By Cirfat Nankpak
With recent realities, there is a version of Nigeria’s next epidemic that does not begin with a virus; rather, it begins with a budget line. The Coronavirus Disease 2019 (COVID-19) pandemic opened our eyes to this stark reality, and we have spent considerable energy debating Nigeria’s dependence on external health financing. The contraction of the U.S. President’s Emergency Plan for AIDS Relief (PEPFAR) allocations, the recalibration of the United States Agency for International Development (USAID) programming, and the broader retreat of Western bilateral health aid have forced a long-overdue conversation about domestic resource mobilisation.
But that conversation has a dangerous blind spot. We speak about mobilising domestic resources as though appropriation is the endpoint of accountability. Until the National Assembly understands this distinction with the urgency it deserves, Nigeria will continue to appropriate money for epidemic preparedness while building very little of it.
Let me be direct about where the institutional failure resides. Sections 88 and 89 of the 1999 Constitution of the Federal Republic of Nigeria vest the National Assembly with explicit and expansive powers of investigation. Section 88 authorises either chamber to conduct investigations into the conduct of any authority or person executing or administering a law enacted by the National Assembly, and into the application or administration of funds appropriated by it. Section 89 empowers those investigations with coercive tools: the authority to summon persons, compel the production of documents, and take evidence under oath.
These are not ceremonial provisions, but a constitutional architecture through which a legislature, in any democracy, holds the executive accountable for what it does with public money after the gavel comes down on the Appropriation Act. In the domain of health security financing, those powers are going almost entirely unused.
The Basic Health Care Provision Fund (BHCPF), established under Section 11 of the National Health Act 2014, is one of the most significant domestic health financing instruments Nigeria has created. Drawing from the Consolidated Revenue Fund at a value of no less than one percent, it channels resources through four gateways: the National Primary Health Care Development Agency (NPHCDA) Gateway, the National Health Insurance Authority (NHIA) Gateway, the National Emergency Management Gateway, and the Nigeria Centre for Disease Control (NCDC) Gateway. The latter is the mechanism specifically designed for epidemic preparedness, outbreak investigation, and health security infrastructure at the sub-national level.
The fund is federal in origin, constitutional in mandate, and parliamentary in authorisation. Yet, the Senate Committee on Health and the House Committee on Primary Health Care have not, to any visible or documented degree, convened systematic public expenditure hearings to examine what
states are actually doing with these resources once they are released. This is an abdication of constitutional duty that is birthing alarming consequences on the ground.
When Connected Development (CODE), with its Follow The Money initiative, conducted a sub-national assessment of BHCPF 2.0 implementation in Adamawa and Kano States in April 2026, the findings that emerged were not just operational anomalies, but systemic indictments of a financing architecture that has never been subjected to serious legislative scrutiny. Three structural vulnerabilities stand out.
The first is the risk-blindness of the equal-per-state allocation formula. The NCDC Gateway, under BHCPF 2.0, distributes health security funds to states using a flat-rate model that does not adequately weight epidemiological vulnerability, population density, historical outbreak burden, or existing infrastructure deficits. Consider what this means in practice: Adamawa State, which has managed active outbreaks of cholera, diphtheria, measles, meningitis, and Buruli ulcer simultaneously, operates a single central public health laboratory at the State Specialist Hospital capable only of first-line culture testing. Any case requiring Polymerase Chain Reaction (PCR) or advanced molecular diagnostics must be referred to the national reference laboratory. The state’s new public health laboratory has been constructed and equipped but sits idle and uncommissioned, pending staff training and a formal commissioning event that has not been organised. A state carrying this epidemiological burden and this infrastructural deficit receives the exact same base allocation as a state with none of it.
The second crack is the compliance fiction surrounding State Public Health Emergency Operations Centres (PHEOCs). PHEOC compliance is a stated criterion for BHCPF NCDC Gateway disbursement; states are required to maintain functional emergency operations infrastructure as a condition of access. What CODE’s assessment revealed is that this compliance is, in many instances, unverified or aspirational rather than operational. In Adamawa, the PHEOC was confirmed as active and meeting weekly, a genuine institutional asset. But the same assessment found that health worker capacity for infection prevention and control (IPC) was, in the words of the State Epidemiologist, “very inadequate,” including for managing Lassa fever suspects at secondary and tertiary facilities. A PHEOC can be technically active while the clinical workforce it is meant to coordinate remains undertrained. If the federal government’s disbursement criteria cannot distinguish between these two realities, the compliance check is not functioning as a readiness filter, but merely as paperwork.
The third, and most structurally dangerous, crack is the complete absence of a public expenditure reporting framework for BHCPF funds at the state level. CODE’s assessment found that in Adamawa State, BHCPF funds do not pass through the state treasury, do not appear in state budget performance reports, and are therefore invisible to state financial management systems on both intake and expenditure. The state budget framework contains a column designated “other sources,” designed precisely to capture external fund flows of this kind. That column has never been operationalised for the BHCPF since the fund’s inception. The Budget Officer, a member of the State Oversight Committee, attends quarterly review meetings but reviews only activity outputs, never
financial flows, and could not provide a cumulative disbursement figure because that data does not move through his office.
What this means in legislative terms is that the National Assembly appropriates funds, the Federal Ministry of Finance releases them, the NCDC disburses them to states, and at that exact point, the trail goes dark.
In Kano State, the evidence is even more acute. Kano has received only one quarter of NCDC Gateway funding since the programme began, specifically the first quarter (Q1) 2022 disbursement of ₦13 million, because the bureaucratic process of updating account signatories each time the State Epidemiologist changes position has completely paralysed access. An entire epidemic preparedness financing mechanism has been rendered non-functional, not by corruption, but by administrative inertia that nobody at the federal level has been mandated to resolve.
Meanwhile, in Adamawa, a ₦13.2 million public health emergency disbursement from the 2021 to 2022 BHCPF 1.0 cycle sat dormant in a Central Bank Treasury Single Account (TSA) and was only accessed and utilised in 2025, three to four years after it was credited. Funds appropriated for epidemic preparedness are not building epidemic preparedness. They are aging in accounts while outbreaks are managed with whatever fallback options are available.
I am not arguing that the National Assembly should micromanage health systems. I am arguing that it should do the bare minimum that its constitutional mandate requires, which it is currently failing to do, and acknowledge that the consequences of that inaction are measurable in the declining quality of Nigeria’s health security infrastructure. Remedying this requires only political will.
The Senate Committee on Health and the House Committee on Primary Health Care and Reproductive Health must jointly mandate annual public expenditure hearings on BHCPF implementation. These should be structured around gateway-specific disbursement data, state-level retirement reports, and facility-level service delivery outcomes. These hearings must be public, transcribed, and published. The NCDC must be required to present a biannual accountability report detailing funds released, accessed, and retired per state, alongside the gaps between all three figures. Where that gap cannot be explained with documented evidence, subsequent disbursements must be withheld pending an audit.
Furthermore, the equal-per-state allocation formula must be reviewed and replaced with a risk-weighted distribution model that incorporates epidemiological vulnerability indices, existing laboratory and PHEOC infrastructure assessments, population-adjusted outbreak burden data, and historical fund utilisation rates. A state that has demonstrated genuine absorptive capacity and readiness should receive more. Conversely, a state that cannot access funds it has already received should receive intensive technical support before it receives an additional allocation.
PHEOC compliance criteria must also be operationalised beyond paperwork. The National Assembly should mandate that the NCDC develop and publish a quarterly PHEOC Functionality Scorecard for each state, covering workforce IPC capacity, laboratory diagnostic capability, surveillance system functionality, and real-time communication readiness. That scorecard should be a hard condition of disbursement, not a courtesy document.
Finally, the BHCPF must be integrated into state budget frameworks as a mandatory disclosure requirement, captured in the “other sources” revenue line, tracked through the state treasury, and reported in state budget performance documents. The National Assembly has the authority to make this a condition of continued allocation. It should exercise that authority without further delay.
Nigeria is not short of health financing policies; as with many other sectors, it is short of health financing accountability. The National Assembly has the constitutional tools, the institutional standing, and the civic obligation to close that gap. The question, as it has always been in this country, is whether the will exists to use them. The next outbreak will not wait for that answer; it will simply arrive, and we might just discover that it is too late.
If the gavel passes the budget, then it must also demand the reckoning.
Nankpak Cirfat is a Communications and Governance professional and Media Relations and Digital Communications Officer at Connected Development (CODE). He is the founder of NarraCo, a strategic communications brand. He writes in his personal capacity.
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