3. Solicitations shall include Statements of Work with task(s) for meeting environmental compliance requirements and appropriate evaluation criteria.

5.4. Environmental mitigation and monitoring requirements, when available, shall also be included in solicitations and awards.

5.5. The IP shall incorporate conditions set forth in this IEE into their annual work plans.

5.6. The IP shall ensure annual work plans do not prescribe activities that are defined as limitations, as defined in Section 6.

5.7. The USAID Mission will include an indicator for environmental compliance as part of the project’s performance monitoring plan. [If an IEE has a threshold determination of negative determination with conditions, then a possible indictor is if the IP produced records of compliance with the

EMMP.]

6. Limitations of the IEE: This IEE does not cover activities (and therefore should changes in scope implicate any of the issues/activities listed below, a BEO-approved amendment shall be required), that:

6.1. Normally have a significant effect on the environment under §216.2(d)(1) [See http://www.usaid.gov/our_work/environment/compliance/regulations.html]

6.2. Support project preparation, project feasibility studies, engineering design for activities listed in

§216.2(d)(1);

6.3. Affect endangered species;

6.4. Result in wetland or biodiversity degradation or loss;

6.5. Support extractive industries (e.g. mining and quarrying);

6.6. Promote timber harvesting;

6.7. Provide support for regulatory permitting;

6.8. Result in privatization of industrial or infrastructure facilities;

6.9. Lead to new construction of buildings or other structures;

6.10. Assist the procurement (including payment in kind, donations, guarantees of credit) or use

(including handling, transport, fuel for transport, storage, mixing, loading, application, cleanup of spray equipment, and disposal) of pesticides or activities involving procurement, transport, use, storage, or disposal of toxic materials and /or pesticides (cover all insecticides, fungicides, rodenticides, etc. covered under the Federal Insecticide, Fungicide, and Rodenticide Act); and

6.11. Procure or use genetically modified organisms.

7. Revisions

7.1. Under §216.3(a)(9), if new information becomes available that indicates that activities covered by the IEE might be considered major and their effect significant, or if additional activities are proposed that might be considered major and their adverse effect significant, this environmental threshold decision will be reviewed and, if necessary, revised by the Mission with concurrence by the BEO. It is the responsibility of the USAID COR/AOR to keep the MEO and BEO informed of any new information or changes in the activity that might require revision of this IEE.

8. Recommended Environmental Threshold Decision Clearances:

Approval :

Susan K. Fritz, Mission Director

Date

Clearance:

John A. Pennell, Deputy Mission Director

Joel Sandefur, Regional Legal Advisor

David Hatch, Program Office Director

Tatiana Kistanova, Mission Environmental Officer

Alina Yurova, COR

Concurrence:

Mark Kamiya E&E Bureau Environmental Officer

Distribution:

IEE File MEO (to also provide a copy to AOR/COR)

Attachments:

Annex 1: EMMP Annex 2: Certification of No Adverse or Significant Effects on the Environment Annex 3: Record of Compliance Annex 4: CRM Screening

ANNEX 1: Health Reform Project EMMP DCN: 2017‐UKR‐020

Building Rehabilitation/Renovation Environmental Mitigation and Monitoring Plan Applicable for Existing Facilities with No New Construction

Activity Identified Environmental

Impacts

Mitigation Measure(s)

Monitoring Indicator(s)

Monitoring & Reporting Frequency

Responsible Party

Building rehabilitation/ renovation

Solid waste management (Soil & Groundwater Contamination)

Collect/segregate solid waste, reuse or dispose according to local regulations (in suitable landfills, if available)

Solid waste management plan developed prior to starting activity/operation to include as appropriate proper management of hazardous materials (especially asbestos & previously stored hazardous items), used or excess supplies or consumables, used batteries, used oils, used fluorescent tubes, hazardous material containers, etc. )

Plan should include adequate employee training on waste management

Types of solid waste & waste quantity (kg (m3))

Record review & site inspections

Complaints from nearby residents

Records of required waste permits

At project initiation & then monthly or quarterly

Implementer

Air Pollution Impacts (including indoor)

Prior to renovation, test for presence of asbestos (common in old flooring tiles, roofing, and pipe insulation) and lead based paint.

Use best practices to avoid airborne asbestos particles*

If lead based paint is to be disturbed, workers should wear dust masks with lead dust capabilities (3M has several models) and wear Tyvek suits to prevent exposure.

Establish procedures to handle the lead including wiping down the area with damp cloths after they scrap/sand.

Use low emissions & energy efficient windows & building materials, high efficiency lighting, low emission burners in boilers

Concentration of relevant pollutants (mg/m3)

Complaints from nearby residents

Amounts & dates of ODS recovery

Up-to-date certification of ODS handlers

Bill of Material

At project initiation & then monthly or quarterly

Implementer

See EMMP for Asbestos Remediation

ANNEX 1: Health Reform Project EMMP DCN: 2017‐UKR‐020

Monitoring & Reporting Frequency

Responsible Party

Use low or non VOC paints, chalk, and adhesives

Avoid the use of medium density fiberboard (MDF) materials, or cut outdoors and paint all surfaces and cut edges.

Use environmentally acceptable fuels for heating equipment

Replace high greenhouse gas emissions fuels (e.g., coal) with cleaner fuels like natural gas, if possible

Use best available technology for minimizing use/release of ozone depleting substances (ODS)

Noise, Traffic Congestion, Odor, & Visual Quality Impacts

Schedule trucks bringing building materials to minimize local impacts

Provide workers with protective equipment

Visual Complaints from users & nearby residents

Quarterly Implementer

Socioeconomic Impacts

Avoid discharges to sensitive ecosystems Minimize visible smoke & boiler air emissions Hire local workers Community public meetings to share mitigation information Obtain required building alteration permits

Visual Number of trained workers Number of public meetings Records of required permits

At project initiation & then quarterly

Implementer

Occupational & Public Health & Safety Impacts

Establish documented occupation safety procedures & provide regular safety training

Provide workers with protective equipment (e.g., dust masks, gloves, boots, eyewear)

Adopt fire precautions (e.g., working fire protection equipment, ban on smoking)

Manage construction traffic to protect children & the community

Signs clearly displayed

Inspection of fire protection equipment

Number of accidents & injuries

Audits safety procedure/training conformance

At project initiation & then quarterly

ANNEX 1: Health Reform Project EMMP DCN: 2017‐UKR‐020

Monitoring & Reporting Frequency

Responsible Party

Resource depletion & indirect impacts from energy & water use

Use high efficiency heating, cooling, & lighting systems & perform regular maintenance to optimize performance

Implement water conservation & re-use measures whenever appropriate

Use environmentally preferable building materials

Plans & specifications that address resource depletion reduction for retrofits

At project initiation & then quarterly

Implementer

Environmental Mitigation and Monitoring Plan for Support for rehabilitation of existing facilities with Asbestos Remediation (no new construction) involving any or all of the following: Asbestos Containing Matter (ACM); Asbestos-tiled Roofs; Asbestos with Corrugated Sheetmetal Plates; and Asbestos Insulation

Activity Identified Environmental

Monitoring & Reporting Frequency

Responsible Party

1) Asbestos Containing Material

2) Asbestos-tiled Roofs

3) Asbestos with Corrugated Sheetmetal Plates

4) Asbestos Insulation

Preparing for Asbestos Removal Asbestos Contamination

Preparing for asbestos removal.

Considerations:

A) Spray amended water (1:200 soap-to-water) to keep asbestos containing material (ACM) damp, but not saturated B) Place ACM in disposal bags, do not allow to accumulate on floor) C) Use HEPA vacuums & damp cloth wiping to stop fiber migration or fibers becoming airborne, do not use dry sweeping D) Use 6 mil polyethylene sheeting as barriers for doors, windows, vents, ACM breakage/cutting

Inspections Amounts of ACM

(kg) ACM removal permit (if applicable)

Complaints from nearly residents

Daily or Weekly

Implementer, Requirements shall be specified in contract/grant/ loan agreements

Asbestos Contamination During Removal

Asbestos removal procedures.

A) Removal of ACM panels intact, if possible and place in disposal bags B) Removal of ACM screwed-in panels after wetting screw heads. Clean holes with damp (amended water) cloth C) Removal of ACM riveted panels. (Describe expected rivet removal steps). Minimize breakage, use amended water

Place ACM & disposable overalls in 6-mil poly

Inspections Amount of ACM

(kg) Inspections Complaints from nearby residents

Daily or Weekly

ANNEX 1: Health Reform Project EMMP DCN: 2017‐UKR‐020

Monitoring & Reporting Frequency

Responsible Party bags. Then label and tightly seal bag; wipe outside bag with cloth (amended water); and remove bags for storage in a designated location

ACM Disposal

Transport waste ACM & bags of contaminated clothing to disposal site in a covered truck.

Excavate special place in landfill, build wooded encasement structure, and bury 1 meter underground

Mark site with permanent warning sign

Inspections Amount of ACM

(kg) Complaints from nearby residents Final ACM removal & disposal report (details of what was done, any problems or unexpected exposures, lessons learned)

Daily/ Weekly

Socioeconomic Impacts

Protect ecosystems in/ near facilities with asbestos

Public meetings with community to share information on asbestos removal, handling & disposal

Avoid asbestos disposal near sensitive ecosystems

Hire local workers Community public meetings to share mitigation information

Inspections.

Number of public meetings

Weekly Implementer

Public Health & Safety

Close access to facility during demolition, asbestos removal & transportation for disposal

Written asbestos safety procedures for workers & the public

Provide workers with protective equipment (e.g., Respirators (negative pressure, P100 equivalent particulate filter, half-face or full-face), gloves, disposable overalls)

Inspection to insure safety equipment is used

IAW

manufacturer specifications

Number of accidents &

Daily or Weekly

ANNEX 1: Health Reform Project EMMP DCN: 2017‐UKR‐020

Monitoring & Reporting Frequency

Responsible Party

Decontamination washing facility to wash workers from head to toe

Signs clearly displayed injuries

Annex 2: Certification of No Adverse or Significant Effects on the Environment DCN: 2017‐UKR‐020

Ukraine / Health Reform Support 1 EE.BEU Standard Form: IEE.v3

Certification of No Adverse or Significant Effects on the Environment

I, the undersigned, certify that activity-specific baseline conditions and applicable environmental requirements have been properly assessed; environment, health, and safety impacts requiring further consideration have been comprehensively identified; and that adverse impacts will be effectively avoided or sufficiently minimized by proper implementation of the EMMP(s) in Section H. If new impacts requiring further consideration are identified or new mitigation measures are needed, I will be responsible for notifying the USAID COR/AOR, as soon as practicable. Upon completion of activities, I will submit a Record of Compliance with Activity-Specific EMMPs using the format provided in Annex 3 of the projects IEE, DCN: 2017-UKR-020.

Implementer Project Director/COP Name

Approvals:

USAID COR/AOR Name

Mission Environmental Officer Name

Concurrence:

Mark Kamiya, Bureau Environmental Officer

Project Files IEE Files

Annex 3: Record of Compliance DCN: 2017‐UKR‐020

Ukraine / Health Reform Support 2 EE.BEU Standard Form: IEE.v3

RECORD OF COMPLIANCE WITH ACTIVITY-SPECIFIC

ENVIRONMENTAL MITIGATION AND MONITORING PLANS (EMMPs)

Subject: Site or Activity Name/Primary Project

IEE DCN: 2017-UKR-020

To: COR/AOR/Activity Manager Name Copy: Mission Environmental Officer Name Date:

The [name of the implementing organization] has finalized its activities at the [site name] to [describe activities and processes that were undertaken]. This memorandum is to certify that our organization has met all conditions of the EMMPs for this activity. A summary and photo evidence of the how mitigation and monitoring requirements were met is provided below.

1. Mobilization and Site Preparation

2. Activity Implementation Phase

3. Site Closure Phase

4. Activity Handover

Sincerely, Implementer Project Director/COP Name

Approved:

USAID/COR/AOR/Activity Manager Name

Project Files

MEO

Bureau Environmental Officer

Annex 4: CRM Screening DCN: 2017‐UKR‐020

Ukraine / Health Reform Support 3 EE.BEU Standard Form: IEE.v3

Climate Risk Screening and Management Tool for Project Design

PROJECT CRM TOOL OUTPUT MATRIX: CLIMATE RISKS, OPPORTUNITIES, AND ACTIONS

1.1: Defined or

Anticipated Tasks or

Interventions

1.2:

Time fram e

1.3:

Geo‐ graphy

2: Climate Risks* 3:

Adaptive Capacity

4:

Climat e Risk Rating

5:

Opportunities*

6.1: Climate Risk

Management Options

6.2: How Climate Risks Are Addresse d in the Activity*

7: Next Steps for Activity

Implementati on

8:

Accepte d Climate Risks*

Improving health sector governance and stewardship

Nation al and regiona l

Damage to Health Infrastructure and Water, Sanitation, and Hygiene

(WASH)

Infrastructure, increased energy demands due to hot summers. Inefficient buildings and operations of hospital infrastructure/syste ms require more energy and financial resources to operate while also contributing to GHG emissions

Lack of awareness of the best practices, standards, and regulatory document s, and weak access to financing to address the issues

Low

Improve coordination with MOH and donors to identify/prioriti ze infrastructure improvements to improve efficiency and save financial resources

Monitor implementati on of international best practices and capacity building

Prior to renovation activities verify the site is not prone to flooding

Work with health policy makers and health providers to improve their awarenes s and build their capacitie s

None.

Annex 4: CRM Screening DCN: 2017‐UKR‐020

Ukraine / Health Reform Support 4 EE.BEU Standard Form: IEE.v3

Implementing the new health care financing model

Nation al and regiona l

Damage to Health Infrastructure and Water, Sanitation, and Hygiene

(WASH)

Infrastructure, increased energy demands due to hot summers. Inefficient buildings and operations of hospital infrastructure/syste ms require more energy and financial resources to operate while also contributing to GHG emissions

Lack of awareness of the best practices, standards, and regulatory document s, and weak access to financing to address the issues

Low

Improve coordination with MOH and donors to identify/prioriti ze infrastructure improvements to improve efficiency and save financial resources

Monitor implementatio n of international best practices and capacity building

Work with health policy makers and health providers to improve their awarenes s and build their capacitie s

None.

Strengthening the health workforce

Nation al and regiona l

N/A

Lack of awareness of the best practices, standards, and regulatory document s, and weak access to financing to address the issues

Low N/A

Monitor implementatio n of international best practices and capacity building

Work with health policy makers and health providers to improve their awarenes s and build their capacitie

Annex 4: CRM Screening DCN: 2017‐UKR‐020

Ukraine / Health Reform Support 5 EE.BEU Standard Form: IEE.v3

Enhancing transparency, accountabilit y and responsivene ss of the health care system

Nation al shifting climatic conditions may result in the return of vector borne illnesses such as malaria, increase in heat related conditions (heat stroke, etc.), increased respiratory illness due to smog

Lack of awareness of the best practices, standards, and regulatory document s, and weak access to financing to address the issues

Low

Improve coordination with MOH and donors to identify emerging trends resulting from climate related health impacts.

Monitor implementatio n of international best practices and capacity building

Work with health policy makers and health providers to improve their awarenes s and build their…