IGAS Confirms Ex-SNS Director Gandra D'Almeida Breached Accumulation Rules at INEM and DE-SNS — 200k Euros at 50€/Hour, 70-Plus Weekly Hours, Payments Through His Own Company — No Sanction Because Military Status Sits Outside the LTFP

The Inspecção-Geral das Actividades em Saúde (IGAS) on 8 May 2026 closed its investigation into António Gandra D'Almeida, the former director executivo of Portugal's Serviço Nacional de Saúde (SNS), with a finding that the ex-director breached public-function accumulation rules both during his earlier tenure leading the INEM Northern Regional Delegation and during his stint at the top of the Direcção Executiva do SNS (DE-SNS). The report — leaked to Público (reporter Daniela Carmo), confirmed by RTP, Renascença, Observador and CNN Portugal — also reads that, while at the head of the DE-SNS, Gandra D'Almeida authorised the payment of a higher hourly rate on a services contract awarded to a company in which he himself was a shareholder and that supplied his own services to the SNS.

Despite the substantive findings, IGAS concludes that no disciplinary sanction can be applied. The reason is institutional, not factual: as a military officer, Gandra D'Almeida sits outside the scope of the Lei Geral do Trabalho em Funções Públicas (LTFP) — the statute that governs disciplinary process for the public service — and falls under the special Estatuto dos Militares regime, which channels accumulation-of-function and conflict-of-interest matters through the Armed Forces hierarchy rather than IGAS. The inspectorate's own language, cited in the leaked report, reads: "não é possível a aplicação de qualquer sanção ao abrigo da LTFP, dada a inexistência de vínculo regulado por este diploma".

The Sequence — INEM Norte, the Tarefeiro Hours, the SNS Move

The case unfolded across two consecutive roles. Gandra D'Almeida led the INEM delegação regional do Norte in the Porto-based emergency-medicine command, with a commission of service that closed on 31 January 2024. He was then named the country's director executivo of the SNS — the operational head of the entire National Health Service, succeeding the original DE-SNS leadership cohort — and exercised that mandate through January 2025, when he resigned amid the first wave of media coverage of the accumulation question. He returned to military duty after the resignation.

The IGAS work covers both windows. While at INEM Norte, Gandra D'Almeida held authorisations to acumular funções with private medical practice — a routine permission that allows public-sector physicians to bill private hours — but the inspectorate's reconstruction of his attendance records shows the actual hours worked as a tarefeiro (temporary contracted physician) in the emergency-medicine services of Faro and Portimão hospitals ran far above the authorised ceiling. The weekly attendance reconstruction lands at over 70 hours per week of combined public and private activity, against authorisation envelopes capped at well below that aggregate. In financial terms, IGAS reads that Gandra D'Almeida earned over €200,000 over the two-year window at a billing rate of €50 per hour for surgical-emergency services.

The Self-Authorisation Problem at DE-SNS

The second tier of the finding, and the more institutionally damaging one, sits at his time leading the SNS itself. While serving as director executivo, Gandra D'Almeida — together with his spouse — was a registered manager and shareholder of a sociedade de prestação de serviços that contracted with the SNS to provide medical services. The contractual structure routed the work back to Gandra D'Almeida as the contracted physician under the company shell.

The IGAS reading is that, during his tenure at DE-SNS, the per-hour rate paid to that company on the relevant contract was lifted — and that the lift was authorised by Gandra D'Almeida himself, ignoring the standard impedimentos regime that forbids public officials from intervening in matters in which they have a direct economic interest. The inspectorate finds a substantive breach of the impediment rules; it cannot find a sanction because the disciplinary statute does not reach a military officer in commission of service.

Why the LTFP Gap Matters

The case is now the cleanest live exhibit of an accountability gap that has surfaced repeatedly in Portuguese public-administration debate: military officers detached to civilian leadership roles in the State carry their estatuto militar across, which means the LTFP-based disciplinary regime applied to permanent civil servants and contracted public employees does not bind them. Accumulation-of-functions rules, the conflict-of-interest catalogue and the disciplinary catalogue of fines, suspension and dismissal all flow through the LTFP — which means, by construction, they do not flow to officers in service-commission abroad of their barracks.

The DL 90/2015 framework governs the military estatuto, which channels disciplinary matters through the chain of command of the relevant force (Army, Navy, Air Force). For accumulation of functions and conflict-of-interest specifically, the chain-of-command process is internal, opaque to public view, and does not produce IGAS-equivalent findings. In Gandra D'Almeida's case, the formal route would be for the Armed Forces hierarchy to open its own process on the same facts — but there is no public indication that has happened.

The Honour-Pledge Loop

One detail in the IGAS file has political traction. Under the accumulation-of-functions framework, the public official requesting the authorisation files a compromisso de honra — an honour pledge — attesting that the parallel activity will be conducted within the legal envelope (hour limits, no conflict with the public role, no use of public resources). The IGAS reconstruction reads that Gandra D'Almeida's honour pledge attested to compliance with hour limits that the attendance reconstruction shows were materially exceeded; and that the impediments declaration filed at DE-SNS did not flag the prestação-de-serviços company. The honour-pledge regime carries no enforcement weight if the underlying disciplinary statute does not bind the declarant — which is exactly the LTFP/militar gap the case now exposes.

The Political Reception

Press coverage on 8–9 May reads the IGAS conclusion as a procedurally faithful finding that lands without operational consequence. The opposition — PS and BE in particular — has called on the Government to either request a formal Armed Forces process on the same facts or to legislatively close the LTFP–militar gap so that officers in civilian-leadership commissions answer to the civilian disciplinary statute for the civilian role. The governing PSD-CDS coalition has not publicly responded to the IGAS leak as of 10 May 2026, with the Council of Ministers calendar this week dominated by the Trabalho XXI labour-code revision and the Portugal 2030 reprogramming.

The current Minister of Health, Ana Paula Martins, who succeeded the previous Government's portfolio holder, inherited the file. The ministry's stance to date has been that the IGAS finding is being studied; no parliamentary statement has been scheduled. The Ordem dos Médicos, the physicians' regulatory body, separately has the question of whether the conduct violates the deontological code — a parallel track that is not bound by the LTFP gap and could in principle reach a sanctioning conclusion on the medical-professional side. No Ordem statement has yet landed.

What Remains Open

• Whether the Armed Forces will open a chain-of-command disciplinary process on the same facts and, if so, whether the outcome will be public.
• Whether the Ministério Público — distinct from IGAS — will open a parallel criminal track on the impediment breach, which could engage prevaricação, recebimento indevido de vantagem, or peculato charges if the facts as reported by IGAS are confirmed in a criminal-investigation envelope.
• Whether the Government will table a legislative fix to extend the LTFP disciplinary regime to military officers in commission of service to civilian-leadership roles — a reform that has been called for by the Ordem dos Advogados and by the Conselho de Prevenção da Corrupção for at least a decade.
• Whether the Tribunal de Contas opens an audit on the specific contract through which the higher hourly rate was authorised — the Tribunal's contracting-supervision power is independent of LTFP discipline.

What This Means for Expats

• Read the SNS file as an institutional, not personal, story. The headline is the LTFP–militar accountability gap, not the individual. The same structural gap touches dozens of military officers in commission-of-service postings across ministries and agencies. The IGAS finding is the cleanest documented exhibit so far.
• It does not change SNS access or operations. The SNS continues to operate as before; Gandra D'Almeida is no longer in the leadership cadre. The successor leadership at DE-SNS has been operationally in place since January 2025. SNS user-facing services — Centro de Saúde appointments, urgência triage, INEM emergency dispatch — are unaffected.
• Tarefeiro economics are now in the spotlight. The €50/hour rate and the 70+ weekly hours read as a single data point on the wider tarefeiro debate — the dependence of SNS emergency services on contracted physicians billing premium hourly rates outside their public engagement. Expect renewed political pressure on the tarefeiro regime in the OE 2027 health-budget cycle.
• If you watch governance reform: The LTFP–militar gap is now the live legislative item. A reform that imports the LTFP disciplinary catalogue into commission-of-service postings would be the structural answer. Whether the Government tables it is a political-calendar question.
• For private-practice physicians and expats in regulated professions: The Ordem deontological track is independent of IGAS and the LTFP. The case underlines that conflict-of-interest catalogues operate at multiple regulatory layers — even where one layer cannot reach, another may.

The IGAS file confirms the facts but exposes the regulatory architecture. The accountability question — who answers, under which statute, with which sanction — is now the live policy debate, and its resolution will define how Portugal handles military-officer postings into civilian state leadership for the next administration cycle.