Sector consultancy
Kenya rebuilt its health financing architecture in 2023 and has spent the years since making it work. We give ministries, counties, contracted providers and funders the economic analysis, verification and digital health evidence they need to decide what to fund, how to pay for it and whether it works.
The policy environment
Kenya's health system now rests on four statutes assented to in October 2023. The Social Health Insurance Act, 2023 replaced the National Hospital Insurance Fund with the Social Health Authority (SHA), which manages three pools: the Primary Healthcare Fund, the Social Health Insurance Fund, and the Emergency, Chronic and Critical Illness Fund. The Primary Health Care Act, 2023 organises services into primary health care networks anchored on community health units and community health promoters. The Digital Health Act, 2023 created the Digital Health Agency as custodian of health data and of a single integrated health information system. The Facilities Improvement Financing Act, 2023 lets public facilities retain the revenue they earn, to supplement rather than replace county budget allocations.
Health is split sharply between the two levels of government. The Fourth Schedule to the Constitution of Kenya, 2010 assigns health policy and national referral health facilities to the national government, and county health facilities, pharmacies, ambulance services and the promotion of primary health care to the 47 counties. The Ministry of Health sets direction under the Kenya Health Policy 2014-2030 and oversees the national agencies: SHA as purchaser, KEMSA as supplier of health products, the National Cancer Institute of Kenya, and the National Syndemic Diseases Control Council, which coordinates the response to HIV, tuberculosis, malaria, sexually transmitted infections and related conditions. Counties run public facilities up to county referral level, appoint community health promoters and co-finance their stipends with the national government.
Implementation has been contested from the start. In July 2024 the High Court declared the Social Health Insurance, Primary Health Care and Digital Health Acts unconstitutional for inadequate public participation; the Court of Appeal stayed that judgment in September 2024, and the appeal was still being heard in late 2025. SHA began operating in October 2024 and has since faced provider protests over delayed payments, disputes over the settlement of verified NHIF legacy claims, and fraud cases. In 2026 SHA made Digital Health Agency certification of facility information systems a condition of contracting. The Quality Healthcare and Patient Safety Bill, 2025, passed by the National Assembly in June 2026, is now before the Senate and would create a single authority to license, accredit and inspect health facilities.
Where the pressure is
Reviewed October 2026. Each pressure traces to a law, a policy or a ruling set out below.
Delayed reimbursements have strained hospital cash flow, and some private hospitals have suspended SHA services in protest. SHA is settling verified NHIF-era claims in stages, and many facilities dispute the amounts offered. Hospital boards and county treasuries need claims data they can defend.
The Court of Appeal stayed the High Court's July 2024 judgment pending appeal, so the Social Health Insurance, Primary Health Care and Digital Health Acts remain in force. The appeal had not been determined by late 2025, leaving a residual legal risk that funders should weigh in long-term commitments.
SHA now requires facilities to run health management information systems certified by the Digital Health Agency to contract for the 2026 to 2028 cycle, with the compliance deadline extended to 30 September 2026. Facilities without compliant systems risk exclusion from SHA-funded schemes.
Passed by the National Assembly in June 2026 and before the Senate Standing Committee on Health, the Bill would create a Quality Healthcare and Patient Safety Authority to license, accredit and inspect facilities, and a Health Care Tribunal. Facilities would need quality improvement programmes, incident reporting and professional indemnity cover.
The withdrawal of United States government funding disrupted HIV services in many facilities in 2025, and the Kenya AIDS Integration Strategic Framework 2025-2030 sets a goal of full domestic financing of the HIV response by 2030. Costing integrated syndemic services and moving them into SHA benefit packages and county budgets are now live decisions.
The October 2025 directive to restructure KEMSA targets drug availability in public hospitals. Counties must decide how much to procure through KEMSA, and stock-outs undercut the services SHA purchases.
Laws, plans and institutions
The Acts and regulations that create obligations, the policies and programmes that set direction, and the institutions that hold the mandate.
Who does what
How the Fourth Schedule of the Constitution of Kenya, 2010 divides the sector between the national government and the 47 county governments.
What we offer
Our practices combine to answer the questions this sector raises. Every assignment is scoped to the institution.
We build costed economic and business cases for screening, treatment and service delivery programmes, testing value for money against SHA tariffs and county budgets. Our 2023 Cancer Screening Programme Economic and Business Case for the National Cancer Institute applied this method.
We analyse how SHA contributions, Primary Healthcare Fund purchasing, facility revenue retention and county allocations combine at facility and county level. Our 2025 Economic Analysis of Devolved Health Financing and Service Delivery for the National Syndemic Diseases Control Council anchors this work.
We design and verify indicator frameworks for disease surveillance and programme results, triangulating facility, community and information system data. We built the Syndemic Surveillance and Indicator Verification Framework for the National Syndemic Diseases Control Council in 2024.
We evaluate digital health pilots and systems against the Digital Health Act, 2023, its 2025 regulations and the Data Protection Act, 2019, verifying whether reported indicators match what happens in care. Our 2025 Digital Health Pilot Indicator Verification in maternal care for PATH International informs this service.
Our work in this sector
| Year | Client | Engagement | Practice |
|---|---|---|---|
| 2025 | PATH International | Digital Health Pilot Indicator Verification, Maternal Care | Digital Health M&E |
| 2025 | National Syndemic Diseases Control Council | Economic Analysis of Devolved Health Financing and Service Delivery | Health Financing |
| 2024 | National Syndemic Diseases Control Council | Syndemic Surveillance and Indicator Verification Framework | Health Surveillance |
| 2023 | National Cancer Institute | Cancer Screening Programme Economic and Business Case | Health Economics |
Key references
Policy environment reviewed October 2026. Laws, regulations and programmes change; consult the official text before relying on any summary here.
Health
Tell us what you need to decide and by when. We will set it against the law, policy and budget realities of the sector and propose the work.