Photo: HFA Chairperson, Simmi Bassudev
The HFA says it believes in its current form, it will undermine the quality of healthcare and the objective of moving towards universal health coverage (UHC) in South Africa.
“While this version of the Bill includes some minor amendments, these amendments fall short of the extensive recommendations made by the private health sector (including the Health Funders Association), opposition parties, various experts and other role-players, as well as the concerns raised by the Parliamentary Legal Advisor,” the HFA says in a statement.
Its key concerns include:
Limitations on the benefits that medical schemes will be permitted to provide:
- According to the Bill, once the NHI Fund has been fully implemented, medical schemes will only be permitted to offer benefits for services not covered by the NHI. HFA believes that adding the nearly nine million lives covered by medical schemes onto an already over-burdened and failing public health system would be detrimental to quality of care.
- The input of the Parliamentary Legal Services to the Portfolio Committee indicates that the limitation on the role of medical schemes would violate the realisation of healthcare access. The constitutional implications of the right to access healthcare and freedom of association have not been addressed.
- HFA believes that limiting the role of medical schemes will have broader implications on the South African economy as it could have a negative impact on investor confidence. Healthcare access is a key consideration for investment in South Africa and for South African employers. Furthermore, it will detract from investment into the healthcare system which would benefit the NHI Fund.
A seeming lack of input from Treasury on the financing mechanism:
While the Bill talks to the principles of cross-subsidisation, it is not clear as to whether affordability studies have been conducted. It is also unclear whether a longer-term financial strategy has been developed to sustain the proposed financing system.
The Bill erroneously refers to the medical scheme tax credits as being paid to medical schemes rather than being a reduction in tax for individuals. This is a concerning misrepresentation as it suggests that the fiscal impact of the proposed tax increases is not being properly assessed. Before tax credits can be allocated to the NHI, these taxes must first be collected and this amounts to an unacceptably high tax increase on a narrow base of taxpayers.
Flight of skills:
If the Bill is passed in its current form, the HFA is concerned that there could be further loss of already constrained healthcare skills. A strategy to partner with the private sector in increasing training capacity of healthcare skills must form part of the implementation plan for NHI. This must be accompanied by a comprehensive retention plan to keep these skills in the country and part of the healthcare system.
A single NHI Fund:
HFA does not support the single-fund model as it will be vulnerable to corruption and theft. As per the current Bill, this Fund will not be autonomous as the Minister of Health will have far-reaching powers over the Fund in terms of appointments and regulations. HFA is particularly concerned that the unintended consequences of the changes to other laws included in the NHI Bill have not been properly addressed.
Quality of healthcare:
While there are pockets of excellence in the public health sector, most of the health provision and facilities do not meet the standards set by the Office of Health Standards Compliance (OHSC). This raises concerns about the overall quality of healthcare under NHI as well as the time that it will take for there to be sufficient facilities that meet the necessary accreditation levels to support full implementation.
“We are cognisant that there is still a lengthy process to be undergone before enactment of this Bill. However, we believe that the Bill in its current form is not fit for purpose if the matters raised are not urgently addressed”, says HFA Chairperson, Simmi Bassudev.
Setting up the healthcare system for failure: SAMA
The HFA’s concerns are similar to those raised by both SAMA and SAPPF which represent doctors and specialists. SAMA said yesterday that while UHC as envisaged in the objectives of the Bill intends to improve the health and livelihoods of the citizens of South Africa, the NHI Bill, in its current form sets up the healthcare system for failure at the expense of further deterioration of the health and wellbeing of all who live in the country.
“While SAMA supports the principle of UHC, it does not support the Bill in its current form,” the association noted.
“The NHI Bill has been developed with disregard to the legitimate concerns and recommendations of experts, particularly on critical issues such as the introduction of Contracting Units for Primary Healthcare (CUPS), Benefit Packages and Reimbursement Models, amongst others. Accordingly, there are significant concerns with regard to the provision of healthcare services to patients in the country should the Bill be taken forward,” SAMA added.
It pointed out that trust in government’s capability to manage the over R500 bn budget efficiently is severely eroded in particular given inter alia the mismanagement of COVID-19 funds. Misappropriation of funds in various state-owned entities casts doubt on government’s ability to handle the healthcare budget responsibly. The public, alongside healthcare stakeholders, cannot simply entrust their lives to a government with an established history of financial mismanagement.
SAMA believes that a robust approach to health systems strengthening is indispensable, as it would rectify the current deficiencies and overcome the challenges posed by the NHI. This approach seeks to enhance the efficiency, effectiveness, and resilience of the healthcare system, ensuring the delivery of optimal care to all individuals.
"Governance within the healthcare sector must be strengthened, with transparency and accountability at its core. Effective management of funds and meticulous budget allocation is imperative to rebuild trust and demonstrate responsible stewardship of public resources,” the association concluded.