TLC Responds to Eswatini Observer Questionnaire (Part 2)
29 November 2025 | Sidvokodvo, Eswatini
On 28 November 2025, The Luke Commission received a four-question questionnaire from the Eswatini Observer. In the interest of transparency and public clarity, TLC is sharing the Observer’s questions and our responses. The previous post shared the first 3 questions and our responses. This post includes the last question and our response, allowing the public to see all responses firsthand.
At a time when misleading narratives can distort public understanding, we welcome opportunities to answer directly and openly. This post includes responses to the first three questions from the Observer’s questionnaire. A follow-up post will address the remaining question.
4. On a totally unrelated matter, a report by MinistryWatch states that:
The Luke Commission holds net assets of USD 17.7 million;
In 2022, TLC reportedly had a reserve coverage of 120%, compared with an average of 68% among organisations in the Foreign Missions sector;
The organisation received a Transparency Grade of "D"
Is TLC aware of this assessment, and if so, does the organisation consider these figures accurate? Furthermore, does TLC wish to provide context or clarification regarding the transparency rating?
4. TLC’s Response
TLC must respectfully note that the manner in which these isolated figures have been framed resembles tabloid-style reporting, which risks shaping public opinion rather than informing it accurately. TLC fully supports rigorous, fact-based scrutiny; however, selective or decontextualised data does not reflect the realities of a national-scale medical institution and risks misleading the public.
To ensure clarity, we address each point below.
4.1 What MinistryWatch Actually Says
MinistryWatch’s own assessment affirms that TLC:
undergoes annual independent consolidated audits
has received clean (unqualified) audit opinions
holds a 4star efficiency rating
carries a “Give with Confidence” donor recommendation
These core findings—omitted from the Observer’s framing—represent the most material elements of the MinistryWatch evaluation.
The “D Transparency Grade” is often misunderstood. It does not evaluate governance, accountability, audit quality, compliance, or financial integrity. It is a mechanical score based on U.S. website publications and ECFA membership — a voluntary U.S. church accreditation with an annual filing fee of USD 10,000–20,000 which is not relevant for an international medical institution.
TLC already invests USD 50,000 annually in independent audits by a top25 U.S. firm.
It is noteworthy that the Observer relies selectively on isolated data from MinistryWatch while ignoring other established U.S. nonprofit evaluators such as Charity Navigator, which rates TLC at 97%.
4.2 Net Assets — 20+ Years of Infrastructure, Not Cash
The USD 17.7 million in “net assets” represents longterm operational infrastructure, including clinical buildings and medical facilities, surgical and diagnostic equipment, hospital furniture and fittings, vehicles, and operating assets used daily for patient care
These are mission-critical tools, not surplus cash.
TLC’s independently audited 2023 consolidated statements (conducted by a top25 U.S. audit firm) show:
2023 Audit Asset Breakdown
Property & medical infrastructure: USD 11,683,823
Medical supply inventory: USD 8,022,466
Cash: USD 326,995
Other assets: USD 149,113
These figures demonstrate clearly that TLC’s assets are functional infrastructure — mission-critical and used every day for the benefit of Emaswati — not financial reserves.
TLC’s cash reserves remain critically low — a direct result of serving the nation at extraordinary scale during COVID19, when TLC stepped in at national level but did not receive cash support from NDMA or the Ministry of Health. This has been TLC’s consistent position and is validated by the very MinistryWatch data the Observer is attempting to distort.
The Miracle Campus — built through decades of sacrifice and personal investment by the founders and North American partners — is not for sale. Many have attempted to acquire or influence it for their own benefit. It exists for one purpose: to provide equitable, compassionate, excellent, accountable healthcare for all.
4.3 Reserve Coverage Ratio — Incomplete and Misleading
The “120% reserve coverage” figure for 2022 is:
Outdated — MinistryWatch’s updated figures show reserves falling to 84% in 2023.
Misleading — It ignores the extraordinary COVID19 period, during which TLC provided national services without cash support.
Methodologically invalid — It compares TLC to the “foreign missions” category, which includes small church ministries, not national-scale medical institutions.
TLC provides 24/7 emergency and trauma care, maternity, surgical, and theatre services, diagnostics and imaging, oxygen production, chronic disease management, a full referral-level hospital, a national outreach programme, and specialised surgical services.
Comparing these national health system functions to small mission groups fundamentally distorts the reality of a large healthcare ecosystem.
4.4 Transparency Grade — Mischaracterised and OverSimplified
The MinistryWatch “D” transparency grade has been mischaracterised and presented in this questionnaire as though it were a school grade failure — a framing that is inaccurate, inappropriate, and misleading.
The grade does not measure governance, accountability, compliance, audit quality, financial integrity, clinical quality, regulatory oversight, or donor compliance.
It is based almost exclusively on U.S. administrative filings and voluntary ECFA membership costing USD 10,000–20,000 annually — a U.S. church-oriented standard irrelevant to global health service delivery.
TLC will not divert donor funds away from patient care to pay for a U.S.-only accreditation designed for churches. Most large humanitarian organisations — including Samaritan’s Purse — also score poorly for this exact reason.
MinistryWatch itself confirms TLC’s clean audits and strong efficiency — yet these facts were omitted from the Observer’s questionnaire.
4.5 TLC’s Position
TLC welcomes independent review grounded in verifiable facts. However, selective, isolated use of data, incomplete comparisons, and omission of MinistryWatch’s core findings risk misleading the public and contributing to misinformation in the health sector. We encourage media to rely on full audited financial statements, operational and clinical data, statutory compliance reports, and the national health sector context when reporting on TLC.
It is also notable that while the Observer continues to focus on selective, isolated U.S. website data that does not measure TLC’s work, it ignores major, internationally verified achievements taking place inside Eswatini — achievements that have direct implications for national health outcomes and demonstrate the strength of TLC’s governance, quality systems, and audited operations.
4.6 These achievements fall into three categories:
4.6.1 Groundbreaking Clinical Milestones in Eswatini
November 2025 — Advanced Retina Surgeries: Highly specialised retina procedures performed at TLC in Eswatini, eliminating the need for Emaswati to travel to South Africa or abroad for care that is otherwise inaccessible.
November 2025 — Iris Implant Surgery: A rare iris implant procedure performed at TLC — a surgery so uncommon it is typically carried out only once a year in the University of California’s training programme.
October 2025 — Regional Joint Replacement Programme: More than 30 hip and knee replacements completed at TLC as part of a regional surgical training initiative involving surgeons from four African nations, TLC specialists, and world-class training surgeons from the United States.
These procedures require rigorous governance, surgical oversight, clinical audit, and internationally benchmarked quality systems — the very elements MinistryWatch does not measure.
4.6.2 Internationally Validated Quality & Accreditation
September 2025 — International ISO Accreditation of the TLC Medical Laboratory:
TLC’s laboratory became the first hospital-based ISO-accredited medical laboratory in Eswatini, joining only Lancet (EPH), Lancet (Mbabane Clinic), and National Referral Laboratory for HIV & TB. ISO accreditation demands strict quality-control systems, documented compliance, and continuous audit cycles.October 2025 — Global Recognition in London:
Luvelo in collaboration with TLC received international recognition for digital transformation in healthcare at the Africa Sustainable Futures Awards, sponsored by the Financial Times and the World Bank Group.
These are independently verified, international achievements requiring extensive governance, audit discipline, and data transparency.
4.6.3 Global Recognition of TLC’s Healthcare Model
Multiple features in international media, including:
Front page coverage in The Washington Post
Several other international publications throughout 2025, all highlighting TLC’s world-class, data-driven medical model
November 2025 — Benchmarking Global Excellence Event:
A national celebration attended by senior Cabinet members to honour TLC’s ISO accreditation and international achievements.
These recognitions reflect the caliber, integrity, and transparency of TLC’s systems and operational excellence — again, none of which the Observer reports.
4.6.4 Why These Omissions Matter
Each of these achievements is independently verified, publicly documented, and recognised by global institutions. They are not opinions; they are audited, accredited, internationally validated milestones.
Yet the Observer repeatedly omits them, depriving the public of an accurate picture of national healthcare progress. These milestones represent TLC’s true operational excellence — none of which U.S. nonprofit evaluators measure, and none of which the Observer reports, despite their direct relevance to national health outcomes.
Their continued omission, coupled with a reliance on selective data, reflects a pattern of reporting that falls short of the balanced, fact-based journalism the public deserves. TLC remains committed to transparency, accuracy, and accountable healthcare — and encourages all reporting on national health institutions to uphold the same standards.
NB: TLC encourages responsible, contextualised reporting grounded in verified information. We remain fully committed to cooperating with journalists who uphold professional standards of accuracy, fairness, and public interest. As a national healthcare institution serving thousands of Emaswati each month, TLC has a duty to ensure that public information regarding our work is factual and not misleading. We therefore expect that any reporting arising from this questionnaire will reflect the full context provided above.
Contact Information
For VIPs: +268 7613 8814 / +268 7923 8814
For Media Inquiries:
Lindani Sifundza, Communications Director
📞 +268 7808 7200
📧 comms@lukecommission.org
