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The Ministry of Health should concede that there is NO DIGITIZATION. There is no vaunted AI/Algorithm screening for fraud. The system is very manual, KMPDC has no capacity to verify bed capacity or ascertain fake facilities, they have no ground teams, they rely on county officials. KMPDC just sells licenses to any person with a report from the County Public Health Office. KMPDC has suffered budget cuts each year and it will just sell hospital licenses to stay afloat. KMPDC as the regulators should have internal capacity to verify fake hospitals, it cannot rely on remote officers of another entity. The bank accounts that Apeiro uses to pay hospitals were migrated directly from the NHIF database, virtually no clean-up. "Fraud detection" is being done manually by a team of young clinicians whose employer and terms of employment are not known . The whole Kshs 104B investment especially by the lead partner Apeiro is smoke and mirrors.