The National Health Insurance (NHI) plan has inadequate provisions for medicines, posing a risk to everyone’s access to treatments, the Health Justice Initiative (HJI) lobby group has warned, pointing out that it is not clear on how patients will access medicines not covered by the NHI fund, and how sales of these drugs will be priced and regulated.
HJI founder Fatima Hassan said the issue had not been adequately thought through.
“The entire shift of our medicine selection, procurement and reimbursement system to NHI reimbursement has not been properly considered, potentially posing a great risk for the future of medicine selection and access in the country for all people,” she said.
The NHI Bill, currently before Parliament, entails centralising selection and procurement of medicines for patients under NHI, collapsing the two largely independent systems used in the public and private sector into an entirely new mechanism.
In the private sector, most medicines are funded by medical schemes, which pay in full for products listed on their formularies. Patients can also get non-formulary products, but often have to pay for these out of their own pockets. Non-medical scheme members also pay out of pocket for over-the-counter and prescription medicines bought at private sector pharmacies.
Private sector medicine sales are governed by the single exit price (SEP) regulations, which control the ex-factory price of drugs and the markups levied at every step on the supply chain from manufacturer to pharmacy checkout. These prices are publicly available, and the Health Minister controls annual increases.
In the state sector, the government issues tenders for medicines that are procured at these prices by provincial Health Departments. Provinces can also procure drugs off-tender.
Section 58 of the Bill says the system set out in the SEP regulations will be used under NHI, with manufacturers selling medicines to the NHI fund at prices published by the office of health products procurement.
In a discussion paper released on Monday, the HJI lobby group said the Bill also does not deal with weaknesses in the SEP regulations, which do not control the launch price of medicines, reports Business Day.
The proposed exclusion of the NHI scheme from the jurisdiction of competition authorities and competition law is also problematic, as it would prevent the Competition Commission from investigating anti-competitive behaviour like collusion and excessive pricing, which pose a barrier to patients’ access to healthcare, according to the HJI.
It said this calls for urgent attention at the highest levels of the executive and the legislature, and is likely to need a multi-department and stakeholder technical group to determine the exact trajectory of this planned process.
Based on their analysis of the provisions in the NHI bill, the HJI wants the government to resolve 17 questions before implementing the Bill, reports Health-e News. Here are some of them:
• What measures will enable and promote public transparency related to medicine selection, procurement, and contracting processes under the NHI?
• How will the deliberations of the NHI ministerial advisory committee be made open to the public, and how will this information be shared?
• Not everyone living in SA will be regarded as a ‘user’ of the NHI fund. In these circumstances, will manufacturers be permitted to sell medicines to health providers other than the state? If so, how, and what will be the maximum price?
• Which medicines will automatically be covered under NHI benefits as part of the NHI formulary?
• Which medicines will not be covered under NHI benefits as part of the NHI formulary?
• Will wealthier people be able to bypass NHI selection and buy more expensive life-saving and other medicines on their own/with others where the state does not procure these?
• Many foreign migrants and South Africans without documentation will not be able to register as NHI users. How will people who are not registered NHI users be able to access basic healthcare services?
• How will the price of medicines not included in or covered by the NHI be regulated? And what will External Reference Pricing (ERP) methodology play in the NHI and beyond?
• When and how will the current Single Exit Price (SEP) system governing private sector medicine acquisition be amended and/or extended, and in what phases of the implementation process will this occur? How will dispensing fees be charged, and how will section 21 exemptions be managed?
Business Day PressReader article – Lobby warns of NHI risk to patients (Open access)
Health-e News article – NHI: New study raises 17 critical questions
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