As part of the monitoring, we analyzed 541 food purchases made by medical institutions in the Kherson region during 2025–2026, from January 3, 2025, to April 24, 2026. The total amount of these contracts amounted to UAH 16,921,880.32.
The analysis showed recurring trends, potential risks, and signs of inefficient use of budget funds in food purchases. We also assessed the competitiveness of this market.
Separately, we analyzed how these purchases are carried out. It turned out that most of them are carried out without competition: out of a total of about 376 purchases, these are direct contracts concluded without using an electronic system. This means that customers often choose suppliers themselves without open selection, reducing transparency and limiting other participants' access to the market.
We analyzed procurement data, compared contract dates and prices with market indicators from Prozorro Market, and paid attention to supplier repeat and compliance with established procurement thresholds.
In the food sector, unlike infrastructure projects, where single large contracts are concluded, the practice of fragmenting procurement prevails. Instead of one tender, hospitals conclude dozens of small contracts, sometimes even for several hryvnias or thousands. This allows them to avoid conducting full-fledged procurement through Prozorro and to independently select suppliers.
In total, 376 direct contracts were recorded for UAH 3,750,791.27, and another 165 purchases for UAH 13,171,089.05. were carried out through a request for quotation. This shows that simplified or non-competitive procurement methods prevail in the food sector.
The strategy of “splitting” and the fragmentation of purchases
One of the key trends in food procurement is the fragmentation of the need into many small contracts. Instead of holding one large tender, medical institutions purchase products in parts: separately bread, separately meat, separately vegetables. And often on the same day or within several days. This allows you to use simplified mechanisms and actually independently choose suppliers.
Such purchases often take place in a series of 5-8 procedures over several days. And the same suppliers regularly appear in them. And although formally, these are different products, in fact, they are one process: patient nutrition. For example, the same supplier can receive contracts for different products (chicken, beetroot, and fish) within the same period. This indicates a systematic approach rather than random purchases.
As a result, instead of one open tender, a set of small contracts is formed without full competition. This practice reduces transparency and limits other suppliers' access to the market, even if the law's formal requirements are not violated.
The most illustrative cases are when one customer makes several purchases of different products within one or two days. For example, MUNICIPAL NON-COMMERCIAL ENTERPRISE "KHERSON CITY CLINICAL HOSPITAL NAMED AFTER AFANASII AND OLGA TROPINYKH" purchased separately: bread, chicken, beets, and fish. Each purchase had a relatively small amount - approximately 50-80 thousand hryvnias, but together they exceeded 250 thousand hryvnias.
It is important to consider that formally, this is not a violation, since the goods have different codes. However, when such purchases are made simultaneously, often with the same suppliers, this looks like dividing a single volume into parts.
The case of the individual entrepreneur Saliuk O.M. is among the most illustrative in our analysis. The data recorded at least 65 lots in which this supplier receives contracts. It is important that this is not one large contract but many small purchases made over time. All of them are carried out through direct or simplified procedures without real competition.
If you look at these purchases in dynamics, you can see a recurring scenario: customers regularly announce small lots, usually within the thresholds that allow you to avoid open bidding, and the same supplier constantly appears in these purchases. Often, such purchases occur at intervals of several days and appear as a series of related contracts.
At the same time, we are not talking about a single product type. These can be different products - meat, vegetables, other items, but they all belong to the same segment, that is, the food supply. In fact, this looks like dividing one volume of purchases into parts.
As a result, one supplier receives dozens of contracts in a short period and occupies a significant market share for specific customers. At the same time, competition in such purchases is either absent or minimal. This creates a situation in which access to procurement is largely shared among the same participants.
Taken together, this suggests a pattern of work in which large volumes of procurement are distributed across a series of smaller contracts. This may be formally compliant with the rules, but in reality, it restricts competition and reduces market transparency.
Change in the structure of suppliers during 2025
The analyzed procurements show a noticeable change in supplier structure during 2025. Until mid-July, the market looks relatively stable. The main volumes of contracts are received by the individual entrepreneur Kovalenko and the individual entrepreneur Orlov, who regularly participate in procurements for various customers.
After mid-July 2025, the situation changes. The number of contracts with previous suppliers decreases sharply. At the same time, other participants begin to dominate the market - primarily the individual entrepreneur Kulish I.V. and the individual entrepreneur Lykhatsky A.V. This change is occurring quite quickly and does not show signs of a gradual transition.
Particularly noticeable is the growth in the role of the individual entrepreneur Kulish I.V., who, in the second half of 2025, becomes the leader in contract amounts, having received over UAH 2.7 million. The individual entrepreneur Lykhatsky A.V. is also actively entering this segment, in particular, making larger purchases in the fall of 2025 (for example, a purchase of beef for UAH 152,000 in October).
It is also worth noting that both suppliers have appeared on the market relatively recently. According to our preliminary analysis, the individual entrepreneur Kulish I.V. was registered in May 2025, and the individual entrepreneur Lykhatsky A.V. was registered in July 2025. Despite this, in their first year of operation, they secured contracts worth millions of hryvnias and quickly captured a significant market share.
In our previous report, we also drew attention to another feature of their participation in procurements - repeated refusals to sign contracts. These are situations when, for example, the individual entrepreneur Lykhatsky submits the lowest price, is recognized as the winner, but then refuses to sign the contract. As a result, the contract is concluded with the next participant, who turns out to be the individual entrepreneur Kulish.
Similar cases occur in the opposite direction. Individual entrepreneur Kulish refuses to sign the contract, and it is then awarded to Individual entrepreneur Lykhatsky. This scenario is repeated and appears to be standard practice.
Another illustrative case is the procurement of the Kherson Children's Regional Hospital from January 26, 2026. On this day, the procurement was actually distributed between two suppliers.
Individual entrepreneur Kulish I.V. received one, but the largest contract — for the supply of meat (beef and chicken) for UAH 221,863
At the same time, the individual entrepreneur Lykhatsky A.V. received 10 more separate contracts in other categories on the same day — dairy products, butter, juices, vegetables, and fish. The total amount of these contracts was UAH 374,354.00.
- UA-2026-01-26-007451-a
- UA-2026-01-26-007240-a
- UA-2026-01-26-006633-a
- UA-2026-01-26-006380-a
- UA-2026-01-26-006001-a
- UA-2026-01-26-005711-a
- UA-2026-01-26-004808-a
- UA-2026-01-26-004522-a
- UA-2026-01-26-003983-a
- UA-2026-01-26-003675-a
Thus, within one day, the main product purchases were divided between two suppliers: one received the largest lot, while the other received a series of smaller contracts for other categories.
Formally, these are separate purchases, but together they cover almost the entire volume of the institution's food. Such a structure resembles an agreed distribution of categories among suppliers, with each receiving its own share of the market.
In general, the dynamics of a sharp change of suppliers looks like a rapid “reformatting” of the market. Instead of a gradual change of participants, there is a sharp shift of contracts towards a new group of suppliers. Taken together with other identified trends, particularly the fragmentation of purchases and low competition, this may indicate a change in market access conditions.
Analysis of price deviations
During the analysis, we also examined purchase prices and compared them with market indicators. In several cases, significant deviations were recorded, which are difficult to explain by seasonality or logistics alone.
The most illustrative example is the purchase of cabbage. In the contracts of the individual entrepreneur Saliuk O.M., the price reached UAH 55.00 per kg.
For comparison, in 2026, another participant, the individual entrepreneur Lykhatsky, offered it at about UAH 9.72 per kg.
The difference between such indicators exceeds fivefold. Even accounting for seasonality, this is a significant price deviation.
At the same time, in the MUNICIPAL NON-COMMERCIAL ENTERPRISE "KHERSON CITY CLINICAL HOSPITAL NAMED AFTER E. E. KARABELESH", cooperation with the individual entrepreneur Saliuk O.M. is maintained both before and after mid-2025. The supplier regularly receives dozens of small contracts, from several hundred to tens of thousands of hryvnas. This model allows the institution to avoid holding larger tenders.
Similar trends are observed in other product categories. For example, the price of beef increased from UAH 288–294 per kg in the first half of 2025 (supplier: individual entrepreneur Orlov) to UAH 353.43 per kg in October 2025 (supplier: individual entrepreneur Lykhatsky).
Similarly, the price of butter rose to UAH 307.44 per kg (individual entrepreneur Kulish, February 2026), while in the first half of 2025 it was approximately UAH 234–240 per kg.
The increase in beef prices was approximately 22%, and in butter prices about 31%, compared to the beginning of 2025. These purchases were mainly carried out through the “request for quotation” procedure, in which, after July 2025, new suppliers began to dominate: individual entrepreneur Kulish I.V. and individual entrepreneur Lykhatsky A.V.
Such changes do not look like a gradual market fluctuation but rather a sharp price increase in the second half of the period. Combined with low competition and a change in supplier structure, this may affect the overall level of procurement costs.
Another illustrative example of price deviations concerns the purchase of yeast. At the Bilozerka hospital, cases were recorded in which individual entrepreneur Krepakov Dmytro Volodymyrovych supplied yeast for UAH 500.00 per kg. In particular, in June 2025, 1 kg was purchased at this price.
And in October 2025, 0.5 kg for UAH 250.00, which also translates to UAH 500.00 per kg.
For comparison, already in January 2026, a similar product was purchased at a much lower price - UAH 314.37 per kg within the framework of the “request for quotation” procedure.
The difference between such prices is significant even for small volumes. This once again shows that in different procedures and with the participation of different suppliers, the cost of the same product can differ significantly.
Signs of bypassing thresholds and fragmentation of procurement
During the analysis, cases were recorded in which the expected cost of the procurement was set close to the threshold for conducting open tenders. For example, the purchase of milk from the Dnipro Agricultural limited liability company for MUNICIPAL NON-COMMERCIAL ENTERPRISE "KHERSON CITY CLINICAL HOSPITAL NAMED AFTER E. E. KARABELESH" was carried out for the amount of UAH 99,990.00.
A similar situation with the purchase of cheese from Additional liability company "The Kherson Maslozavod" for the regional hospital, also for the amount of UAH 99,990.00
In such cases, the purchase amount differs from the UAH 100,000 threshold by only UAH 10. Formally, this allows the cost to be left at a level that does not require a tender.
Conclusions
If you look at individual procurements, most look normal.
Small amounts, different goods, different procedures. But when all these procurements are added together, we see a systemic nature. Procurement is fragmented into small parts; most procedures take place without real competition. The same suppliers appear in dozens of contracts, and prices for the same goods may vary several times.
The dynamics of changes since mid-2025 are particularly noteworthy. Until this period, the market looks stable, with a limited number of suppliers regularly receiving contracts. After mid-July 2025, the structure changes quite rapidly. New participants appear, who receive significant volumes of procurement in a short time. At the same time, these changes occur without a noticeable transition phase.
In parallel, price behavior is changing. In the second half of 2025, an increase in the cost of individual products is observed, as well as significant deviations across purchases of the same goods. Combined, these factors form a market that outwardly appears to be a set of individual purchases but internally operates according to recurring scenarios.
Formally, such purchases may meet the requirements of the law. But from the perspective of competition, transparency, and the efficient use of funds, the question arises: how open is this market really?
The report was prepared by the Kherson Regional Charitable Foundation “Union” with the support of the European Endowment for Democracy (EED). Its content does not necessarily reflect the official position of the EED. The information and views expressed in this material are the sole responsibility of the author(s).
