SAMED presented to the Portfolio Committee on Health (the Committee) on the National Health Insurance (NHI) Bill on 20 July 2021. SAMED opened the opportunity with an affirmation of its support for the National Health Insurance and its objectives. We agreed on the urgency of adopting this Bill and its effective implementation, however, engaged in an open and frank presentation on its current shortcomings and the unintended consequences it may have on the sustainable delivery of high-quality health care.
Represented by Marlon Burgess (SAMED Chair and Chair of the NHI Committee), Ruwaida Shaikh (Vice-chair of the NHI Committee) and Tanya Vogt (SAMED Executive Officer), we shared our desire to grow our industry so that we continue to provide innovative medical technologies, skills development opportunities, create more jobs and harness South Africa’s capacity to serve as a hub for medical technology in Africa. The presentation was informed by our wish to see a more enabling regulatory regime for our industry and the broader health care services sector. The presentation focused on the following key areas:
- Constitution and Legal framework
- Accreditation of MedTech suppliers
- Procurement, including HTAs
- Governance of NHI fund
A key observation on the Bill was that policy integration is essential to the successful implementation of NHI. The absence of alignment with the Constitution, the Public Procurement Bill and several other pieces of pending legislature would hamper the effective implementation of NHI. Legislating uncertainty would also risk delayed implementation and limited investment in the sector. SAMED called for engagement across ministries and agencies, between the private and public sectors, to ensure a strong framework that avoided litigation which would delay implementation and frustrate the process.
With respect to procurement, SAMED asked the Committee to consider that medtech is not a commodity. Medtech has a complex supply chain and many medtech suppliers are SMMEs that lack a national footprint. As a result, central procurement of medical technology poses significant disadvantages. SAMED proposed that the Committee consider a diversified supply chain with multiple and non-exclusive contracts and consider a pilot programme that could identify and address challenges before a national rollout.
SAMED posed that procurement best practice centres on a holistic definition of “value” and takes account of the lifetime benefit to the patient (not merely short-term), the benefit to healthcare professionals and broader efficiencies in the health system (better diagnosis, shorter admissions, fewer complications). SAMED highlighted that medtech procurement envisioned by the NHI needs to accommodate rapid innovation cycles with flexibility in procurement necessary for health systems to benefit from this innovation.
SAMED recommended to the Committee that the membership of the Benefits Advisory Committee, appointed by the Minister, must consist of persons with specialist knowledge of medical devices and IVDs in addition to the stipulated technical expertise. SAMED also asked the Committee to adopt the Open contracting data standard and maintain the CSD with input from SAHPRA on licensed companies in the future system to ensure only accredited suppliers are procured from.
SAMED addressed corporate governance concerns in the Bill and made several recommendations that provide independence of the Board, ensure continuity and mitigate against governance failure – especially in light of the recent scrutiny that had fallen on the Department of Health. SAMED advocated for a phased implementation through measurable milestones to ensure the successful implementation of the Bill.
SAMED concluded that it recognises the inequities of the current fragmented health care system and was an eager partner in the mission to improve the nation’s health care and achieve universal health coverage. We reiterated our commitment to building the required capacity and skills and finding ways to effectively address the health care needs of all South Africans.