Starting from February 2026, the Law Center of Advocates (CDA) has recorded a significant increase in requests from beneficiaries of international protection (refugees and beneficiaries of humanitarian protection) reporting that certain public medical institutions have refused to provide them with medical assistance within the mandatory health insurance system under the same conditions as citizens of the Republic of Moldova. These situations particularly affect persons belonging to vulnerable categories, such as children, pregnant women, and pensioners.
Based on the analysis of the cases documented by CDA, these refusals stem from the administrative practice of the National Health Insurance Company (CNAM), which refuses to validate the status of persons insured by the Government for beneficiaries of international protection who fall within the categories of persons provided for in Article 4 para. (4) letters a), h), and j) of the Law on Mandatory Health Insurance No. 1585/1998.
According to the explanations provided by CNAM, letter o) of the same paragraph represents the only legal provision applicable to beneficiaries of international protection within the mandatory health insurance system, with the status of a person insured by the Government being limited to persons included in an integration program, for the duration of that program.
In CDA’s view, this approach represents an erroneous and restrictive interpretation of the legal framework, which contradicts both the letter and the spirit of the law, as well as the international human rights obligations undertaken by the Republic of Moldova. In its practical effects, this interpretation limits the access of beneficiaries of international protection to medical services within the mandatory health insurance system, generating a matter of major public interest with a direct impact on the exercise of the right to health by persons who are objectively in a vulnerable situation.
In a notification addressed to the Ministry of Health and the National Health Insurance Company, CDA requested the adoption of the necessary measures to eliminate the identified administrative practice and to ensure respect for the right of beneficiaries of international protection to medical assistance within the mandatory health insurance system, in accordance with applicable national and international standards.
“The practice of CNAM effectively results in a restriction of a fundamental right, a restriction that is not provided for by law and does not meet the requirements of legality, necessity, and compliance with international law established by Article 54 of the Constitution,” the document states.
CDA also notified the Ombudsperson and the Ombudsperson for Children’s Rights regarding the situation described and requested that they examine CNAM’s administrative practice in terms of its compatibility with the fundamental rights guaranteed by the Constitution of the Republic of Moldova and by the international treaties to which the state is a party.
The analytical note prepared by CDA on this subject can be consulted at the following link: https://cda.md/wp-content/uploads/2026/03/Nota-analitica_final.pdf
