National Health Insurance (NHI) Bill: public hearings day 11

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30 June 2021
Chairperson: Dr S Dhlomo (ANC)
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Meeting Summary

Video: Portfolio Committee on Health, 30 June 2021
NHI: Tracking the bill through Parliament

In this virtual meeting, the Committee continued with its public hearings on the National Health Insurance (NHI)Bill, and received oral submissions from the South African Bone Marrow Registry, RH Bophelo Limited and the Health Products Association of Southern Africa. All of the entities welcomed the initiatives to improve access to quality health care services for all South Africans, and proposed a number of amendments to improve the Bill.

The South African Bone Marrow Registry’s main concerns about the Bill were outlined. These included the need for clarity around the transition to the NHI and the relationship between the public and private sectors during the transition process. It was highlighted that at present, risk-pooling took place amongst medical schemes for primary minimum benefits and other conditions, but there was no clarity as to whether bone marrow transplantation would specifically be covered under the NHI. The Bill was also unclear when it came to the definition of quality health service benefits, and whether the costs incurred by the Registry would be reimbursed by the Fund. It said it was willing to engage with the National Department of Health in terms of service and quality of healthcare.

The Committee asked the Registry for clarity regarding its statement that "equal treatment would result in a higher cost in reality." What was its view on existing risk-pooling amongst medical schemes? As the Registry had highlighted that bone marrow transplantation was not mentioned in the Bill, did it understand that benefits would be defined and determined by the Benefits Advisory Committee? It emphasised that during the period of transition to the NHI, the medical aids would still be in operation.

RH Bophelo emphasised the need for the NHI. An overview of the current health sector in South Africa was provided, and general concern was expressed regarding the problems that existed in the current health system. Various issues were raised about the Bill and its misalignment with the constitution, including the access to healthcare by asylum seekers and illegal foreigners. A detailed breakdown per clause of the Bill was presented, and emphasis was placed on the need for efficient registration, the rights of users, services coverage and the role of medical schemes.

Members requested clarity regarding RH Bophelo’s suggestion that the private sector was an enabler. They asked whether its concerns around portability were not covered in clause 7 of the Bill. What was its proposal for the provision of healthcare to asylum seekers and illegal foreigners? Should the Fund should be ring-fenced or earmarked, similarly to the Unemployment Insurance Fund? How would RH Bophelo support or invest in healthcare services in rural areas? Where in the Bill were private facilities excluded from providing services? What was its proposal for the governance of the NHI Fund and the associated power given to the Minister? What was its view on the pilot projects?

The Health Products Association of Southern Africa said one of its main concerns was the exclusion of "wellness" from the Bill. The lack of clarity about the role of the private sector in the complementary services sphere concerned the Association. It warned that given the current economic climate, taxpaying South Africans would not be able to afford to pay an additional tax in the form of national health insurance, and neither would companies. It wanted to know whether the NHI Fund would be ring fenced. The applicability of the single exit price, as well as its impact on health supplementation, and access to health supplementation products, was highlighted. It suggested that the proposed introduction of the NHI by 2026 was an unrealistic goal, and that a milestone approach would be more appropriate. Various concerns around clause 33 and the governance of the Fund were raised.

The Committee asked what mechanisms were in place to measure health outcomes in the complementary and alternative medicines industry. How was evidence collected to explain the rationale for relying upon such health products? Clarity was sought regarding the Association’s statement that the Bill could lower the level of care available to the majority. It asked where ‘wellness’ should be included in the Bill, and how the NHI would impact investment in this sector. Was the Association suggesting that all South Africans should consume dietary supplements? How should the Fund cover this?

Meeting report

South African Bone Marrow Registry (SABMR)

Dr Charlotte Ingram, Medical Director/Chief Executive Officer (CEO), SABMR, presented to the Committee.

She said the services of SABMR were essential in providing haematopoietic stem cells from matched unrelated donors (MUD) for bone marrow transplantation. It also worked continuously to increase donor information which would ultimately be in the best interest of the recipient/ patient. It conducts highly complex medical searches to identify MUD for patients with life-threatening blood diseases such as leukaemia, immune disorders and other blood disorders.

The SABMR's concern was that the NHI Bill explicitly states that its various provisions were to give effect to the right of access to healthcare to all (section 27(1)(a) of the Constitution), as well as the rights of children to basic healthcare (section 28 of the Constitution). These themes were therefore aimed at providing "social securities," and by their achievement to correct past injustices and inequalities, improving human life and the need to improve their quality of life. Its main concerns were:

  • Aspects of transition, relationship between private and state sector and the reimbursement for services.
  • Under the current legislation there was a risk-pooling by medical schemes for prescribed minimum benefits (PMBs) and other conditions. This risk-pooling was aimed at covering persons and not excluding them financially when they were in need of this and emergency care.
  • Costs for bone marrow transplants, including those incurred by the SABMR, were reimbursed under the current PMBs.
  • It would mean that equal treatment sometimes meant, in reality, a different or a higher cost when a specific situation was considered.
  • Some donors matched by SABMR to South African recipients were listed in international registries and were therefore outside of South Africa. Thus, the costs of obtaining haematopoietic stem cells from such donors were significantly higher than the costs of stem cells from local matched unrelated donors.
  • There was no indication if bone marrow transplantation would be covered at all by the fund, as the previously published NHI benefits framework did not indicate this.
  • The SABMR was committed to accessing resources which would reduce the time to find such a match. These patients were faced with huge financial constraints due to the high cost relating to these procedures, and their burden would be increased should they be required to fund the NHI Fund from a portion of their taxable earnings.
  • It was unclear what the definition of quality health service benefits was.
  • In order to ultimately provide complete health services for members of the Fund, it may be necessary to utilise the services of the SABMR, but it was still unclear whether the costs incurred would be reimbursed by the Fund.

Dr Ingram said the Registry's general comments were that the NHI claimed to prioritise services to those populations most in need, which would surely be the case for patients in need of a bone marrow transplant. However, there was no indication if bone marrow transplantation would be covered at all by the Fund, as the previously published NHI benefits framework did not indicate this.

Section 9(a) of the Bill states that "quality health service benefits" should be received. It was unclear what the definition of quality health service benefits were. As mentioned, SABMR was tasked with highly specialised matching, related to bone marrow transplantation, to ensure that the patients receive quality healthcare. It was also not clear from the definitions if "health services" bears the same meaning as defined in section 1 of the National Health Act, 2003 (Act No. 61 of 2003))"; with "health establishment" or "healthcare provider,'' where an organisation of the nature of the SABMR fits; or whether in respect of the services rendered by the SABMR, the NHI fund makes provision to fund the costs for members of the Fund who require a bone marrow transplant.

Section 12(1) of the Bill states that the Fund would pay only for health services that were purchased on the user's behalf by the Fund from certified and accredited service providers. In order to ultimately provide complete health services for members of the Fund, it may be necessary to utilise the services of the SABMR, but it was still unclear whether the costs incurred would be reimbursed by the Fund.

Recent PMB haematology guidelines indicate clearly that bone marrow transplantation was a PMB treatment for refractory CLL (relapsed disease), T cell prolymphocytic leukaemia, (T PLL), ALL, AML, Franconci Anaemia & other immune-related genetic immune deficiencies.

Dr Ingram said the SABMR was more than willing to engage with the National Department of Health (NDoH) should any of the particulars relating to the SABMR's services which provide complete quality healthcare with respect to the use of matched unrelated donors for Fund members requiring bone marrow transplantation, were unclear to the Department.


Ms H Ismail (DA) referred to slide 7.4, where it was mentioned that equal treatment would result in a higher cost in reality, and asked that SABMR elaborate on this. Was Dr Ingram suggesting that it would lead to a barrier to access this service?

Ms A Gela (ANC) referred to the mention of ‘risk pooling’ in the medical scheme environment – what was SAMBR’s thoughts on the fragmentation of the current pools within the medical schemes? Did SABMR think the current health financing system was equitable and efficient?

Mr T Munyai (ANC) noted that SABMR had raised a concern that there was no indication that bone marrow transplantation would be covered at all by the Fund. Was SABMR aware that benefits would be defined and determined by the Benefits Advisory Committee, as indicated in clause 24 of the Bill? The membership of the Benefits Advisory Committee would consist of technical experts in medicine, amongst others.

Dr K Jacobs (ANC) asked whether SABMR had noted that in the preamble to the Bill, its objects were to ensure financial protection from costs of healthcare and to provide access to quality healthcare through the pooling of funding and risks. Would SABMR consider this as addressing the requirement risk pool for 59 million people, as opposed to the prescribed minimum benefits which were pooling for only 8.5 million people? In terms of the definition of ‘service providers,’ were the services provided by SABMR in the sphere of diagnostics or treatment?

The Chairperson encouraged the SABMR to engage with the Department of Health on a continual basis, and commented that the Department was in attendance. He said the SABMR was providing a highly specialised service in the community. He referred to clause 33 of the Bill, where it touched on issues about medical aids and schemes. It provided comfort that during the period of transition to NHI, services would be covered and the medical aids would still be operational. It would be important to indicate where these services would fit in – specifically in terms of the Benefits Advisory Committee. The Bill was not conclusive about what would and would not be covered. Clause 33 provided an open window for experts in the field to provide advice as the Bill came to fruition.

SABMR's response

Dr Ingram thanked the Chairperson for referring back to clause 33, as it provided some hope and a way to approach the issue.

She responded to the question about stem cell storage and collection. The SABMR recruited all the donors so that they could be Human Leukocyte Antigen (HLA)-typed right at the beginning. This was then held in a database – which was like a bank. When SABMR received a patient request, it was matched to a donor on their database. SABMR then had to go back to the matching donor and prepare the donor to donate stem cells. The process was similar to donating blood. A machine was used and the method was similar to the way one would donate platelets. It took four to six hours on the machine. The donor was usually admitted overnight to ensure that there were no complications. The needle went in one arm and out the other, and the patient was given Granulocyte Stimulating Factor (GCSF), which was a stimulator of stem cells, to make them come away from the bone marrow into the peripheral blood for five days, and thereafter the collection took place. The blood went through the machine and was separated, and only the stem cells were kept for the patient. There was a tight timeline. If the stem cells were fresh and they did not try and preserve them, their ideal was to get them to the patient within 48 hours. That was why transport logistics were so important. Once one had donated stem cells, one would remain on the Registry but not be available for other patients, just in case the patient’s graft did not work. If the graft did not work, the patient may die. It was a life-saving initiative. Those stem cells would then be collected again to give the patient. Once one had donated once, one could not donate to another patient. That was why it was so difficult to keep the Registry going. People were taken off the Registry at 60 years.

Regarding the issue of higher costs, costs were dependent on where the donor was located. The Registry worked on a cost recovery basis -- only the charges that SABMR was charged were put through. For example, if it was a local donor, it would include the flight of the donor, which was a lot less than international donors. Each registry had a costing system that was paid for international donors. The state would not pay for an unrelated donor for a patient. There was a patient assistance fund, which was raised with SABMR’s own funding. When there was a case that was reviewed by the Medical Ethics Review Panel and deemed as a real need case, the SABMR would cover the cost of getting that donor. The patient would then be transplanted in a state facility.

There were inequalities, as not all patients could afford to pay for themselves. State patients did not have medical aid, whereas medical aids would normally cover the costs. In terms of reimbursement by medical schemes, there were agreements in place with the medical schemes. The SABMR worked on a cost recovery basis, and every year it looked at its costings. This was based on activity-based costing, as highly technical, qualified professionals were required to match and interpret the results. It was diagnostic in some ways, in that the SABMR did interpret the HLA typing result, but the SABMR did not actually do the testing. The testing was done through an accredited laboratory. This was costly. Before that, they used a local laboratory which charged the SABMR for the testing.

One way the medical aids functioned was by cross-subsidisation and splitting the risk. People might pay the same rates, but some patients might ‘cost more’ -- for instance, young people might not be getting as ill or possess as many conditions. That was where the cross-subsidisation likely came in. She noted that reference was made to clause 24(a), and asked that this be explained further to her. If the medical aids paid SABMR, some of the funds would be used towards patient assistance. The company was not-for profit. The SABMR would also use those funds to build the Registry.

Some of the medical aids would not cover this service, and those patients would sometimes contact SABMR and see if they could provide assistance.

Additional questions

Ms Ismail requested clarity as to whether the SABMR felt that the service would be adequately covered by the NHI, or if there would still be a need for a fund to raise money for the service.

Mr Munyai noted that SABMR had raised a concern that there was no indication that bone marrow transplantation would be covered at all by the Fund. Was the SABMR aware that the NHI benefits would be defined and determined by the Benefits Advisory Committee, as indicated in clause 24 of the Bill? The membership of the Benefits Advisory Committee would consist of technical experts in medicine, amongst others.


Dr Ingram acknowledged that the SABMR knew that transplantation was covered under certain conditions. It was presenting before the Committee, to explain that there may not be an awareness of what it cost to find a matched unrelated donor. The SABMR requested that this be taken into consideration under the NHI.

If the SABMR got a donor from the United States of America (USA), it could cost up to R900 000, but with a local donor it could cost R250 000 to R350 000. There was a huge difference in the price, but it did not relate to the quality of the service -- it was purely related to the cost of getting those cells. The SABMR’s question was whether the NHI Fund would subsidise at least part of the cost.

The Chairperson said that these were considerations that the Committee would note. He suggested that SABMR continue to engage with the Department.

Question from SABMR

Dr Ingram said that the SABMR was aware that the Office of Health Standards Compliance (OHSC) conducted certification. The SABMR was slightly different to a hospital in terms of the type of services provided, so should it still go through the process of certification via the OHSC? How would it work for the SABMR?


The Chairperson suggested the SABMR check with their sister organisation, the South African National Blood Service, as he was not sure. This was a question that would probably be best answered by the Department.

RH Bophelo Ltd

Mr Quinton Zungu, Founder and Chief Executive Officer (CEO), RH Bophelo Ltd, Mr Dion Mhlaba, Chief Financial Officer (CFO), Mr Khaya Sithole, Research Consultant, and Dr Murray Heyns, Partner, RH Bophelo, presented to the Committee.

RH Bophelo, a healthcare investment facility, gave its view on why the NHI was needed:

  • It would assist in the transformation of the sector through new entrants in the market;
  • Improve the provision of healthcare service;  
  • Availability of capital (banks and equity) – the market would not fragmented to a portion of the population;
  • Fiscal resources would be better deployed, with the move from donor to fee for service;
  • Collapsing favour in the system amongst medical aids and big groups;
  • Practitioners and service providers to be reimbursed through the system.

He pointed out that Rwanda, with fewer resources, had managed to rollout a national health scheme.

Healthcare sector overview

The South African healthcare sector was estimated at a value of R359 billion in 2015. This figure had been growing at a compound rate of 9% since 2010, despite slowing economic growth, and was expected to reach R515 billion by 2020. In 2015, this equated to 9% of gross domestic product (GDP), and this was expected to continue.

South Africa’s healthcare system was two-pronged. Firstly, there was a large, under-resourced and overused public sector which serviced the majority of the population, compared to a small, well-funded and well-equipped private sector. The public sector provided healthcare to 80% of the population (48% of total healthcare spending), whereas the private sector provided healthcare to 20% (50% of total healthcare spending). The remaining 2% was provided by non-profit organisations. Of the private sector spending, 81% was funded from private prepaid plans, and about 14% from out of pocket payments, with the balance coming from social insurance consisting of the Road Accident Fund (RAF) and the Compensation for Occupational Injuries and Diseases (COID) fund.

Ageing patterns and a larger absolute population size were important demand drivers for healthcare services. The average revenue per admission for a patient over 50 was 67% higher than the average revenue of a patient below 50. A continual increase in the 50-and-above-year-old population was expected to grow to approximately 19.1% of the population in 2030, compared with 13.9% in 2005.


The current model of the healthcare system in South Africa was characterised by:

(i) fragmentation;

(ii) limited resources;

(iii) inefficient resource allocation between the public and private sector; and

(iv) weak governance systems.

The consequence of the current model was that the country’s health outcomes were suboptimal.

Within the public sector, the health system competes with other priorities for attention from the fiscus. This leads to an enduring gap between the level of investment and resources available to the system, versus the desired funding and resource levels.

In the private sector, inefficiencies exist between the funding mechanisms and the access, quality, location and utilisation of facilities. As it stands now, the country runs two parallel healthcare systems which were not – in their current form – able to generate the healthcare outcomes acceptable to the nation at large.

The proposal to restructure the healthcare system through the NHI model had the capacity to serve as the catalyst for the convergence of the two systems in a manner that leverages the benefits associated with both.

RH Bophelo was fully in support of initiatives aimed at expanding quality healthcare to the majority of citizens, and as they had seen in the areas where they operated that the current model of payment remained an impediment to significant members of society who sought to access healthcare services. In their view, when it came to healthcare funding and risk-sharing, the pooling of resources with the most diverse pool of healthcare users and funders reduces healthcare costs and administratively leads to more consistent best practices. They therefore believe there was indeed merit in the pooling of resources, as envisaged by the NHI Bill.

As the NHI Bill seeks to pool together funding resources and then enable private facilities providers to become implementing agents for the NHI Fund, they believe that their strategy of building primary healthcare facilities in communities where they were most needed was fully aligned with the objectives of the National Health Insurance Bill. They therefore support the plan to introduce the NHI, but would also like to offer specific comments on aspects of the Bill as currently drafted.

Constitutional issues

  • In relation to section 27, the state’s obligation was to facilitate universal access to healthcare. In RH Bophela's reading, the obligation to provide universal healthcare was common cause.
  • The Bill as it stands makes a distinction between those whose access to the NHI was unlimited, and those who were classified as ‘asylum seekers and illegal foreigners’; children of asylum seekers and illegal migrants; and visiting foreigners. The distinction that had been created implied that the access afforded to certain persons was limited and not absolute. A concern that might arise was whether the distinction was not in itself antithetical to the idea of universal coverage.
  • Additionally, section 27(1)(a) of the Constitution grants everyone access to healthcare services, including reproductive healthcare.
  • If persons mentioned in section 4(2) of the Bill -- asylum seekers and illegal foreigners -- were to approach the NHI-accredited facilities, they would be granted only ‘emergency medical services’ and ‘services for notifiable conditions of public health concern.’ To this end, an access vacuum germinates where, for example, an affected person -- a pregnant woman, for example -- was denied access to the facilities on the basis that her condition was not an emergency, and yet the child to be delivered was immediately entitled to access as the children's rights were not limited according to section 28(1)(c) of the Constitution. There was then the possibility of the confusion emerging at the operational level, of whether a facility could treat only the child and deny the mother of the child access to treatment on the basis that the mother was entitled only to emergency care on the basis of the citizenship or residency status, in the absence of an emergency
  • The NHI Bill had followed the spirit of the Constitution in relation to correctional services inmates, as they were also going to be covered by the Fund. They fully supported that aspect of the Bill
  • Finally, in relation to the key practical health issues one witnesses every day, they did think it was important to ensure that treatments like anti-retroviral treatments, pre- and post-exposure prophylaxis and treatment that was of great need to rape victims and other victims of sexual violence, be specifically mentioned as the type of treatment for which no exclusions exist. This was particularly important in the case of sex workers, illegal immigrants and foreigners who were exposed to particularly acute social vulnerabilities. Sticking to the exclusion rules in this case would be self-defeating, as the spread of such diseases and secondary transmission may well affect ‘legitimate’ users of the NHI Fund.


The registration section required users to register with the Fund in order to access accredited healthcare facilities. The requirements for registration made the proof of address a compulsory requirement of registration. This might be challenged, as it was common cause that even the voters’ roll was hamstrung by the fact that proof of habitual residence was not universally available and accessible to all inhabitants of South Africa. To then have this as a barrier to registration may frustrate the objectives of obtaining as much data about healthcare users as possible.

RH Bophela was mindful of the fact that the registration process includes the provision of biometrics and possibly fingerprints, and thought that the registration process should indeed serve a dual purpose of obtaining demographic information and also could be used to create the diagnostic profile of each prospective healthcare user. To this end, they would support a programme that made it compulsory for preliminary assessments to be done at the registration point in order to create a ‘medical profile’ of each registered healthcare user. This would provide data that enabled the Fund to better identity the prevalence of particular healthcare conditions in particular locations. That in turn would inform the supply chain management (SCM) process relating to the provision of the appropriate treatments to the right communities. Failure to onboard the medical profile at the registration point would represent a missed opportunity in their view.

Rights of users

Referring to the ability of users to purchase healthcare services that were not provided by the Fund through complementary voluntary medical schemes, they thought it would be important for the publication of the list of services covered by the Fund to be a key priority area at the inception of the NHI rollout. This was mainly due to the fact that the question of whether users maintained a form of voluntary medical scheme was intrinsically linked to the question of whether conditions that they had, or were at risk of contracting, were covered by the NHI Fund or not.

Another key question in relation to section 6(o) was what happened to users who needed to use services that were outside the ambit of the Fund, but were not in a position to join the voluntary medical schemes. Currently, such people would be covered by the public healthcare system, as the means test would confirm their inability to afford private healthcare and hence access to public facilities was provided to them. Their understanding was that the means test – like every other form of filtering at the point of care – would cease to exist. The question of what happened to users whose conditions were not covered and yet could not afford voluntary medical schemes, was therefore an important issue.

Healthcare services coverage

RH Bothelo supported the idea that whenever practical, users should indeed seek healthcare services at the healthcare facilities where they had registered. They also acknowledge that logistically, the basis for registration was going to be driven by proximity to a facility, rather than by the nature of the healthcare services likely to be required. Consequently, in the initial phase the reality was that users would be registered at places where the services they would eventually need to use were not necessarily allocated to the registration facility. In Soweto for example, Baragwanath Hospital would attract the bulk of registrations, even though it was not a primary healthcare facility. Similarly, in the geographically remote areas, the prevalence of primary healthcare facilities (clinics) meant that most registrations would be in those facilities, even though the actual treatment or medical profile of a user may warrant registration at a different facility.

Given the fact that proximity would be the driver of registrations, the ‘portability of health services’ as mentioned in section 7(2)(b) was indeed one of the most important aspects of the Bill, and would remain so for the foreseeable future. To this end, they would strongly advocate for the creation of a data platform that integrates information across the various healthcare facilities. For example, if the reality was that a tertiary facility was going to attract the bulk of user registrations, the primary healthcare facilities around that tertiary facility should immediately obtain access to that data in order to be able to meet the objectives of section 7(2)(d).

Referral pathways

Regarding the management of users within the system, they agree with the principle of this section. However, in 7(2)(d)(iii), the term used implies that a user was not ‘entitled’ to services if they failed to adhere to the referral pathways as prescribed. Given the fact that they were still uncertain about the reliability and accessibility of the data under the system, they would caution against an approach that locks out a user from the system altogether on the basis that they had failed to comply with the administration pathway that was still to be developed. The nature of migration and ‘semigration’ patterns in the country, plus the reality of the spatial design of local living spaces, made the strictness of compliance with the administrative pathway criteria potentially contentious.

The Fund would need to partner with private healthcare players that were building new hospitals or were rolling out primary healthcare in order to increase the access to proximity and to have an effective referral system. A comprehensive infrastructure gap review would need to be conducted in order to identify locations that were under-invested.

Denial of funding

The wording of section 7(4) seemed to suggest that treatment would not be paid for if, for example, the healthcare service provider demonstrated that no medical necessity existed for the service in question. This sounded confusing, as the wording suggests that treatment would simply not be paid for (implying that it may well be done, and the departure point was the payment process rather than refusing the treatment altogether, particularly when it says the healthcare service provider had demonstrated that no medical need existed for the treatment). They think the intention was to say that treatment would not be provided to users in those cases.

Naturally, as private facilities, the healthcare service providers were still free to conduct the treatment for those under voluntary medical schemes and those paying out of pocket.

Cost coverage

Section 8(2) indicates that those whose treatment was not covered by the Fund for any of the listed reasons must then pay through the voluntary medical insurance scheme, or any other private insurance scheme. This was unnecessarily restrictive and should rather read “…through a voluntary medical insurance scheme or any other means…”

Additionally, the third possible reason for the denial of treatment was when a user “seeks services that were not deemed medically necessary by the Benefits Advisory Committee.”  Their understanding was that the Benefits Advisory Committee had the overarching responsibilities mentioned in section 25(5) of the Bill, which include the responsibility to determine and review “in consultation with the Minister and the Board, the health service benefits provided by the Fund.” Such a responsibility was more akin to a strategic, rather than an operational, process.

Consequently, they did not believe that a Benefits Advisory Committee would have the operational presence or reach to implement section 8(2)(c) of the Bill. In the alternative, 8(2)(c) was similar to section 7(4), in that it was the health care service provider who was more likely to be able to deem that a service was medically unnecessary on a case-by-case basis. They would therefore advocate for an amendment in the wording of 8(2)(c) to refer to the health care service provider, rather than the Benefits Advisory Committee.

Role of medical schemes

The wording of section 33 limits the ability of medical schemes to provide cover only to instances where services were not reimbursable by the Fund. Such a limitation was antithetical to the Constitutional right to freedom of choice and association. For example, in spite of the fact that it makes economic sense to sign up as a user under the NHI, there was actually no obligation to do so. In other words, a citizen may well be perfectly content with contributing to the NHI but preferring not to use accredited facilities, for example. For the NHI to still leave the scope open for unaccredited facilities to exist (section 5(7)) and then prohibit the medical schemes from providing a full suite of products, sounds difficult to reconcile with the objectives of the Bill.

Secondly, by limiting medical schemes to services not refundable by the Fund, the Bill creates another potential conflict, as individuals may well be registered as users but then have their services not paid for because of the following clauses in section 8(2):

  • The qualification exclusion clause in section 8(2)(a), read with section 4 and 5;
  • The administrative exclusion clause in section 8(2)(b);
  • The service exclusion clause in section 8(2)(c);
  • This was further compounded by the restrictive wording of section 8(2), as already discussed;
  • To be read with the next point: the South African Revenue Service (SARS) was within its rights to cancel medical aid rebates.


The Chairperson asked for clarity regarding their suggestion that the private health sector was an enabler. One got the impression from the presentation that everything that was not going well took place in the public sector. He asked for a response in that regard.

Mr M Sokatsha (ANC) said that in the presentation, concerns were raised about the portability to access NHI services. Clause 7 of the Bill stated that services would be portable, so this catered for the ability of a user to access healthcare services from an unaccredited healthcare service provider or at an accredited health establishment, other than the healthcare service provider or at the health establishment with whom or at which a user was registered in terms of clause 5. Did this not cover the presenters concern about portability? He referred to clauses 49 and 50 of the Bill, and asked why the presentation linked the abolishment of tax credits to the inability of the Fund to generate its funding.

Dr X Havard (ANC) said that RH Bophelo’s request to know the health services covered under NHI was noted, and asked if this was not taken care of in clause 25 of the Bill, which outlined the role of the Benefits Advisory Committee?

Dr Jacobs asked what RH Bophelo’s proposal would be in terms of coverage of asylum seekers and undocumented migrants. He asked it to indicate where in the Bill there was exclusion of private facilities for the provision of services. Were the criteria for providing services, in terms of clause 10(1)(b) of the Bill, adequate? He requested clarity as to whether its proposal was that the NHI Fund should be ring-fenced or earmarked, like the Unemployment Insurance Fund (UIF).

Mr Munyai said that he was glad RH Bophelo provided a service to the so-called low-income population. Under the current circumstances, what percentage of its revenue was from medical schemes and what was from cash, or out-of-pocket payments? What percentage, if any, of out-of-pocket payments did it write-off? What type of investment would RH Bophelo put into the provision of healthcare services in rural areas? Was it of the opinion that those without means must be given only basic services, and those with means to be given the best that existed? This would maintain the current system of inequality. Could the presenter indicate where in the Bill there was an exclusion of private facilities in the provision of services?

Ms M Hlengwa (IFP) asked what RH Bophelo’s proposals were in achieving equality in registration and treatment in geographically remote areas under the NHI. How could those disadvantaged communities be bridged before 2026?

Ms Gela suggested that RH Bophelo’s approach had divided the population into three groups. It had mentioned that there needed to be different approaches to each group. She asked it to explain and expand on that, bearing in mind the purpose of the Bill. Whilst RH Bophelo had indicated their support for the NHI Bill, she got the sense that it supported the maintenance of the status quo and the two-tier fragmented system. Was that correct?

Ms Ismail said that RH Bophelo had mentioned how the Bill sought to exclude asylum seekers and illegal foreigners, and asked if this could be viewed as 'institutionalised xenophobia.’ How did this contradict the Bill’s intended purpose? Could this pose a concern in terms of human rights? In terms of governance, with the number of Special Investigating Unit (SIU) investigations of the Department of Health and government entities, what was its view on the Bill giving the Minister the right to establish the Board and related entities. Did it agree with this or would it suggest that the boards be elected by, and be answerable to, Parliament?

It had mentioned that the Committee was aware of medical liability – what was its view of the impact of approximately R104 billion in legal costs due to medical negligence? Taking this into account, what was its view of how the NHI would be negatively impacted in the long run? What was its view on the NHI pilot projects – were they successful, given that there were very few features of the NHI present therein? The OHSC could monitor only seven percent of healthcare facilities, many of which did not meet the minimum norms and standards. Currently, the majority of healthcare facilities would not meet the accreditation requirements of the NHI. How would this negatively impact equal access between urban and rural areas? Quality healthcare facilities were often clustered in urban areas, so how would this impact equality, which was supposed to be a goal of the NHI?

The Chairperson noted that RH Bophelo had raised a concern about the limitation of residents in clause 5(5). There were proposals that banks could or should be used to register the population. What would its proposal ne in terms of allocation and reimbursement, particularly the capitation model? The Bill made provision for stakeholders – did RH Bophelo acknowledge that there was room for stakeholders to participate? This included input on the provision of quality, access, equitability and availability of healthcare services. This Bill was coming in from previous White and Green Papers, so if RH Bophelo thought that participation had been lost, it should explain this. When it referred to the rights of users, was it suggesting that the rights to freedom of choice and association were more important than the rights of providing access to healthcare services?

RH Bophelo's response

Mr Zungu stated that RH Bophelo was not implying that the private sector was the solution – in fact, it had its own problems which Mr Mhlaba had tried to articulate. It was proposing that this should be a partnership for both sides to work best. Both sides needed one another to ensure sustainability. He did not want to give the impression that the private sector held the solutions alone. It did not subscribe to the ‘rich and poor’ system -- the ethos of RH Bophelo was to increase access to the underserved. It was predominantly active in rural and peri-urban areas. There was alignment in intent. It was about making it as practical as possible. It was attempting to ventilate practical challenges that might need to be aligned in order to have fewer concerns, less contestation and increased efficiency.

Describing its investment in the health sector, he said RH Bophelo had invested R5 billion in South Africa across 30 healthcare facilities and 20 medical centres. It had built 20 new facilities, and was in the process of building five to seven new facilities a year. This year, it would be opening the Royal Buffalo Private Hospital in East London, and another one in Nelspruit. It was very much located in townships and peri-urban areas. It did not want to spend lots of money and be redundant -- it wanted to be a partner and not a contradictor. RH Bophelo was continuing the pace of its investments and wanted to be able to align them with the NHI Bill.

He responded to the question about the proportions of their current patient base in terms of medical aid and out-of-pocket expenditure. Currently, 85% of their patients were covered by medical aid, while 15% used cash. However, there was about 6% of a specific type of medical insurance that cost less than R450, and that market was growing significantly for those who were employed but uninsured. This had included the transfer of all security guards to a mandatory medical product as of the beginning of June 2021, which cost R250 per member. RH Bophelo had seen the opportunity, and other parties were also doing that. That market was growing bigger than medical aid, which was contracting. About 7% of medical aid schemes included low cost plans.

RH Bophelo would continue to provide services in rural areas. The Bill should consider favourably those who invested in the underserved areas. One should be able to access similar quality of care anywhere in South Africa.

RH Bophelo did not advocate for the registration process to take place at hospitals. One should be able to do it in shopping centres etc, which would take the pressure away from the hospitals.

There was something to be said about inclusive development of the Fund. It was an economic activity.

Dr Heyns said that the system was based on a rebate system and premised on the fact that people were members of a medical scheme. RH Bophelo’s view was that if the tax rebate associated with medical scheme membership was abolished, one would have fewer numbers that would sign up for the medical schemes and, as a consequence, a greater proportion of the population would be dependent on the NHI funding mechanism. As a result, the net-funding effect would be limited.

Regarding access for asylum seekers and illegal foreigners, the point that RH Bophelo had raised about clause 4(2) and clause 27(1)(a) was not that there was institutional xenophobia, but that complexity arose regarding various parts of the Bill in relation to Section 28(1)(c) of the Constitution and the provision for access of minors to healthcare. It had provided an example where a mother and child would be treated separately, based on status, and the complexity of that at a healthcare provider level was one that required clear guidance and management pathways.

Mr Zungu said that the Bill needed to be as inclusive as possible. RH Bophelo was trying to find mechanisms to bring in foreigners – this could include co-payment options, which could take place at the borders.

In terms of the Board and governance, RH Bophelo was not sure what would be appropriate. It wanted the most efficient body possible. Medical decisions were made very quickly, and some of them were life changing, so there was a need for quick decision-making.

Mr Mhlaba said it was generally left to the state to provide infrastructure in the villages, and with the introduction of the NHI, RH Bophelo hoped there would be some shared responsibility with government. When it spoke of the private sector, it was also about getting some patient fund structure, and where there would be gaps in services, those needed to be provided by government. If that changed and was shared with the private sector, this would reduce the fiscal obligation. There was currently a big infrastructure gap in South Africa in terms of services. Government might take longer to put up all the infrastructure. RH Bophelo supported the NHI -- infrastructure was required to allow for the system to work. If it was not there, it would mean the services would not be available to everyone.

Mr Zungu said that RH Bophelo was disappointed at not having participated in any of the pilots. It did not know how successful the pilot projects had been. The contracting channels were not transparent. RH Bophelo asked that the results of those studies be widely disseminated for everyone to learn from. The anticipation of the Bill and health provision for the nation was a high expectation, and one would not want to disappoint when the services were not matching the intent. There was a lot of work that needed to be done in terms of quality. It should not be underestimated. It need not start in 2026 -- it should start now. Currently, RH Bophelo had not seen that move in anticipation of NHI. It currently supported the public sector to design facilities, and there was more that could be done. It was not elevating the right of users above the right of providing healthcare. It was asking that options be available. The issue there was around the limitation of rights.

It had been asked where in the Bill the private sector was limited. The Bill did not explicitly state that the private sector was limited, but there could be restriction by design or constructive limitations. The private sector was already accredited by the Department of Health, which was a yearly process. RH Bophelo was suggesting that this process should not be made defunct. It did not see the necessity for additional administrative workloads, given the intensity of what needed to be done in comparison to what was being done.

The suggestion that there needed to be another accreditation process implied that the current one was deficient in the private sector. He proposed that there should be an ‘automatic graduation’ into the NHI if one was currently accredited. The process of registration should not be under-estimated, as it was resource consuming. It was not automatic -- it often required changes and took time. Expecting all the facilities in the private sector to migrate efficiently might also pose practical challenges. If one already had a licence, why would one not already be accredited under the NHI, unless there was an understanding that there was presently an insufficiency, in which case that needed to be dealt with.

By ring-fencing NHI funds, the structure would be more efficient and allow the Fund to get quickly to individual sustainability. The historical precedent of statutory funds had not been great, in terms of liability. There was the situation with the Road Accident Fund (RAF) and the like, where there was an exclusion of a provision of service due to a lack of efficiency from other parties. There was a need to ensure that the same pitfalls were not experienced.

There needed to be greater provision for undocumented migrants, as there were some constitutional obligations that the state had been given. The key was that South Africa needed to lead in terms of the ability to provide healthcare for all. There needed to be more options provided.

Dr Heyns addressed the question around the R104 billion in legal costs due to medical negligence. It was a delicate matter, as there was a significant correlation between the amount at which resources were stretched and the occurrence of medical legal cases. With a concerted and coordinated effort from all role players – to lessen that burden on certain facilities – there should be a decrease in the amount of negligent cases being raised. It was something that needed to be considered closely. It was a significant cost burden on the system. There were structural checks that could be put in place to guard against this. There were also ways that the financial burden of this could be mitigated. A reinsurance model could be considered that would limit the size or scope of some of the claims, in terms of the financial impact on the Fund.

Mr Zungu said that the current provisions of portability to non-creditable facilities were fine – the issue was not the ability to move. RH Bophelo’s suggestion was that all medical facilities should start off private and accredited because they were already accredited on a much more rigid basis. The workload should not be increased for the Fund, as it had a lot more functions. The ongoing monitoring could exclude the ones they did not want. RH Bophelo proposed that when there was the ability to provide a differential service, one could pay for it. The private sector had already invested in differential services. There were hospitals with general, private and singular wards. It must not be overlooked that investment had already been made. It should not be the case that if one had invested in the private sector, one had wasted one's time – that it could not be used anymore. There needed to be flexibility and options to utilise them.

He referred to the question about the limitation on access. RH Bophelo supported the capitation model. He suggested that effort would be best served by policing outcomes rather than the route of care, which required a lot of administration. In terms of participation, it saw this as an opportunity and suggested that the ability to engage with the system should be easier. Entities should have the best access possible, to allow the system to function. Nothing would start out perfectly, and allowing for changes to come gradually would be a point of success.

Health Products Association (HPA) of Southern Africa

Ms Leigh Gunkel-Keuler, Vice Chairperson of HPA, said the NHI Bill sought to achieve universal access to quality health care services in the Republic in accordance with section 27 of the Constitution; to establish a National Health Insurance Fund and to set out its powers, functions and governance structures; to provide a framework for the strategic purchasing of health care services by the Fund on behalf of users; to create mechanisms for the equitable, effective and efficient utilisation of the resources of the Fund to meet the health needs of the population; to preclude or limit undesirable, unethical and unlawful practices in relation to the Fund and its users; and to provide for matters connected herewith.

She said the basis of HPA's primary concern was that ‘‘health related product’’ meant any commodity other than orthodox medicine, complementary medicine, veterinary medicine, medical device or scheduled substance which was produced by human effort or some mechanical, chemical, electrical or other human engineering process for medicinal purposes or other preventive, curative, therapeutic or diagnostic purposes in connection with human health.

She referred to the muted role of wellness in NHI Bill, and said the HPA understood and appreciated the need to ensure equitable access to all citizens in the Republic of South Africa for healthcare services. What was not apparent or defined in the NHI Bill was the role of wellness as part of the NHI. The HPA was of the view that the key focus and narrative should be how to remain healthy, with a focus on wellness as opposed to the focus on medical treatment. Companies within the wellness space ought to be incentivised in some way for the role they played in this regard. Notwithstanding this, the HPA welcomed the focus on primary healthcare (PHC) with a referral system in order to access relevant healthcare services.

However, the HPA remained concerned that the private sector would be assigned a role within the complementary services sphere. What did this mean? Additionally, it had concerns around the distribution of medicine, as well as the prohibition of rebates, bonuses and incentives, the life-blood of the Complementary and Alternative Medicines (CAMs) industry.

The HPA was also concerned that taxpaying South Africans would not be able to afford to pay an additional tax to support the NHI, and neither could companies. It was concerned about how far taxation for the NHI would go, and if this taxation would be ring-fenced.

One of the primary concerns of its members was the role of the Single Exit Pricing (SEP) system and its applicability to CAMs products, given its classification under health related products. The HPA was of the opinion that the current exemption would cease to exist, and its members would be expected to sell such products including S0 Category A and S0 Category D medicines at a single exit price. The unintended consequences for S0 Category A and Category D medicines could be extensive. Access to these products would be severely restricted. As an industry, the HPA could not afford SEP. The majority of its members fell into the small and medium sized categories of business within the CAMs industry and the anticipated increase in costs to implement SEP on its products would negatively affect them. This decision, if implemented, would severely and negatively impact the CAMs industry in South Africa.

Regarding time-frames, the HPA was of the opinion that the various milestones of the NHI needed to be executed in a phased in manner, and that it would be unrealistic to achieve all the necessary milestones by the effective go-live date of 2026.

Ms Gunkel-Keuler said clause 33 dealt with the role of medical schemes. In terms of this clause, medical schemes registered in terms of the Medical Schemes Act, 1998 (Act No 131 of 1998), or any other voluntary private health insurance scheme, "shall be restricted to providing complementary cover for health care service benefits that were not purchased by the Fund on behalf of users.” The HPA was of the view that Section 33 of the Bill needed to be omitted, as it pertained to "once fully implemented... the private sector to play a complementary role" -- what did this mean? The private sector required clarity. This would have an impact on future investments, planning, etc

With regard to governance, the HPA was of the view that Parliament should play an oversight role, like was done with other Chapter 9 institutions. This was to ensure the integrity of the governance framework and to hold the relevant Ministry to account.

She commented that the HPA was of the view that all Acts to be repealed and/or amended needed to undergo a legislative process like was being done with the NHI Bill. It should not be automatic that relevant Acts, like the Medical Schemes Act, 1998, Correctional Services Act 1998, Compensation for Occupational Injury & Diseases, 1993, the Road Accident Fund Act, 1996, etc, were impacted in this way.

Ms Gunkel-Keuler concluded that the HPA was appreciative of the opportunity to comment and present to the Portfolio Committee on the NHI Bill. The HPA remained supportive of achieving universal healthcare coverage for all South Africans, and most notably looked to its member companies in the health and wellness space to play a meaningful role in this regard.

The HPA welcomed the opportunity for engagement on this Bill, given its significance, and looked forward to all relevant comments and views being taken into account as part of this Parliamentary process. The HPA was of the opinion that the attainment of universal healthcare coverage could not be left to government alone and as part of the private sector, the HPA welcomed constructive dialogue and engagement on this very significant Bill. It was also of the view that an additional draft of the NHI Bill was required as part of this process before finalisation.

The HPA was of the opinion that it needed to be appreciated that as complementary and alternative medicines had been listed as health-related products, that the HPA’s voice needed to be heard as it related to CAMs forming a part of the NHI system for healthcare delivery. However in so doing, it also wanted to utilise this opportunity to provide additional insights into the wellness space and its need to be adequately reflected within the objectives of universal healthcare coverage. In this regard, the HPA was of the opinion that the CAMs industry could not be subjected to allopathic/pharmaceutical terms as they related to procurement, listing and access as a part, or any future part, of the NHI.


Ms Gela noted that the HPA was concerned about ‘wellness’ not being defined in the Bill. Was the HPA aware that the NHI would cover a comprehensive set of health services that would provide a continuum of care from community outreach, health promotion and prevention, to other levels of care as indicated in clauses 57, 3 and 4 of the Bill. These benefits would be defined by the Benefits Advisory Committee, as outlined in clause 25 of the Bill. Was HPA’s concern addressed there?

The HPA had raised concerns about the lack of clarity on complementary health services. Did itthink that the Benefits Advisory Committee had defined the NHI package of services according to their roles, as defined by clause 25 of the Bill? This was supported by clauses 6 and 33, which dealt with the future role of medical schemes.

She noted the HPA’s concern about the tax burden -- was it not addressed in clause 49(2), as the majority of medical scheme members could not afford to pay their premiums? The cost of private healthcare was extremely unaffordable. This had been noted by the Health Market Inquiry -- what was the HPA’s view on this?

The HPA had highlighted a series of issues about the single exit price. Clause 38(3) outlined the role of the Office of Health Products Procurement, which amongst other things would address the HPA’s concerns. The Healthcare Benefits Pricing Committee, as prescribed by clause 26 of the Bill, would have a role in addressing this issue. Given this information, was HPA still concerned about this?

Mr Sokatsha asked what mechanisms the industry had put in place to measure healthcare outcomes, and how evidence was collected to explain the rationale for using HPA’s health products?

Ms Ismail noted that the HPA had mentioned that the Bill could lower the level of care available to the majority. She asked that it be a bit more specific as to the ways this would lower care. Was it suggesting that the Bill, as it currently stood, could have an opposite effect to that which was intended? Where did the HPA propose ‘wellness’ should be included in the Bill? What did it think should be more detailed in terms of the private sector’s role in the Bill? In what ways would the NHI impact investment? She acknowledged their position regarding the Minister’s role, and thanked them for their input on that issue.

Mr Munyai said the HPA had made a recommendation about the phased implementation of NHI – did it think the phased-in approach was not sufficiently addressed in clause 57 of the Bill, as well as the associated memorandum?

He noted the HPA’s concern about clause 33 – was this not sufficiently addressed in the NHI White Paper, which needed to be read together with the NHI Bill? The White Paper stated that, as part of the transition process, medical schemes would play a supplementary role. Only when the NHI was fully implemented, would medical schemes offer complementary cover.

The Chairperson asked a question in relation to the HPA’s proposed wellness programme. Was it advocating for the wellness programme to be included in the Act? He asked the HPA to expand on this.

Currently, the medical schemes reimbursed for the products of the services delivered to the stakeholders. If so, how were these benefits determined currently? How was the wellness industry regulated?

HPA's response

Ms Gunkel-Keuler addressed the questions regarding the funding mechanisms and single exit price.

The HPA was suggesting that there was an opportunity to look beyond complementary and alternative medicines -- that provision had been cited under the definition of health-related products. This was an opportunity to expand the category as they knew it to be, as a system of healthcare in South Africa. It was about becoming aware of the other wellness contributors to the wellness paradigm, such as homeopathy, African traditional medicine, etc. It needed to be considered as an opportunity in time to come. The HPA was asking for greater inclusion in terms of the current understanding of wellness programmes and what could be added to this in the future, to make it more relevant to the country holistically.

The cost and funding of the NHI was a concern. The HPA agreed that medical aid rates were exorbitant and were ill-affordable, but by the same token there were many different ways that people paid for some level of insurance. This might be through a medical aid or a hospital plan. People were currently paying for something – it was an extensive sliding scale. There would clearly be costs associated with funding the NHI, given the status of unemployment in the country, particularly in light of the pandemic. It was something that the HPA, as a responsible association, was raising as a concern.

It noted the point about single exit prices. The HPA had raised the issue in relation to CAMS products that were registered through the South African Health Products Regulatory Authority (SAHPRA). Those products were now classified as medicines, and therefore fell under the banner of single exit prices. Given the current construct of the wellness market, it became difficult for member companies to go through a single exit price process because their products, or a certain part of their products, were now categorised as medicines, and not as a food, health or dietary supplement.

Ms Maria Ascencao, Chairperson of the HPA, spoke about the wellness paradigm and preventative healthcare. Food, dietary or health supplements were part of a global trend which was backed by science in an increasingly valuable sector of good health and lifestyle practice adopted by many citizens globally and in South Africa. This was done in order to keep their personal healthcare costs down and to live more healthily. It had become an entrenched understanding that one could actually take good care of one's own health, and this information had come to the fore through the growth of the internet and the increasing focus on wellness. There was awareness about not only supplementation, but other lifestyle adaptations such as the correct diet, stress management, personal growth etc.

Scientific data put together by the Council for Responsible Nutrition, based in the USA and Europe, took interest in ensuring the scientific and practical adaptation of supplementation for a global population. Recently, the Council undertook a study, through an independent organisation called Frost and Sullivan, which had measured health cost savings through various supplementations, such as calcium and vitamin D, in the European Union, as this was a focused area where 500 million people lived. The benefits of vitamin D and calcium supplements was established in that the burden of osteoporosis-attributed bone fractures in the European Union were predominantly prevented, and the development or progression of the disease was slowed. Likewise, they had explored the phytosterol food supplements in the European Union, where botanicals products such as St Johns Wort were considered, and how they reduced certain conditions, resulting in huge cost savings.

The European Union had adopted a national health system in every country, and valued research on preventative methods. One of the things that had become age-related was macular degeneration, which was attributed to vision impairment, and how the benefits of lutein supplementation prevented it and retarded the progression of the disease. There were many more examples of this.

All supplements were not patented or chemically synthesised in a laboratory, nor targeted at a disease such as cancer. The vitamin extracts, amino acids, omegas etc, had been shown to contribute to better health on a preventative healthcare level. Many South Africans had taken the decision to adapt a healthy lifestyle to keep medical aid costs down. Many had chosen to have only a hospital plan, because that was what many could afford. Everything else focused on preventative healthcare. For example, up to 80% of South Africans looked to African traditional medicine for their primary healthcare needs. All of these supplements were in a free-market system, with no patents. By virtue of the fact that vitamin C, for example, was an ingredient from nature, and anyone could access it, it automatically kept the price down.

Ms Janet Welham, Technical Consultant at the HPA, responded to the question regarding the expansion of the wellness progamme. The HPA had the expertise to add real value in the expansion of such a wellness programme and how it could integrate into the NHI, and would welcome further dialogue in this regard.

There was a concern relating to the current regulation of the industry, as the definition of a medicine had expanded to include what was broadly known in South Africa as complementary medicines. This included health supplements, which in the rest of world were seen as food supplements, but in South Africa were deemed to be medicines. As such, all of the allopathic medicine requirements were being put on as a requirement for these products. It was starting to influence their availability and accessibility to the consumer.

Follow-up question

Mr Munyai asked whether the HPA’s members were prescribers of these products. How would an ordinary person diagnose these conditions? Was the HPA recommending that all South Africans should consume these products for prevention? How did it propose that the NHI should pay for these products?

HPA's response

Ms Ascencao said the reality was that in South Africa there were many people with malnutrition – there were insufficient vitamins in the food chain to sustain good health. The HPA was extremely supportive of a plan going forward, where it could assist with supplementing the millions of South Africans who were malnourished. There had been discussions between the HPA and government on how to assist South Africans with supplementation. Food fortification and better eating proposals had been explored, which was a challenge where there were economic constraints. The HPA was open to an ongoing partnership with government to look at how wellness could be maintained under the NHI in terms of supplementation. There were a number of courses that had been started to train and educate people in South Africa about supplementation, and how that improved health. There needed to be collaboration with the government, and policies that enabled the industry to unlock its potential for good health of the population. In South Africa there was the Allied Health Professions Council, that represented practitioners in the wellness industry, i.e nutritionists. Collaboration was required. 

Mr Steve Parker, Committee Member of the HPA, said that global manufacturers considered matters with a global perspective. There was no doubt that complementary products were very necessary to assist the general population to remain healthy without burdening the state. Health supplements were referred to as such in virtually every country in the world, but in South Africa the industry was becoming more and more regulated and it was harder to manufacture products and make them freely available to the public, because they were being termed medicines. This was something that the industry was engaging with SAHPRA on.

The industry could go a long way in assisting South Africans at all socio-economic levels to remain healthier, to be more prepared for global pandemics and chronic illnesses etc. Very little cost was involved when compared to becoming chronically or acutely ill and having to then enter the orthodox treatment processes which weighed heavily on the state.

The meeting was adjourned.


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