Military Medical Examinations: Changes Initiated to Verify Persons Receiving Substitution Supportive Therapy

The Office of the Military Ombudsman regularly receives complaints concerning possible violations of the law during Military Medical Commission (MMC) examinations of persons receiving Substitution Supportive Therapy (SST).

According to Order No. 402 of the Ministry of Defence of Ukraine, persons who have been receiving state-funded SST for more than three years are considered unfit for military service. However, such persons continue to be assigned to military units.

Among the reasons are the failure of MMC to take into account documents confirming participation in SST programs, as well as their lack of access to the information system “Monitoring of Socially Significant Diseases,” administered by the Public Health Center of the Ministry of Health of Ukraine.

The Office of the Military Ombudsman has initiated amendments to the regulatory framework and the technical functionality of the information system, including the creation of an “SST” section accessible to psychiatrists serving on Military Medical Commissions. This will enable the prompt identification, during medical examinations, of persons participating in Substitution Supportive Therapy programs.

In addition, during the monitoring of one of the Military Medical Commissions in the Kyiv region, the Office’s team identified a clear procedure demonstrating that the relevant process can be properly organized.

If, during a medical examination, a conscript is found to have signs of substance dependence or reports that they were receiving Substitution Supportive Therapy before mobilization, they are referred to a narcological or psychiatric dispensary. There, they receive the necessary medical documents. The district Territorial Recruitment and Social Support Center issues a summons requiring them to return the following day. The medical certificates and conclusions obtained are submitted by the person in a sealed envelope. The psychiatrist keeps records and verifies the data.

The digitalization of MMC procedures is already provided for by current regulations: Military Medical Commission decisions are issued electronically, while the relevant documents and medical examination results are transmitted to designated information systems and registers. At the same time, in practice, MMC doctors do not always have access to the medical data necessary to objectively determine a person’s fitness for military service.

Ensuring that MMC doctors have proper and lawful access to the necessary medical information and state registers, as well as introducing clear procedures for mandatory verification of such information, are important prerequisites for compliance with the requirements of Ministry of Defence Order No. 402.