SI 330: Fix the problem without breaking the system

Zimbabwe’s proposed medical aid reforms raise a fundamental question: can the problems in healthcare financing be addressed without creating new risks for patients, workers and existing services?

Regulating healthcare is necessary. But before changing who can own and operate healthcare facilities, Government must answer a more fundamental question: what problem is the proposed reform intended to solve, and what evidence shows that the chosen remedy will solve it?

That is the question at the heart of the debate over amendments to Statutory Instrument 330 of 2000, which governs medical aid societies.

The case for reform cannot simply be dismissed. Concerns about conflicts of interest, pricing, governance and the relationship between financing healthcare and providing treatment deserve serious attention. Medical aid members need transparency, fair treatment and protection from practices that undermine their interests.

Regulators may also argue that separating the financing of healthcare from its delivery can reduce conflicts of interest and improve accountability. That case deserves examination. But so do the costs, risks and practical consequences of enforcing such a separation.

A policy should be judged not only by the problem it identifies, but also by the consequences of the solution it proposes.

If the proposed changes restrict medical aid societies from owning or operating healthcare facilities, the implications extend beyond the institutions directly affected. They touch on clinics, pharmacies, laboratories, hospitals, employment, investment and patient access.

These are not minor administrative details. They are central to whether healthcare reform works in practice.

Consider the practical questions. If an existing facility must be sold, who will acquire it? Will the buyer have the capital and capacity to continue operating it? What happens to its employees, its patients and its existing service arrangements? Could the transition affect prices or access? And what safeguards will ensure that essential services remain available?

These questions do not establish that the proposed reforms will necessarily cause disruption. They establish why a credible impact assessment is needed before conclusions are drawn.

The same standard must apply to the concerns motivating reform. If ownership arrangements create conflicts of interest, regulators should identify where those conflicts arise, how they affect patients and what safeguards would address them. If there are concerns about market power, pricing or referrals, the evidence should establish their nature and extent.

Ownership alone cannot answer every question about conduct. Equally, the existence of an integrated healthcare model should not exempt an institution from scrutiny.

The challenge is to distinguish between a structure that creates an identifiable risk and a practice that causes demonstrable harm. Effective regulation needs to understand both.

Follow the money — and the patient

Zimbabwe’s healthcare debate repeatedly returns to tariffs, affordability and the sustainability of service delivery.

Providers must meet the costs of staffing, medicines, equipment, consumables, infrastructure and quality assurance. Medical aid societies must manage members’ contributions and claims. Patients need care they can afford without facing unpredictable shortfalls.

These interests frequently collide.

When tariffs are disputed, the public deserves to know what lies behind the disagreement. What does it cost to deliver a particular service safely? How are those costs calculated? What role do inefficiencies, payment delays and administrative expenses play? How can prices remain affordable without making service provision financially unsustainable?

These are questions for evidence, transparent costing and structured dialogue — not assumptions about which side is right.

A properly constituted National Tariffs Liaison Committee could provide a forum for Government, medical aid societies, healthcare providers and technical experts to examine these issues. Its value would depend on a clear mandate, credible data, transparent procedures and a willingness to confront uncomfortable findings.

It should not become another table where stakeholders repeat their positions. It should help establish what the numbers actually show and identify practical areas for resolution.

Parliament must test the policy

The proposed SI 330 amendments have entered parliamentary scrutiny. The Portfolio Committee on Health and Child Care has considered submissions from the Association of Healthcare Funders of Zimbabwe, while the matter has also been taken up with the Portfolio Committee on Justice, Legal and Parliamentary Affairs, where questions of legality and the scope of delegated legislative authority have been raised.

Parliament’s role is not to accept one stakeholder’s argument simply because it is presented forcefully. Nor is it to dismiss concerns because they come from institutions whose interests may be affected.

Its responsibility is to test the evidence, examine competing positions and establish whether the proposed measures are lawful, proportionate and likely to achieve their stated objectives.

That requires hearing all relevant parties, including patients and medical aid members whose contributions ultimately finance the system.

It also requires distinguishing between claims about possible consequences and consequences that have been demonstrated. Predictions of job losses, higher costs or reduced access should be tested against credible evidence. So should assurances that the proposed changes will improve competition, accountability or patient protection.

Neither side should be allowed to substitute confidence for proof.

Reform must be measured by what changes for patients

Zimbabwe does not have the luxury of treating healthcare regulation as an abstract contest between institutions. The real test is what happens to the person who needs a consultation, a diagnostic test, medicine or surgery — and must find a way to pay for it.

A successful reform should strengthen accountability while protecting access to care. It should address conflicts of interest without overlooking other sources of market abuse. It should improve transparency without creating unnecessary uncertainty for existing services and investment.

That does not mean preserving every arrangement as it stands. Where evidence establishes that a practice is harmful, corrective action may be necessary. But where structural restrictions are proposed, their likely costs, benefits and alternatives should be examined with equal seriousness.

The choice should not be reduced to regulation versus no regulation, or reform versus resistance. The more useful question is whether the chosen intervention is the most effective and proportionate way to achieve the intended public benefit.

Government should explain the problem it is solving. Regulators should demonstrate the risks they have identified. Medical aid societies and healthcare providers should disclose the evidence relevant to their claims. Parliament should scrutinise the legal and practical implications. And patients should not be left out of the discussion.

The measure of SI 330 will not be how forcefully it regulates, or how fiercely it is resisted. It will be whether the final framework protects patients, strengthens accountability and supports a healthcare system capable of delivering safe, affordable and accessible care.

Zimbabwe does not have to choose between regulation and healthcare capacity. It must find a way to protect both. That is the test SI 330 must pass.

Nothando Ndlovu is a dedicated public health expert committed to improving health outcomes and advancing health equity in communities. With a strong background in disease prevention, health promotion, and community-based interventions, Nothando works at the intersection of research, policy, and practice to design solutions that truly meet people’s needs.