quest to find common ground with a medical profession fiercely opposed to the
regulation of medical practitioner fees, the Health Professions Council of
South Africa (HPCSA) recently appointed respected healthcare actuary Shivani
Ramjee to assist with the process of setting a guideline tariff that can be
used to assess overcharging by medical practitioners.
member of the Actuarial Society of South Africa and head of actuarial science
at the University of Cape Town, says the absence of guideline tariffs for
medical and dental practitioners has created a problematic vacuum that leaves
consumers unable to prove accusations of overcharging by medical and dental
Professions Act makes provision for the establishment of a mechanism by which
the HPCSA can determine whether a medical practitioner overcharged a patient by
means of a “price norm”. However, this has yet to materialise. A previous
attempt to introduce guideline tariffs was aborted last year after medical
associations threatened legal action. The HPCSA stood accused of having set
guideline tariffs that were unreasonably low and calculated without scientific
enlisting the help of a healthcare actuary, the HPCSA is making sure that
future price norms will have a strong scientific basis.
setting of a norm will have financial implications for health professionals,
funders and the general public this process needs to be fair, rational and
lawful,” comments Ramjee.
guideline tariffs will only become a reality if the differing needs of all stakeholders
are met in some way.
tariffs must protect the right of medical practitioners to earn a fair living
and recognise the fact that their skills are scarce. A pricing norm must also
ensure the sustainability of private practice and ensure that the profession
remains attractive to new entrants.
on the other hand, are entitled to fair and reasonable fees. Equally important
is that patients are empowered to give informed consent based on transparent
the termination of last year’s guideline tariffs the HPCSA launched a
comprehensive public participation process to determine the guideline tariffs
that meet the requirements of medical practitioners as well as
more than 80 submissions were received from various interest groups including
medical and dental practitioners, professional bodies, consumer groups,
funders, administrators, individual patients and the Competition Commission.
Having analysed most of these submissions she noted that despite the divergent
views expressed, there were also areas where many stakeholders were in
Deep levels of mistrust
the sentiments expressed in the submissions also indicated that the highly
complex process of establishing guideline tariffs is further complicated by
deep levels of mistrust between stakeholders and conflicting views on what the
pricing norm should be.
out that practitioners are also very wary of guideline tariffs becoming medical
scheme reimbursement tariffs.
the complexities and emotions that have marred the process thus far there is
light at the end of the tunnel, according to Ramjee. “A meeting in April
attended by stakeholders who made submissions into the process was
unprecedented in that this was the first time that the various stakeholders
engaged constructively on the subject of tariffs.”
the analysis of the submissions made to the HPCSA and the feedback from the
stakeholder engagement, Ramjee says the next step is to design a process that will
be used to determine the final numbers that will make up the guideline tariffs.
believes that there are two possible broad approaches to determining a fair
- Option 1: An administrative norm
determination process whereby an expert committee decides on an
appropriate guideline tariff based on information and evidence submitted
and appropriate consultation with all affected parties.
- Option 2: A negotiated norm
determination process whereby all affected parties are involved in the
decision making process. If no consensus can be reached an impartial
expert committee decides based on the information supplied by the parties
to the negotiation process.
says Ramjee, both approaches support decisions being made based on the basis of
- (Actuarial Society of South Africa press release)