Social Security Commission National Medical Benefit Fund Actuarial Report on the Design of the NMBF – Final draft Actuarial & Analytical Solutions (A&AS) at Deloitte July 2012 0|Page Contents Executive Summary ...................................................................................................................................... 3 1. Introduction ........................................................................................................................................ 9 2. Legal Framework for the NMBF ....................................................................................................... 11 3. 4. 2.1 Social Security Act .................................................................................................................. 11 2.2 Constitution ............................................................................................................................. 16 Health Insurance Models and Funding Models ............................................................................... 17 3.1 National Health Insurance (NHI) Model .................................................................................. 17 3.2 Bismarck Social Health Insurance (SHI) Model ..................................................................... 17 3.3 Beveridge Model ..................................................................................................................... 18 3.4 Out-of-Pocket (OOP) Model ................................................................................................... 18 International literature and country experience ............................................................................... 20 4.1 The Advantages and Disadvantages of NHI .......................................................................... 20 4.2 The Advantages and Disadvantages of SHI (Bismarck model) ............................................. 20 4.3 The Advantages and Disadvantages of the Beveridge Model ............................................... 21 4.4 Achieving Universal Coverage ............................................................................................... 22 4.5 Implementation of SHI: Lessons Learnt ................................................................................. 23 4.6 Country experience within the informal sector ........................................................................... 34 5. 6. 7. Collection Methods .......................................................................................................................... 36 5.1 Tax collection system in Namibia ........................................................................................... 36 5.2 Current collection methods by medical aid schemes ............................................................. 37 Demarcation between Health Insurance and the NMBF ................................................................. 39 6.1 Health insurance vs. medical aid ............................................................................................ 39 6.2 Demarcation in Namibia ......................................................................................................... 39 6.3 What does this mean for NMBF? ........................................................................................... 40 Overview of the Healthcare Environment in Namibia ...................................................................... 41 7.1 Overview ................................................................................................................................. 41 7.2 Public Sector........................................................................................................................... 42 7.3 Private Sector ......................................................................................................................... 42 8. Policy objectives of the NMBF ......................................................................................................... 45 9. Situational Analysis for SHI ............................................................................................................. 47 9.1 Payroll Deduction i.e. Employee Taxation .............................................................................. 49 9.2 Unemployment........................................................................................................................ 49 9.3 Labour market structure ......................................................................................................... 50 9.4 Burning health priorities and need: curative care or basic preventative care and health promotion? ....................................................................................................................................... 50 9.5 Projected GDP growth ............................................................................................................ 52 1|Page 10. Design Considerations for the NMBF .............................................................................................. 54 11. Macro-economic factors impacting the NMBF ................................................................................. 76 11.1 Population Demographics ...................................................................................................... 76 11.2 Economy ................................................................................................................................. 78 11.3 Other influences...................................................................................................................... 79 11.4 Social trends and technology ................................................................................................. 80 12. Administration of the NMBF ............................................................................................................. 81 12.1 Technical requirements .......................................................................................................... 81 12.2 Model options ......................................................................................................................... 83 13. Investment Strategy ......................................................................................................................... 87 14. Stakeholder considerations ............................................................................................................. 88 15. Design of the NMBF......................................................................................................................... 91 15.1 Overview: Defining a target population .................................................................................. 91 15.2 Estimating the covered population size and profile ................................................................ 95 15.3 Membership Options ............................................................................................................ 103 15.4 Actuarial costing of benefit packages ................................................................................... 106 Data received ....................................................................................................................................... 107 “Hospital” benefit package ................................................................................................................... 108 “Hospital + Day to Day” benefit package ............................................................................................. 111 Benefit package and membership base combinations: Risk Matrices ................................................ 116 Limitations and considerations:............................................................................................................ 123 16. Conclusions and Recommendations ............................................................................................. 127 16.1 The enabling legal framework for the NMBF ......................................................................... 127 16.2 Health insurance models ....................................................................................................... 127 16.3 International experience with SHI .......................................................................................... 128 16.4 Collection methods for the NMBF .......................................................................................... 128 16.5 Legislative considerations: NMBF Target population ............................................................ 129 16.6 Benefit package recommendations ....................................................................................... 130 16.7 A phased implementation approach ...................................................................................... 131 Bibliography .............................................................................................................................................. 133 Annexure A: Population groups ................................................................................................................ 134 Annexure B: PSEMAS subsidy ................................................................................................................. 138 2|Page Executive Summary The Social Security Act, No. 34 of 1994, paved the way for the establishment of a National Medical Benefit Fund (NMBF) to provide for the payment of medical benefits to employees. Actuarial and Analytical Solutions (A&AS) at Deloitte have been appointed by the Social Security Commission of Namibia to assist with the design and development of the National Medical Benefit Fund of Namibia. This report is a comprehensive consolidation of strategic research, health care expertise and actuarial analysis conducted in the following four broad areas that define the scope of work concerned: Policy Framework: An analysis of the enabling legal framework for the NMBF; a basic review of other social security provisions in Namibia; a literature review on international health insurance practice and experience; as well as potential policy objectives for the NMBF. Namibian Medical Insurance Market Status The current healthcare environment of Namibia is analyzed in order to understand the role that the NMBF would play in this environment; its interaction with the current healthcare provisions; the possible membership of the fund and the macro-economic and general implications of the fund. NMBF Design and Actuarial Review This area requires comprehensive research and analysis on the possible design and structure of the NMBF, including funding options and the form of the benefits to be provided. This section also required the determination and recommendation of a reasonable and appropriate contribution structure and benefit package for the NMBF. Administration and Stakeholder Engagement The possible administration models for the NMBF and the identification and assessment of the various stakeholders that will be impacted by the NMBF. The results of this comprehensive undertaking of research and analysis are provided in this report, the main findings of which are presented below. Report Findings The enabling legal framework for the NMBF is enshrined in the Social Security Act of 1994. The Social Security Act 34 of 1994 provides for the establishment, constitution, powers, duties and functions of the Social Security Commission. The Act paves the way for the establishment of a National Medical Benefit Fund (NMBF) which is to provide for the payment of medical benefits to employees. 3|Page Section 20 (1) of the existing Social Security Act firmly defines the envisaged target population for the NMBF as follows: • The NMBF requires registration of every employee of every employer • “Except if he or she is a member of any other medical aid fund or scheme approved by the Minister on recommendation of the Commission” The Act - with the exception of Parts VI (National Medical Benefit Fund) and VII (National Pension Fund) - came into force on 15 January 1995. The NMBF is yet to be implemented and hence, the consideration of its design and funding options is presented in this report. Research into health care funding models revealed that there are four main models namely the: 1. National Health Insurance (NHI) model, 2. Bismarck Social Health Insurance (SHI) model, 3. Beveridge model, and 4. Out-of-Pocket model. The NMBF is intended to ensure that all employed persons are members of a medical fund. Based on the literature review of international experience the objectives of the NMBF are consistent with the Bismarck Social Health Insurance (SHI) model where all employed persons form part of a prepaid health arrangement. . It is therefore distinct from more universal health systems such as National Health Insurance which is extended to the unemployed population, and in which all have access to healthcare facilities and services irrespective of ability to pay. A detailed literature review of international experience was performed, illustrating the path to achieving universal coverage, as well as important lessons that have been learnt from such experience. SHI was found to be one of the main funding models used for healthcare financing. Many SHI initiatives have taken place in Africa, Asia, and Latin America. A total of twenty seven countries have introduced the overriding principle of universal coverage via SHI (Hsiao & Shaw, 2006). The following factors were found to contribute positively to an enabling environment for SHI: • • • • • • • • Large formal sector employment High wages and salaries Low poverty rate Small family and/or household size Efficiently functioning provider networks Strong human resource capabilities Strong administrative support Government capacity to regulate (Hsiao & Shaw, 2006) Possible collection methods for NMBF contributions were identified. The contributions could be funded via income tax. The Namibian tax system has undergone continuous reform since independence which has brought about numerous improvements. The tax system is perceived to be equitable and transparent, and after the introduction of the value-added tax in November 2000, tax collection has significantly improved. Countries who have implemented Social/National Health insurance typically have a considerably higher total tax rate. If Namibia is to fund the NMBF through taxes it may need to increase the tax rate to accommodate this. However this will have many other implications that will need to be considered such as the effect on GDP and economic growth. Alternatively the government may need to redistribute the current budget in which tax is currently being utilized. 4|Page A further consideration for the NMBF is how contributions will be collected via individuals and/or employers. If government fails to collect contributions successfully, they will not be able to cover the claim costs and expenses needed to support the fund. It is recommended that the NMBF, should they chose to use contributions collected from employers/individuals in order to fund the scheme, use a similar method as the one used in South Africa, whereby all employed individuals must have medical cover, and contributions are collected via employers or direct debit orders. The collection of contributions from the self-employed, however, will be more challenging due to the variability of the income, the inability to verify the accuracy of the income stipulated, as well as the difficulty in locating the self-employed. Medical aid funds in Namibia are required to comply with the Medical Aid Funds Act, No 23 of 1995 and the regulations of 11 February 1997, and are governed/ regulated by NAMFISA. Health Insurance is classified as short term insurance in Namibia and therefore falls under the Short-term Insurance Act, No 4 of 1998, but is also governed/regulated by NAMFISA The NMBF will act as a medical aid fund rather than provide health insurance and will therefore need to comply with similar provisions to those stipulated in the Medical Aid Funds Act. It will be exempt from the Medical Schemes Act (Act 72 of 1967), except in so far as the Minister determines otherwise (as laid out in the Social Security Act). An overview of the current healthcare environment in Namibia revealed that the Namibian government is the main provider of healthcare services in Namibia, with the private sector and mission facilities playing supporting roles. The medical aid fund population is dominated by the Public Service Employees Medical Aid Scheme (PSEMAS). This is a state run scheme, exempt from the Medical Aid Funds Act, with approximately 80 000 principal members and is open to civil servants only. PSEMAS accounts for over 50% of the medical scheme principal member population, with the other schemes consisting of above 60 000 principal members. The total number of beneficiaries covered by medical schemes, including PSEMAS, was approximately 320 000 people during 2010. Given that the total population in 2010 was estimated by the US census bureau to be approximately 2 million, this implies that approximately 1.68 million uncovered Namibians are forced to make use of public health facilities where an out-of-pocket method of payment is required. The possible policy objectives of the NMBF include: Accessibility (Increasing the proportion of the population that reaches appropriate health services.) Financial accessibility Geographical accessibility Universal access to health care Universal coverage Equity in health care Equity in health financing Equity in resource allocation Quality in health care Responsiveness in health care Sustainability Protect the nation’s health 5|Page Key design requirements that should be considered for the design of the NMBF were identified as: Maximizing the overall percentage of population covered by SHI Maximizing the overall percentage of population covered by SHI, by target group Setting the ratio of prepaid contributions to total costs (i.e. the overall prepayment ratio) of the SHI benefit package at an acceptable rate Setting the prepayment ratio by target group, at acceptable levels Minimizing the percentage of households with catastrophic spending Minimizing fragmentation of the NMBF pool Making membership compulsory If the NMBF is going to be priced on solidarity principles, then legislation is required which also imposes such cross-subsidies from rich to poor on all existing open and closed funds to limit anti-selection on the NMBF. Ensuring the effective collection of finances The benefits package should adhere to certain broad principles Monitoring mechanisms associated with the benefits package should be put in place Minimizing risks, legal contracts between the NMBF and its providers need to be welldefined. Ensuring that the mix of reimbursement methods promotes optimal resource allocation Minimizing the percentage of total expenditure on administration expenses Ensuring that an effective governance structure is put in place The technical requirements for the administration of the fund include: Correspondence management services Membership management services Claims management services Financial management services The following administration models exist which could be used by the NMBF: Agency Model (Outsourcing the administrative function) Self-Administration A combination of the above A “phased-in” approach (Moving from an outsourced position until eventually successful selfadministration is possible) However, the Social Security Act of 1994 contains two stipulations which may prohibit, or restrict, the extent to which outsourcing of the administration system is permissible: “15. (1) Every person engaged in carrying out any provision of this Act shall preserve and aid in preserving secrecy in relation to all matters that may come to his or her knowledge in the exercise of the powers or the performance of the duties and functions conferred or imposed upon him or her in terms of any provision of this Act, and shall not communicate any such matter to any other person or permit any other person to have access to any documents in his or her possession or custody, except in so far as any such communication (a) is made in the ordinary course of the exercise of his or her powers or the performance of his or her duties under this Act or any other law, or is required by an order of a competent court; (b) is effected with the prior permission in writing of the person concerned.” “16. (1) The Commission shall, in accordance with sound business principles, administer every fund referred to in paragraph (a) of subsection (1) of section 9.” It is recommended that legal advice is obtained before embarking on an outsourcing strategy which may be in contravention of the above stipulation. Furthermore, clarity on the scope for any such outsourcing activity permissible under the act should be obtained. 6|Page The following parties were identified as direct stakeholders in the NMBF with due consideration: Social security commission Ministry of Health and Social Services NAMFISA PSEMAS Ministry of Labour Employers Taxpayers In the absence of previous empirical studies regarding the uncovered population, Deloitte estimated the uncovered tax paying population (who would be principal members on a medical fund) to be approximately 115 938. This estimated population exhibits a moderately young age profile. Additionally, upon analysis of the medical scheme industry data including an appropriate adjustment to reflect 2012 numbers, the medical scheme industry comprises of 149 696 principal members. The results of the actuarial costings undertaken showed the expected costs per family per month for three different benefit packages as at the beginning of 2012: a Hospital benefit package at N$ 1196.68; a Hospital + Day-to-Day benefit package at N$ 2535.78 and the PSEMAS package at N$ 998.46. These costs were appropriately adjusted to reflect the expected costs under implementation of a number of different possible NMBF target populations. Conclusions and recommendations This report analyzed various benefit packages and membership base combinations, however the optimal combinations are highly dependent on the interpretation of the Social Security Act and the financing constraints of the NMBF. This report therefore considered a variety of outcomes and commented on their relative merits and possible restrictions: Benefit package: Affordability The “Adjusted PSEMAS” benefit package was found to be the superior option based on cost alone and is therefore the most applicable to the uncovered population which we assume to be on average poorer than the covered population. Benefit package: Public vs. Private The choice of sector will determine the funnelling of funds to health care facilities and this choice must be considered at a strategic level in terms of how the NMBF will improve both health infrastructure and access to healthcare for the target population while achieving goals on the NMBF. Target population According to the Social Security Act the target population is defined as all employed persons “Except if he or she is a member of any other medical aid fund or scheme approved by the Minister on recommendation of the Commission”. (SSA, Section 20 (1)) This report considered various interpretations of whether or not PSEMAS can be considered a medical fund and therefore whether it will form part of the NMBF. 7|Page Scenario: PSEMAS is classified as a medical fund The resultant target population (the uncovered taxpayers) was found to be the least sustainable group from a design perspective, however the easiest to implement given the lack of any reform required. Scenario: PSEMAS is not classified as a medical fund This target population extends from the uncovered to include PSEMAS lives. Based on a risk analysis it was found that this group would be a superior option to the above (i.e. Uncovered population) due to a larger risk pool and the opportunity to reform PSEMAS into a more financially sustainable structure. However there is likely to be resistance from both employee’s and unions if the benefit and subsidization arrangements are reduced to become more financially sustainable. Scenario: Legislation is revised and medical scheme members are no longer excluded This target population was found to be the best option purely from a design perspective as it represents the largest risk pool (the entire taxpaying population), has extensive scope for risk and income cross-subsidisation, eliminates buy-down risk (cross sector) which serve to reduce the financing requirement and contribution rates. However the need to reform both the medical fund industry and PSEMAS as well as a need to revise the legislation may make this option practically unviable. A phased implementation approach Implementing the NMBF at its full membership base level from the outset faces many practical problems and leaves little room for error in terms of administration systems, pricing correctly, collecting contributions and taxes and ensuring optimal service delivery of benefits. It is therefore recommended that a phased approached be adopted by gradually adding various population subgroups until the target population is reached and the legislation’s objectives are met. 8|Page 1. Introduction Background The Social Security Act, No. 34 of 1994, paved the way for the establishment of a National Medical Benefit Fund (NMBF) to provide for the payment of medical benefits to employees. Actuarial and Analytical Solutions (AAS) at Deloitte have been appointed by the Social Security Commission of Namibia to assist with the design and development of the National Medical Benefit Fund of Namibia. Scope of work This report is a comprehensive consolidation of strategic research, health care expertise and actuarial analysis conducted in the following four broad areas that define the scope of work concerned: Policy Framework: This section of the deliverable involves an analysis of the enabling legal framework for the NMBF; a basic review of other social security provisions in Namibia; a literature review on international health insurance practice and experience; as well as potential policy objectives for the NMBF. Namibian Medical Insurance Market Status This section explores the current healthcare environment of Namibia to understand the role that the NMBF would play in this environment; its interaction with the current healthcare provisions; the possible membership of the fund and the macro-economic and general implications of the fund. NMBF Design and Actuarial Review This section consists of comprehensive research and analysis on the possible design and structure of the NMBF, including funding options and the form of the benefits to be provided. This section also required the determination and recommendation of a reasonable and appropriate contribution structure and benefit package for the NMBF. Administration and Stakeholder Engagement This section looks at possible administration models for the NMBF and the identification and assessment of the various stakeholders that will be impacted by the NMBF. The results of this comprehensive undertaking of research and analysis are provided in this report, the sections of which are outlined below. Report Structure Section 2 of the report explores the enabling legal framework for the NMBF and other social security provisions in Namibia. This is followed by an overview of the four main models of health care funding in Section 3. 9|Page Section 4 provides a detailed literature review of international experience, the path to achieving universal coverage, as well as important lessons that have been learnt from such experience. Possible collection methods for NMBF contributions are then explored in Section 5. The demarcation between the NMBF and health insurance is provided in Section 6 followed by an overview of the current healthcare environment in Namibia in Section 7 that includes both public and private sector provisions, as well as the medical scheme environment. The possible policy objectives of the NMBF are defined in Section 8. Section 9 provides a situational analysis for SHI in Namibia by assessing certain criteria that would support the development of SHI. This is followed by key design features that should be considered for the design of the NMBF in Section 10 as well as macro-economic impacts of the NMBF in Section 11. The technical requirements and options for the administration of the fund, investment considerations and stakeholder considerations are then discussed in Section 12, 13 and 14 respectively. Finally, Section 15 details the methodology applied and results obtained from the actuarial costings performed which includes the proposed benefit package, the determination of the target population for the NMBF as well as the assumptions used and limitations faced in conducting these analyses. The Namibian healthcare environment is defined by unique characteristics that need appropriate attention for the implementation of Social Health Insurance and for overall health care reform. This report provides the Social Security Commission with insights and tools to effectively implement these reforms by drawing from international experience and actuarial expertise. Limitations This report has been prepared for the exclusive use of the Social Security Commission of Namibia. This report should be considered in its entirety, as parts taken out of context may be misleading. Any third parties reading this report may not have the background information necessary for a full understanding of the report. The actuarial costings performed for the determination of contribution rates for the NMBF were restricted by the limited data available. This data was neither audited nor verified other than performing standard checks on the data. These limitations are discussed in the report and should be taken into consideration when examining the results thereof. The accuracy of the calculations is therefore impacted by these limitations. 10 | P a g e 2. Legal Framework for the NMBF The purpose of this section of the report is to explore and analyse the enabling legal framework for the NMBF. The Social Security Act (which pertains to the achievement of SHI), and the Constitution (which would be the starting point for paving the way for NHI), will be investigated. 2.1 Social Security Act The Social Security Act 34 of 1994 provides for the establishment, constitution, powers, duties and functions of the Social Security Commission. The Act paves the way for the establishment of four social security funds namely: Maternity Leave, Sick Leave and Death Benefit Fund: to provide for the payment of maternity leave benefits to female employee members, sick leave benefits to all employee members, and death benefits to dependants of all employees, subject to the provisions of the fund. Development Fund: to provide for the funding of training schemes for disadvantaged persons, employment schemes for unemployed persons, bursaries, and other forms of financial aid. National Pension Fund: to provide for the payment of pension benefits to retired employees, subject to the rules of the fund. National Medical Benefit Fund (NMBF): to provide for the payment of medical benefits to employees. The Act - with the exception of Parts VI (National Medical Benefit Fund) and VII (National Pension Fund) came into force on 15 January 1995. The Social Security Commission (SSC) is currently administering the first two of the funds listed above. The NMBF is yet to be implemented and hence, the consideration of its design and funding options is presented in this report. It is important to understand the key features of the Act in order to properly frame the design of the NMBF, and to understand how the establishment of the NMBF will impact the other three funds. The key general provisions of the Social Security Act with respect to the NMBF are: The Act applies to every employer, including the State, and every employee The assets and liabilities of every fund shall be valued at such times as may be considered necessary by the Commission, but at least once every three years by an actuary appointed by the Minister of Labour and Human Resources Development; Every employer and employee must be registered with the Commission, in the prescribed manner and within the prescribed period A self-employed person who does not employ any other person may, in the prescribed manner, voluntarily register with the Commission Every employee registered with the Commission shall be a member of: o the Maternity Leave, Sick Leave and Death Benefit Fund o the National Medical Benefit Fund, except if he or she is a member of any other medical fund or scheme approved by the Minister on recommendation of the Commission o the National Pension Fund, except if he or she is a member of any other pension fund or scheme approved by the Minister on recommendation of the Commission Different contributions may be prescribed in respect of different categories of employers or employees 11 | P a g e No claim for any benefit payable under this Act shall be considered by the Commission unless: o The person to whom such claim relates has been a member of the fund concerned for a continuous period of at least six months before the date on which such claim arose o All contributions payable in respect of his or her membership of such fund have been paid in full Authorized personnel are given the power to inquire and investigate the NMBF through auditing enterprise accounting and registration systems, and enterprise facilities No benefits payable, or any right to such benefits, shall be capable of being assigned, transferred, ceded, pledged or hypothecated, or be liable to attachment or any form of execution under any judgement or order of any court of law The Commission may at any time, but only after the person concerned has been notified and granted an opportunity to be heard, review any benefits granted and payable to any person if: o Upon the request of the Commission, he or she refuses or fails without sufficient cause to submit himself or herself to a medical examination o In the case of a person receiving maternity leave, sick leave or medical benefits, such person has become: Addicted to Intoxicating liquor or any dependence-producing substance or uses such liquor or substance excessively Mentally or physically disabled to such extent that he or she is unable to care for himself or herself or the child concerned o In the case of a person receiving sick leave or medical benefits, he or she refuses or fails without sufficient cause to submit himself or herself to medical or surgical treatment when considered necessary by the Commission; and in the opinion of the Commission, such refusal or failure is prolonging or aggravating the condition as a result of which the benefits have been granted to such person o Such benefits, if payable by way of instalments, have due to altered circumstances become either insufficient or excessive to meet the circumstances of the case o Such benefits, due to mistake or misrepresentation, have been incorrectly granted or granted in a wrong amount We will now discuss the specifics of each fund as prescribed by the Social Security Act. Maternity Leave, Sick Leave and Death Benefit Fund The Fund is mandated, subject to the provisions of the Act, to provide the following benefits to members of the Fund: maternity leave benefits to every female employee sick leave benefits to every employee death benefits to the dependants of every employee Maternity benefits are payable in respect of both the four week period prior to the expected confinement date and the eight week period after the actual confinement date. The Act stipulates further conditions should the actual confinement date differ to the expected confinement date. Sick leave benefits shall be payable in respect of a member who was incapable for at least 30 consecutive days. These benefits are prescribed based on the number of days during which the member was absent from work through incapacity which exceed the number of days sick leave provided for in section 40 of the Labour Act. Sick leave benefits shall not be payable in respect of a period of sick leave which exceeds two consecutive years. The following items may be allowed for when determining the amount of sick leave benefits payable to a member: 12 | P a g e Any disability pension referred to in section 2 of the National Pensions Act, 1992 (Act 10 of 1992) Any compensation referred to in section 38 or 39 of the Employees' Compensation Act, 1941 Any compensation from a fund or organization contemplated in paragraph (a) of subsection (4) of section 40 of the Labour Act Any compensation or remuneration (i.e. basic wage, salary, or commission earned by the member) from his or her employer If the dependant entitled to a death benefit is a minor, then the death benefits will be paid to his or her guardian or to any other person who is considered by the Commission to be a fit and proper person to administer such benefits on behalf of the dependant. If a member retires or becomes permanently disabled, then the full value of the death benefits which would have been payable had the member died on the date of his or her retirement shall be paid to him or her and no further benefits shall be payable. If a member dies without leaving any dependants, then the death benefits shall be paid into his or her deceased estate. Development Fund It is important to note that a portion of the prescribed contributions payable to the NMBF fund may be paid into the Development Fund, in accordance with Section 37 of the Social Security Act: (3) There shall be paid into the Fund – (a) such portion of the prescribed contributions payable to any other fund as may be determined by the Commission with the concurrence of the Minister Therefore, this provision may increase the cost of contributions to the NMBF. The Development Fund provides benefits in respect of: The conducting of training schemes and employment schemes approved by the President for the benefit of socio-economically disadvantaged persons who are unemployed; The granting of bursaries, loans, and other forms of financial aid to students enrolled at any technical or academic institution of higher education. National Pension Fund The National Pension Fund has not currently been implemented. The Pension Funds Act (Act 24 of 1956), shall, except in so far as the Minister determines otherwise by notice in the Gazette, not apply to the Fund. The Fund pays pension benefits in respect of retirement, permanent disability and death. National Medical Benefit Fund The National Medical Benefit Fund has not currently been implemented. The National Medical Benefit Fund will aim to provide medical benefits to every employee who is a member of the fund and who has complied with the terms of membership. These terms state that 13 | P a g e members should belong to the fund for at least 6 months and that contributions to the fund should be upto-date. Only under these conditions will members be eligible for receipt of any benefits from the NMBF when claims are incurred. Critically, Section 20 (1) of the existing Social Security Act firmly defines the envisaged target population for the NMBF as follows: The NMBF requires registration of every employee of every employer “Except if he or she is a member of any other medical aid fund or scheme approved by the Minister on recommendation of the Commission” The establishment of the Fund dictates that the Fund shall be a juristic person. Furthermore, the following items will be paid into the Fund: The prescribed contributions payable to the Fund The moneys appropriated by Parliament for the purposes of the Fund Any interest or dividend earned Any fines paid by virtue of penalties imposed under this Act in respect of an offence involving the Fund Any other moneys which may accrue from any other source The Medical Schemes Act (Act 72 of 1967), shall, except in so far as the Minister determines otherwise by notice in the Gazette, not apply to the Fund. The medical benefits payable in respect of medical expenses incurred by a member, shall be as prescribed. Given that the Fund has not yet been established, this provision allows for the definition of a specified benefits package. Regulations The Act allows for the establishment of further regulations in relation to: Entering into agreements, handling of funds, and keeping of books by the Commission. This is a useful provision for the NMBF since alternative provider reimbursement methods may need to be agreed, and governance rules surrounding the management of the fund may need to be set up. Regular monitoring of claims and membership experience is made possible by the above provision. Except as otherwise provided by this Act, any fees, contributions or benefits payable under the Act. This is a useful provision for the NMBF as the benefits package, which still needs to be defined, will drive costs, which will in turn drive contributions. The setting of benefits and hence contributions is made possible by the above provision. The form of the registrars and certificates to be kept or which may be issued in terms of the Act. This provision allows the NMBF to contract with providers for the formation of pre-specified provider networks. The procedure to be followed in the submission of claims and the requirements with which claims should comply. This provision allows the NMBF to set rules to minimise claims processing delays, and set benefit conditions and rules to minimise risk and potential fraud. The manner in which the Commission may execute or perform any power, duty or function in terms of the Act. This provision is open ended and the Fund could potentially create a regulation relating to any area as deemed fit, for example, providers, members, existing insurers, etc. The management and control of any fund established by the Act. This provision allows for the introduction of inter alia, a regular analysis and reporting requirement, and a new governance structure. 14 | P a g e All other matters in general which are by the Act required or permitted to be prescribed or which are necessary or expedient to be prescribed in order to achieve the purposes of the Act. Once again, this is an open ended provision. Essentially, this provision paves the way for any NMBF design feature that is deemed necessary and appropriate to achieve the aims of the Act. For example, the establishment of procedures to collect contributions that are essential to help ensure the sustainability and solvency of NMBF, can potentially become law by virtue of this provision. Furthermore, these procedures can be set up in a manner which appropriately acknowledges the exchange of sensitive data. Any existing or future regulation may prescribe a fine not exceeding N$2 000, or imprisonment for a period not exceeding six months, as a penalty for the contravention of such regulation. Overall Assessment The Social Security Act provides the platform for the development and implementation of the NMBF in line with Namibia’s health and social security policy objectives. It is therefore important that this Act contains all the required supporting legislations and does not overlook any material requirement of the Fund. If SHI is to work effectively, it is necessary to equip the SHI scheme with certain legal instruments to: implement compulsory membership - allowed for in theory since “every employer must register every employee” limit fraud - partially allowed for in theory through the use of checks on the operations of enterprises & the specification of penalties (fine or imprisonment) enforce the collection of contributions - allowed for in theory through the definition of penalties audit enterprise accounting and registration systems & to have access to facilities – allowed for in theory through a combination of inquiry, authorised personnel, and investigation provisions negotiate and enforce provider payments and to accredit providers - allowed for in theory through the Regulation section of the Act, which allows for the entering into any necessary agreements e.g. with providers, and the formation of certificates e.g. for accreditation of providers (Normand & Weber, 2009) The points below highlight potential gaps in the Social Security Act legislation that may constitute a risk to the successful implementation of the NMBF: The Fund’s exemption from income tax is clearly stipulated in the Act. However, SHI contributions should also be exempt from taxes because the NMBF is a social fund. The Act allows for dispute resolution through the labour courts, following an appeal made by a member regarding determinations made by the social security appeals board, as established by section 15(1)(a) of the Labour Act 1992, but not through a cheaper arbitration process: o The Labour Act has since been updated and the latest Act, the Labour act 2007 (Act 6 of 1992), makes provision for arbitration or dispute resolution. The Social security act should be updated to allow for the new Labour act and take advantage of the arbitration process enshrined therein. Accelerating disputes to the Labour court, without first attempting less time consuming and less costly channels of dispute resolution, such as via the ombudsman and an arbitrator, would be an unnecessary drag on resources and administrative efficiency within the SSC as well as for the SSC fund members. o Experience with both SHI and tax collection shows that if SHI related matters have to go to court for every fraud detected, this may hamper its effective enforcement, increase the costs associated with SHI and cause delays. 15 | P a g e o Medical benefits are heterogeneous in nature, subject to complex medical claims definitions, and are incurred frequently (in contrast to death benefits as per the other Funds under the Commission’s administration) Legislation in Namibia does not require medical schemes to operate on the basis of solidarity principles, resulting in many schemes making use of age-rated contributions. Thus, if the NMBF contributions incorporate a cross-subsidy from rich to poor, but not all private open medical funds do so, then the NMBF may be significantly selected against. The potential long-term objective of extending the SHI system to a NHI system: o International experience, as analysed in section 3 of this report, recommends an SHI strategy that is linked to a NHI strategy, assuming that NHI is on the agenda (Hsiao & Shaw, 2006). 2.2 Constitution Based on past Health Insurance workshops conducted in Namibia, and the subsequent establishment of the Health Insurance Funding and Technical Advisory Committee (HIFTAC), NHI is on the agenda in Namibia. However, it is worth noting that the Constitution of Namibia only allows for an indirect provision for NHI as opposed to a direct one. Therefore, NHI cannot be viewed as a Constitutional imperative in Namibia, as it is found to be in some countries. In Namibia, Article 95 on The Promotion of the Welfare of the People, paves the way indirectly for the implementation of NHI. Article 95 states that the State shall actively promote and maintain the welfare of the people by adopting, inter alia, policies aimed at the following: (a) enactment of legislation to ensure that the unemployed, the incapacitated, the indigent and the disadvantaged….accorded such social benefit amenities as are just and affordable with due regard to the resources of the State; and (b) consistent planning to….improve public health. We will illustrate the contrast to a direct implementation as is the case in South Africa. Section 27 of the Constitution on Health Care, Food and Social Security paves the way directly for NHI. Section 27 states that everyone has the right to have access to: (a) health care services, including reproductive healthcare; (b) sufficient food and water; and (c) social security, including, if they are unable to support themselves and their dependants, through appropriate social assistance. 16 | P a g e 3. Health Insurance Models and Funding Models The fundamental objective of health systems is to improve the health of the population and to provide financial protection against the unexpected costs of ill-health. Central to achieving these goals is the concept of risk pooling, where the risk of having to pay for health care is spread across the entire pool of members instead of being borne solely on the individual. Therefore, the larger the degree of risk pooling in a health financing system, the smaller the financial consequences of individual health risks, and the easier it is to increase access to health care and achieve universal coverage. The purpose of this section of the report is to outline the features of the four main models of healthcare system financing: 5. 6. 7. 8. the National Health Insurance (NHI) model, the Bismarck Social Health Insurance (SHI) model, the Beveridge model, and the Out-of-Pocket model. 3.1 National Health Insurance (NHI) Model The NHI model uses an insurance system as opposed to a budget system. This implies that the pool of state insurance funds, as opposed to the household’s personal income, becomes the budget for individuals to service their healthcare needs. A single state NHI fund acts as a single funder and single purchaser of medical benefits, with only those citizens/employers earning above a certain income or means threshold, required to pay contributions into the NHI Fund. However, the entire population is entitled to benefits from the Fund. The NHI Fund is non-profit and may contract with both public and private sector health providers i.e. it is a multiple delivery system. 3.2 Bismarck Social Health Insurance (SHI) Model The Bismarck SHI model is named after the Prussian Chancellor, Otto von Bismarck, who invented the welfare state. The SHI model also utilizes an insurance system, with the insurers called "sickness funds”. A Bismarck SHI scheme can either be made up of multiple risk pools/funds, or a single risk pool/fund. The SHI scheme can be funded by a single entity (for example the Government) or by multiple entities. It may also consist of a single-purchaser or multiple- purchasers of health care services, where the purchaser of health care services contracts with health care providers to provide health care services to the scheme members. Funds are usually financed jointly by employers and employees through payroll deductions. Typically, an SHI scheme contracts with both public and private providers i.e. a multiple delivery system. The sickness funds are non-profit. ii It is important to outline certain distinct characteristics of SHI : 1. Membership under the “contributory regime” is compulsory 2. Government may fund poor enrolees under the “subsidised regime” (should the government wish to extend SHI to achieve NHI). 3. Enrolees are eligible for benefits once a contribution is paid (whether this contribution is subsidised or not). 4. Legislation sets out the contribution and benefit rules 17 | P a g e Given that the Social Security Act of 1994 specifies that the NMBF will cover every employee of every employer, except if he or she is a member of a private medical fund or scheme, the NMBF is essentially envisaged to be a medical fund which, together with the ten existing open and closed medical aid funds in Namibia, will achieve SHI. Namibia is considering an NHI system. Whether NHI follows from a financially stable SHI or whether NHI is achieved directly, it is important to draw the key distinction between NHI and SHI. NHI covers the entire population, thereby achieving “universal coverage”, whilst the Bismarck SHI model only covers those in the formal sector who contribute to the SHI Scheme. 3.3 Beveridge Model The Beveridge model is named after William Beveridge, a social reformer who designed Britain's National Health System (NHS). In this system, health services are free at the point of treatment and health care is provided and financed by the government through tax payments (in a similar manner to the police force or the public library). The government is the sole payer i.e. single funder model. Many, but not all, hospitals and clinics are owned by the government. Some doctors are government employees, but there are also private doctors who collect their fees from the government. Government directly reimburses providers i.e. single purchaser. The State fund contracts with a network of public and private providers i.e. a multiple delivery system. 3.4 Out-of-Pocket (OOP) Model Only the developed and industrialised countries (perhaps 40 of the world's 200 countries) have well established national health care systems. Most nations are too poor and suffer from unsophisticated organisational structures which limit their ability to provide mass medical care. They are thus forced to adopt an out-of-pocket model where the individual bears the full cost of any health care. The basic result in such countries is that the rich get medical care and the poor stay sick or die. Access to care under the Out-of-Pocket model is only available if the individual: Can pay the bill out-of-pocket at the time of treatment, or Is sick enough to be admitted to the emergency ward at the public hospital Therefore, this model can force individuals and families into poverty due to the costs of ill-health and can thus jeopardise economic growth and the overall health of the population. 18 | P a g e The following graphic indicates which models a number of countries have opted to implement: 19 | P a g e 4. International literature and country experience The purpose of this section of the report is to outline the country case studies and summarise the lessons learned by each of the above models. The lessons learned will be summarised at a high-level. References will be included for further reference. 4.1 The Advantages and Disadvantages of NHI Country experiences show that NHI has the following advantages: Potential to be cheaper and much simpler administratively than for-profit private insurance since there is no need for marketing and no profit objective and hence no financial motive to manage/assess claims The single payer tends to have considerable market/bargaining power to negotiate for lower prices Cost control through benefit limits or waiting lists Increases ease of access to health services Increases equity Universal coverage ultimately achieved Single-payer system allows more effective cost containment (unified fees, lower administration) If the unemployment rate is low and there is a functioning existing health system, then NHI can be phased in potentially without using more resources (increases in claims cost can be offset by savings due to economies of scale and risk pooling) Country experiences show that NHI has the following disadvantages (du Toit, 2009): Requires substantial organisational skill and HR are required to manage and administer NHI Resources might be channelled to services that deliver non-optimal health returns Decreases funding for public health, since significant NHI funding channelled to comprehensive coverage for acute care and short-term care The NHI Fund and not individual disposable income becomes the budget constraint, which may make it difficult for supply to keep up with patient demand for more and more health benefits, thus resulting in high medical inflation 4.2 The Advantages and Disadvantages of SHI (Bismarck model) Country experiences show that SHI has the following advantages: Comprehensive and uniform benefits package possible, although challenging Universal cover is possible in the long-term, although challenging Funding and provision of services functions are separated Increased competition between providers contains cost Competition between private providers drives quality of services provided. 20 | P a g e Country experiences show that SHI has the following disadvantages (du Toit, 2009): Contributions are community-rated (i.e. contributions do not depend on risk, but on ability to pay), which results in significant increases in contributions for young and/or healthy employees relative to what the contributions would have been for them in a risk rated environment) Enforcing compulsory contributions under a contributory regime is challenging The self-employed may not enrol or they may understate their income Significant administration expenses Significant regulatory control is required The SHI Scheme and not individual disposable income becomes the budget constraint, which may make it difficult for supply to keep up with the increasing patient demand for health benefits, thus resulting in high medical inflation If there are multiple funds and community rating is in place, then a risk equalisation fund (REF) is 1 required, however a REF is difficult to implement with poor information systems (Netherlands) . Continual depletion/degradation of benefits under subsidised regimes (Colombia) Fee-for-service reimbursement is expensive such that SHI fund starts to short-pay providers, who t hen charge out-of-pocket payments (Ghana) 4.3 The Advantages and Disadvantages of the Beveridge Model Country experiences show that the Beveridge model has the following advantages: Reasonable potential for cost-control bargaining power over the long-term: these systems tend to have low costs per capita, because the government, as the sole payer, controls what doctors can do and what they can charge Universal coverage Low administration expenses Simple for members of public to use A public budget system is administratively simpler than a NHI or SHI insurance system Country experiences show that the Beveridge model has the following disadvantages (du Toit, 2009): Deficits in government finances may develop over time if healthcare costs increase at a faster rate than tax revenue Quality problems may become prevalent because of the government deficits Substantial co-payments may develop due to deficits 1 Risk equalisation refers to the notion of having an equitable and efficient private medical scheme market. The purpose of risk equalisation is to prevent medical schemes from competing on a risk-selection basis, whereby members are charged contributions commensurate with the level of risk they represent as determined by risk factors (e.g. age and health status) and instead promote competition on the basis of cost efficiency and quality of healthcare services provided. (SADoH, 2002) The concept of a Risk Equalisation Fund is readily explained within the context of a health insurance (medical) scheme environment in which open enrolment and community rating is practised. Open enrolment refers to the fact that enrolment in a particular scheme is not restricted and community rating refers to the fact that prospective members of a scheme must be accepted at the standard contribution rates i.e. a prospective member may not be charged a higher contribution based on his/her age, health status, or any other risk factor. (Mcleod, 2008) As a result of such an environment, members will be charged different contributions by different medical schemes for an equivalent “benefit package”. A Risk Equalisation Fund (REF) could be established and operated by a regulatory body in a health insurance/medical scheme market where open enrolment and community rating is employed in order to achieve risk equalisation. The essential idea is that mandatory contributions are made by medical schemes to the REF and subsidies are paid back to those medical schemes that are determined to have poor experience as a result of the risk profile of its members being worse than average. This would in effect create greater fairness in the level of contributions paid by members. 21 | P a g e Significant waiting lists for e.g. surgical procedures, in-hospital, specialists Restricted provider choice Private health insurance typically used to obtain “higher level of care” by the rich e.g. bypass waiting lists, luxury accommodation, increased doctor choice, access to local hospital, increased standards. However, this results in inequitable access e.g. for specialist and in-hospital treatment 4.4 Achieving Universal Coverage Universal coverage is defined by the World Health Organization as: “access to key promotive, preventative, curative and rehabilitative health interventions for all at an affordable cost” (WHO, 2005). The literature recognises four options for achieving the ultimate objective of universal coverage (WHO, 2004): 1. The Beveridge Model, which achieves universal coverage immediately 2. The Bismarck Model, where SHI can be viewed as a building block for NHI. This model follows a phased implementation approach towards achieving universal coverage in the long-term. 3. National Health Insurance, which achieves universal coverage immediately. NHI can be viewed as a mix of the above two options. Under mixed health financing systems, the subsidised population group is partially covered via general tax revenue, and a clearly specified contributory population group is covered by SHI. 4. A system of private health insurance that is subject to government regulatory powers, especially ensuring a pre-defined benefit package of care. The Social Security Act paves the way for the NMBF, which essentially aims to insure the currently uninsured in the formal sector. Once the NMBF is implemented, it is envisaged that, a mix of private medical funds and a single State fund (the NMBF), will cover all members employed in the formal sector and their dependants (thereby achieving SHI). If SHI will be achieved via the NMBF, then Namibia will presumably be looking to achieve NHI via SHI. Pro-active planning is essential, as any long-term NHI strategy must be linked to the short- to medium-term SHI strategy. Due to the existing NMBF Social Security Act legislation and debates on NHI in Namibia, it is important to outline a few points pertaining to the NHI-via-SHI strategy below. SHI is a one of the main funding models used for healthcare financing. Many SHI initiatives have taken place in Africa, Asia, and Latin America. A total of twenty seven countries have introduced the overriding principle of universal coverage via SHI (Hsiao & Shaw, 2006). Due to the difficulty of moving to universal coverage overnight, a process or phased approach is needed: 1. Start with occupational/employee groups 2. Expand coverage, where the government plays a role in subsidising the rest of the population Advantages of this two-step approach: More financial stability (once the contributory regime is solvent and performing well, the subsidised regime can then be established) More buy-in from contributors i.e. more acceptable to people who pay SHI contributions in Step 1. The above two-step approach is particularly important given the small size of the Namibian taxpaying population. However, Dr Zokufa (CEO of the BHF in SA) noted that South Africa did not choose to follow the above approach as they perceived that the transition from SHI to NHI would generate excessive 22 | P a g e resistance i.e. those lives registered under the contributory SHI regime would be reluctant to roll-out their fund to incorporate a subsidised regime. However, this argument against the two-step approach could be countered in several ways: 1. Decide the subsidized regime in advance, while designing the contributory regime 2. Secure donor funding in advance of introducing the subsidized regime: This is unlikely to be possible in Namibia given the expected decline of donor funds. Hence, secure government funding in advance of introducing the subsidized regime. It is also important to note that the transition from SHI to NHI is a lengthy process. The figure below illustrates the transition period from SHI to NHI by country (WHO, 2004) : Time to universal coverage Republic of Korea 26 Japan 36 Country Costa Rica 48 Luxembourg 72 Austria 79 Belgium 118 Germany 127 0 20 40 60 80 Years to universal coverage 100 120 140 However, it is important to also note that the factors at play for these countries, in the distant and recent past, differed to the factors at play in today’s more technologically sophisticated world. This report focuses on providing recommendations on the successful design and implementation of the NMBF only. Considerations for a transition to NHI are not covered in detail. For further reading on the factors to consider when transitioning from SHI to NHI, please refer to “Reaching universal coverage via social health insurance: key design features in the transition period” by the WHO. 4.5 Implementation of SHI: Lessons Learnt As this report focuses on providing recommendations on the successful design and implementation of the NMBF, and thus achieving SHI, we provide a summary of the key findings from a systematic review of SHI (in particular) country experiences from 5 developing countries (Hsiao & Shaw, 2006). These countries were/are developing nations and therefore, their circumstances were/are similar to those of Namibia to a certain extent. 23 | P a g e Year Source Kenya Ghana Philippines Colombia Thailand Namibia Population (millions) Per capita GDP (US $) Population below poverty line (%) 2010 World Bank 40.5 24.4 93.3 46.3 69.1 2.3 2010 World Bank 775 1283 2140 6225 4608 5330 2003 - 2009 UNdata 45.9 (2005) 28.5 (2006) 26.5 (2009) 45.5 (2009) 8.1 (2009) 38 (2003) % of Private Health OOP health population Unemployment Expenditure expenditure (% living in urban rate (%) (% of THE) of THE) areas 2010 2008 - 2010 2010 2010 UNICEF NationMaster WHO WHO 22 40.0 (2008) 55.7 42.7 51 11.0 (2000) 40.5 26.9 49 7.3 (2010) 64.7 54.1 75 11.8 (2010) 27.3 19.5 34 1.2 (2010) 25.0 14.0 38 51.2 (2008) 41.6 7.4 Total dependency ratio 2010 WHO 82.2 73.6 64.1 52.3 41.7 66.9 However, the table above highlights some distinct characteristics of Namibia that one should bear in mind when drawing from the experience of these 5 countries. In particular, the Namibian population is much smaller in number and the unemployment rate is significantly higher than that in the other countries. This will result in greater financing challenges for Namibia. On the other hand, the low out-of-pocket (OOP) expenditure is favourable for the achievement of SHI. Even though the lessons learned relate mainly to SHI, the lessons learned can very well be extended to the design and implementation of any State health insurance fund (including the NHI and Beveridge models). (Hsiao & Shaw, 2006) synthesize the overall lessons learned and policy implications from the above 5 countries, which have been chosen because: 1. Their circumstances are similar to Namibia’s, and 2. They are at various stages of SHI implementation (see diagram below for the various stages and which country provides the case study for each stage) Thailand Colombia Philippines Ghana Kenya Initiating SHI Extending coverage beyond the formal sector SHI with managed competition to improve health care delivery Achieving universal coverage with SHI Designing SHI Hsiao and Shaw make the point that SHI is a complex instrument of reform. Done well, SHI can yield positive outcomes over time. Done properly, SHI can be expected to improve a country’s risk protection and health status outcomes. Done hastily, SHI can be backward, disruptive, and possibly hazardous. Against this cautionary background, the main overall lessons learned are synthesised across the five case studies and are key unwavering principles that must be adhered to when designing and implementing a fund, such as the NMBF, which will achieve SHI. 24 | P a g e These lessons learned are summarised in terms of the following four dimensions (Hsiao & Shaw, 2006): 1. 2. 3. 4. Factors contributing positively to an enabling environment for SHI Positive changes that can be attributed to SHI Major problems that challenge implementation Implications for policy makers Factors Contributing Positively to an Enabling Environment for SHI Large formal sector employment • Ease of administering mandated payroll tax on employers and/or employees • Ease of locating employers and collecting premiums High wages and salaries • Reduced economic burden of payroll tax • Opportunity to finance broader benefit entitlements Low poverty rate • Reduced need to subsidise membership of poor households Small family and/or household size • Reduced need for worker contributions to cover large number of dependants Efficiently functioning provider networks • Improved access by members to provider • Greater choice of providers • Possibility of quality-based competition among providers Strong human resource capacities • Available skills to manage SHI and monitor and evaluate quality Strong administrative support • Banking, accounting, actuarial, and legal support available Government capacity to regulate • Greater capacity to regulate for quality and manage grievance procedures Source: Social Health Insurance for Developing Nations, Hsiao & Shaw Several structural features of the economy, as illustrated in the diagram above, tend to contribute positively to the enabling environment for SHI. A successful launch of SHI requires three major pre-conditions: 25 | P a g e 1. Incentive for people to pay premiums People must be motivated to accept and pay for SHI, even in compulsory systems. People are willing to prepay for health care services only if they currently have to pay for their health services. If adequate public sector services of good quality are provided for free or nearly free, why would people who use these services want to enrol and pay for SHI? People will not want to pay for SHI unless user fees are high, if patients have to purchase drugs and supplies, or if public services are so poor that many patients pay out-of-pocket for private providers. A comparison of the Ghanaian and Tanzanian experiences can be instructive. Ghana shifted to the “cashand-carry” user fee system in 1999, and patients had to pay fairly high user fees. Consequently, voluntary prepayment plans such as the community-based mutual health organisations (MHOs) flourished, growing from 4 MHO funds in 1999 to 157 by 2002. In 2003, Ghana was able to pass legislation to establish SHI nationwide, relying on the MHOs as a building block. By contrast, Tanzania does not have high user fees. Since 1996, Tanzania has tried to attract and enrol its population into its district-based insurance, the community health funds. The government subsidises 50% of the premium, regardless of income level, yet the enrolment rate remains low, ranging from 5% to 20% of the eligible population, and those who enrol tend to be the elderly and the sick. 2. Certifications of qualified providers Developing nations have tended to pay little attention to the safety and quality of health services rendered in the private sector, other than establishing minimum standards such as licensing requirements. Following initial licensing, the actual safety and quality of health services remain largely unmonitored and unregulated. In rural areas, drug peddlers and indigenous doctors have free reign, because regulations are not enforced. Moreover, governments rarely require private facilities to be transparent in relation to their financial operations or to adopt modern financial and medical record systems. Under such conditions, the quality of private sector health services is highly variable, and detecting fraud and price gouging when SHI pays for claims is difficult. Publicly provided health services are also problematic. Governments manage public facilities by means of bureaucratic rules that tend not to encompass modern accounting, financial, and clinical information systems. The average clinical quality of public facilities might be better than that of private facilities, but it is nevertheless highly variable. These deficiencies have to be remedied before or concurrently with SHI to gain sustained public support, perform its role of assuring a reasonable quality of health care, and sustain its operations financially. The SHI administration should prudently purchase health care for its insured. A prudent purchaser has to ensure that services and drugs meet certain standards. Equally important, SHI has to be able to control fraudulent claims and supplier-induced demand for unnecessary services, as well as “inside” dealings between doctors, pharmacies, and testing laboratories. Conditions in the market for health services often requires SHI to set safety, quality, financial, and audit standards beyond what currently exists so that SHI can be a responsible and prudent purchaser. Under such circumstances, SHI has to develop and implement new standards and enforcement mechanisms to assure the safety and clinical quality of health care, as well as standard medical records and accounting systems, and adequate inspection and auditing of providers. Establishing standards and a system for enforcing them must be high priorities before SHI can be implemented. 26 | P a g e 3. Rapid economic growth Rapid economic growth is an important consideration in sustaining an SHI program and in expanding it to achieve universal coverage. Health care costs rise rapidly due to inflation, rising expectations, and expensive new drugs and technology. Unless wage rates are also rising rapidly, premiums would have to be increased frequently. Meanwhile, governments may need rising revenues to subsidise the growth in premiums for the poor and to expand coverage. Moreover, rapid economic growth has positive effects on SHI enrolment in that it (a) can lift people out of poverty, meaning that more people can afford to pay their premiums; (b) can bring more workers into the formal sector, which increases the number of people in the contributory regime; (c) can raise the government’s general revenues, meaning that the government can subsidise more of the poor; and (d) tends to increase the government’s administrative capacity to collect taxes and insurance premiums. Rapid economic growth will therefore enable a nation to move toward universal coverage. Positive Changes Attributable to SHI SHI experiences from developing countries indicate that SHI can be credited with at least 13 positive changes. Effective SHI: 1. Facilitates national debate and consensus on the financing of health care and allocation of resources, involving more stakeholders such as industrial groups, cooperatives and religious groups 2. Mobilises more revenue for health 3. Constitutes a formal mechanism for pooling revenues and spreading risks across population groups, from rich to poor, the sick and the healthy, and across the life cycle 4. Forces more careful and rational planning to equate SHI revenues with SHI expenditures 5. Responds to clients’ preferences and complaints through grievance procedures if benefit entitlements have not been honoured 6. Separates public finance from public provision, whereby the SHI fund manages the financing and contracts out to public and private providers to deliver services 7. Inspires more realistic consideration of equity, arising from the debate on subsidising and expanding coverage for the poor and the indigent that accompanies SHI 8. Encourages more efficient purchasing of health services using different forms of provider remuneration (e.g. capitation agreements) in the quest to achieve value for money 9. Results in a clarification and redefinition of the roles of ministries of health 10. Succeeds in expanding membership rather than simply stalling or levelling off 11. Reduces catastrophic financial loss that is faced at times of serious illness or injury, and thus the vicious cycle of indebtedness, debt servicing, and reduced household expenditure on necessities 12. Expanding access to quality services by the insured 13. Free up scarce public revenues (from general taxation) for more effective targeting to the poor Major Challenges Inherent in Implementation The experiences of the five countries also indicate that, at various stages of development, SHI can expect to encounter at least 9 major implementation challenges along the following themes: 1. Enforcing the collection of contributions 27 | P a g e Mandatory SHI needs to be enforced. Passing a law and creating an organisation to collect premiums is relatively easy, but actually collecting those premiums is another matter. Collection will be easiest for civil servants using regular payroll lists and monthly deductions. Collection from large formal sector employers and employees will also be relatively easy. Collection will be much harder among smaller enterprises in the formal sector, with evasion by both employers and employees being a major problem. In the Philippines, for example, the Office of the Actuary estimates that for small employers in the formal sector, only 30% of those who should be contributing actually do. In Colombia, estimates indicate that only 65% of potential contributors are actually paying, with evasion decreasing revenues by up to 35%. 2. Contributing members may not afford contributions in respect of dependants The poorer the country, the higher the dependency ratio, largely because of high levels of fertility and large family size. If dependents are excluded from SHI benefits, as was initially the case in Costa Rica’s and Thailand’s SHI systems, then revenue from workers’ contributions only pays for the workers’ health care costs. To cover workers’ dependents, the contributions must be more than doubled (although the independence of some administration costs on the number of lives covered reduces the overall contribution to some extent). A favourable financial condition for including dependants is that the premium rate for a child is typically only about one-quarter of that for an adult. In the Philippines, approximately 25% of benefit payments go to beneficiaries less than 20 years of age, 50% to those aged 20 to 60, and 25% to those older than 60. Thailand eventually extended its coverage to dependants, but only once SHI accumulated a hefty surplus. 3. Actuarial costing of the benefits package requires technical skills and data, and is essential to determine the financial sustainability and survival of SHI Actuarial costing of the benefits package is essential, with such techniques increasingly being applied. Actuarial methods require such information as household utilisation data broken down by age, sex, employment, and income. Furthermore, utilisation and unit costs will have to be projected to reflect moral hazard, induced demand, and price increases associated with the introduction of SHI. For example, health services of higher quality than in the past, without financial barriers to their use, are likely to lead to a large increase in primary care consultations. The contribution can only be determined when accurate actuarial costings have been completed. Is a contribution of x% of payroll, split evenly between employer and employee, enough? Is y% enough or is a higher percentage called for? What level is politically acceptable and collectible? If the required contributions are too high, as usually happens, what has to be cut back in the benefits package? In order to take all these considerations into account, the benefits package is determined by means of an iterative cycle: designing the benefits package, estimating its costs, undertaking political consultation, then adjusting the benefits package and estimating its costs, and so on. This process requires technical skills and data. In countries with a per capita annual income of US$2,000 or less, these problems will be a major challenge; in countries with a per capita annual income of US$500 or less, they will be monumental. In all countries, sound actuarial analysis combined with a political process will be essential. Many districts in Ghana encountered difficulty in implementing SHI because the premium was too low. 4. Enrolment of those in the informal sector and the self-employed, since mandatory enrolment is not easily enforceable Enrolment of those in the informal sector and the self-employed will always be a major challenge, because mandatory enrolment is not easily enforceable. If their enrolment is voluntary, antiselection—meaning the poor and the sick with the highest medical bills will be the most likely to join— will be a major threat to the financial sustainability of SHI. In addition, the administrative costs to enrol, monitor, and collect contributions from this population can also be high. In the Philippines, two28 | P a g e thirds of voluntary enrolees did not pay their premiums on a regular basis, motivating the SHI fund to give religious and cooperative organisations group discounts as a way of enrolling their entire membership, which helped somewhat, but did not solve the problem. In Thailand, coverage and collection problems were such that the government decided to use general revenues to pay for all informal sector and self-employed workers. The more confidence workers have in government and SHI, the more recourse government and SHI have to effectively punish those who evade. 5. Defining, certifying, and subsidising the poor All stages of SHI face major problems in relation to defining, certifying, and subsidising the poor. As implied by the Ghana and Kenya case studies, the poorer the country, the worse the problem, because the number of poor people will be large and the capacity to monitor and evaluate them will be limited. Moreover, actually getting public subsidies to the poor and the indigent will be a major hurdle, requiring proper cross-subsidisation and pooling of risks between rich and poor regions if SHI contributions are held at the regional or district level. 6. Supply will have to be built up progressively if clients in semi-urban and rural areas are to have access to adequate health care Moreover, improving performance through contracting (on the supply side) and through choice of providers (on the demand side) will be compromised without sufficient providers to allow some form of competition. 7. Provider payment mechanisms that aim to shift the financial risk of provision to the provider, will have to be continuously monitored and evaluated As Thailand’s experience shows, capitation without special provisions for the indigent or for expensive cases, can lead to cream skimming and risk selection as providers have an incentive to keep their costs to a minimum. 8. Administrative efficiency improvements e.g. associated with the consolidation of existing social insurance and other risk-pooling schemes Improvement of the administrative efficiency and effectiveness of SHI requires attention on several fronts. How should a country consolidate existing social insurance and other risk-pooling schemes? In Colombia and Ghana, for example, several different insurance schemes already existed prior to the introduction of a universal SHI, resulting in fragmented risk pools, inefficiencies, and large transaction costs. In Ghana, SHI faces the challenge of integrating various schemes that vary in terms of membership, benefits, premiums, and types of providers. In Colombia, the administrative costs of health plans were so variable, ranging from 4 to 60% of the value of the premium, that the government issued a decree that required plans to have a minimum of 200,000 enrolees. This led to a wave of mergers among plans serving the subsidised population, with a reduction in their numbers from 239 in 1999 to 43 by 2004, with 45% being private, 42% being community based, 6% being public, and the remainder being health plans for indigent people. Moreover, administrative budgets have to be realistically determined and adhered to. In Kenya, these are set at 5% of SHI revenues, but are as high as 12% in the Philippines. Within those budgets, SHI administrations have to be more effective in discharging their responsibilities because they have little recourse to soft budgets and government bailouts should cost overruns occur. This places a premium on establishing efficient administrative operations and recruiting good managers. 9. Leakage of SHI funds because of corruption will be a perpetual threat 29 | P a g e In Kenya, compulsory SHI for hospital services suffered greatly from poor management and corruption, with only 22% of the fund actually used to pay for benefits and a large portion of the accumulated reserve lost through corruption. As a result, Kenya’s plans to launch a new national SHI system include rules to constrain the board’s behaviour, including a 5% limit on administrative costs, a 3% limit on reserves, and a requirement for board members to abstain from voting on investments or contracts if they have any financial links to them. Fraudulent claims will hound SHI, as in the Philippines, where the Office of the Actuary estimates that somewhere between 10 to 20% of claims are fraudulent. Policy Implications The 15 policy implications are cautionary statements, intended to minimise misconceptions and mistakes surrounding SHI: 1. SHI is complicated: effective and efficient implementation takes many years SHI is a sophisticated financing method and effective implementation requires reorganising the Ministry of Health and establishing a new SHI agency. The ministry of health has to be transformed from being a funder, manager, and operator of public health services to being a policy maker, a regulator, and an overseer. The new SHI agency has to have a sound organisational structure, effective leadership and management, capable and dedicated professional staff, and sophisticated management information and information technology systems. For example, the SHI agency has to recruit or contract capable doctors, actuaries, accountants, financial managers, information technology specialists, policy analysts, and planners and its executives and managers have to be educated in the nature and functions of SHI. In managing health services, the SHI agency needs to select and contract health care providers and monitor their services, which requires hospitals to develop modern accounting, financial, and medical record-keeping systems. Most low-income countries simply do not have the required human resources and knowledge and these will have to be developed over time. 2. It takes decades for SHI to achieve universality Passing a law to introduce the principle of universal coverage through SHI is only the first step. In relatively rich countries, the number of years between the first law related to health insurance and the final law that effectively implemented universal coverage through SHI ranged from 70 to 100 or more years in several Western European countries, to 30 to 50 years for Costa Rica, Japan, and Korea. Moreover, coverage tended to grow slowly, usually taking decades to approach universality. The most severe constraints to achieving universality in low- and middle- income countries are tax revenues and the portion of workers employed in the formal sector, which depends on a country’s stage of economic development and employment structure. Poor countries not only have small tax bases worsened by large informal sectors. Enrolling civil servants and employees of large firms is easy, but enrolling the self-employed and informal sector workers is much more difficult. The challenge for enrolling the poor is funding them. Economic growth can have four positive effects on SHI enrolment: it lifts people out of poverty, meaning that more people can afford to pay; it brings more workers into the formal sector, which increases the number of people in the contributory regime; 30 | P a g e it raises general revenues for the government, meaning that more of the poor can be subsidised; it tends to increase the government’s administrative capacity to collect taxes and insurance premiums. Thailand took more than 25 years to reach universality, at which point their annual per capita income had reached US$2,400. Thus expanding SHI coverage and attaining universality depends on a nation’s rate of economic development. 3. Initially, having the same benefits package for all groups may not be possible All countries would like to offer a comprehensive benefits package to all citizens. Unfortunately lowand middle-income countries may not be able to afford such a package. Formal sector employees demand comprehensive benefits and may be able to pay for it. However, a difficult trade-off has to be made for the poor and near-poor. The choice involves covering fewer poor and near-poor with a comprehensive package or covering more of them with a less comprehensive package. For example, Colombia had to limit the benefits package of the poor to make it only half as expensive as that of formal sector employees so that it could be affordable. Colombia then expanded its coverage to the near-poor with an overall benefits package less comprehensive than that offered when it was restricted to just the poor population. 4. The benefits package must be designed and costed Costing out the benefits package is a major technical and political hurdle in implementing SHI. Usually, politicians like to promise the most and pay the least. A sound SHI program requires adequate and sustainable financing. The initial “wishful” benefits package has to be costed to ascertain its affordability and acceptability by the funders. In practice, it requires several rounds of designing a benefits package, estimating its actuarial costs, modifying the benefits package, and then re-estimating its actuarial cost to reach a balance between “wishes” and economic reality. Kenya did not conduct such a process, which resulted in the president’s refusal to sign the SHI bill into law. Ghana, as at 2004, had yet to cost its benefits package. The Philippines had, after 10 years of SHI, not undertaken actuarial studies of the real costs of providing benefit packages. Absence of this kind of information disempowers managers. 5. User fees must be in place to motivate people to join People have to have incentives to pay SHI premiums. This applies especially to self-employed workers, who would not be motivated to join SHI if government services were available at little or no cost. This is a significant issue in countries with high levels of poverty and strong political pressures to eliminate user chargers at public facilities. In other words, people will be motivated to pay for SHI if user fees are relatively high, if patients have to purchase drugs and supplies, or if public services are so poor that many patients pay out-of-pocket for private providers and are susceptible to catastrophic financial loss at times of serious illness or injury. 6. SHI must create adequate incentives for workers to enrol The mainstay of SHI membership will be workers in the formal sector who can be identified as employees of organisations and are mandated to pay monthly premiums. However, even when contributions are mandatory, anti-selection can be a critical problem, with evasion most likely among smaller employers. To overcome this, SHI has to create incentives for workers to enrol by requiring employers to pay a share of the SHI premium. Thus Colombia, Ghana, Kenya, the Philippines, and Thailand all designed their SHI so that employers pay at least half of the premium. This parallels the 31 | P a g e experience of SHI in many countries that are more developed than these five, where the contribution rate is also split between employers and employees, for example, 4.5% of payroll each in Bulgaria and 6.1% each in Romania. 7. Large general revenues are needed to cover the poor All low- and middle-income countries have large poor populations who are unable to pay the premium, and nations use different criteria to establish the poverty level. The indigent population usually accounts for 40 to 50% of the population of low-income nations. Even in the United States, 12% of the population falls below the poverty line. The government has to have the budget to subsidise the poor, and to do this, it could reallocate funds from other programs to health and/or raise new tax revenues. For example, Ghana imposed a new 2.5% value added tax to help finance the subsidised regime, but whether the funds will be sufficient to pay for all the poor as Ghana’s SHI coverage expands, is not clear. The Philippines used revenues from a national sweepstakes lottery to help finance premiums for the poor. 8. Stakeholders must be convinced of the actuarial soundness of SHI SHI is required to maintain its own solvency, meaning expenditures “out” must not exceed revenue “in,” and thus must be transparent and accountable. Solvency cannot be adequately assessed without actuarial calculations that consider near and longer-term characteristics of the workforce and the level of workers’ earnings. These, in turn, will depend upon many economic and demographic factors, including future birth rates, death rates, labour force participation rates, economic development rates, and wage increases. In the United States, for example, actuarial calculations must show predicted revenues and expenditures for 25 years into the future for Medicare, a program financed primarily by a payroll tax that covers 38 million elderly and disabled Americans. The absence of actuarial studies will leave SHI policies and implementation plans vulnerable to intense public scrutiny and criticism in relation to solvency. 9. Supply-side subsidies must be reduced In most low-income countries, the government subsidises public health facilities with a large annual budget. Under SHI, public health facilities will receive their revenues from SHI payments. The supplyside subsidy should be reduced in synchronization with the implementation of SHI, with the savings used to expand the subsidy for the poor or the like. Otherwise, the public health facilities will be overpaid, a poor use of scarce resources. Colombia had planned to reduce this supply-side subsidy as SHI expanded, but it has been unable to do so, because of the political power of public health workers’ unions. As a result, the planned expansion of SHI to cover the near-poor has been retarded and public health facilities used the additional revenues from SHI payments to increase staff compensation and to undertake new capital projects. 10. The SHI Agency should be insulated from political interference To represent the interests of the insured and prevent corruption, SHI needs to be independent from the government. The new independent agency must be transparent in relation to its finances, which requires independent audits. Many countries establish their SHI agency under the ministry of health without adequate representation by the insured and by premium payers. Typically, the ministry of health is dominated by medical professionals who tend to protect supply-side interests, as was the case in Colombia and the Philippines. Under such governance, much of the new revenue went to increasing the salaries and profits of providers. 32 | P a g e 11. The SHI Agency should be a prudent purchaser of medical services and goods For the ministry of health to manage SHI is difficult, because doing so requires a transformation of its corporate culture from that of a funder and operator of public services to that of an active, prudent purchaser of services for the insured. The contrasting experience of the Philippines and Thailand provides a good example. The SHI agency in the Philippines has acted like a traditional, passive, private insurance company, that is, as just a financial intermediary. It enrols members, collects premiums, and pays claims. By contrast, the national health security office (NHSO) in Thailand selectively contracts with provider networks and pays them a capitation rate, a payment system designed to discourage overuse. As a result, Thailand has not had the same problems the Philippines has of new funds being used to benefit suppliers instead of the insured. 12. Qualified providers must be certified before or concurrently with implementation of SHI As a purchaser of services, SHI will need to contract with public, NGO, and private-for-profit providers. SHI members will expect these providers to provide more or less uniform quality of services and have more or less uniform capacity to deliver them. To a large degree, public providers will be trying to conform to established, published, provider guidelines, with the onus on public providers to live up to those guidelines if contracted by SHI. At the same time, the quality of private sector health services is highly variable, and detecting fraud and price gouging is difficult when SHI pays claims. These kinds of deficiencies have to be remedied before or concurrently with the implementation of SHI if it is to gain enduring public support, perform its role of assuring reasonable quality, and sustain its operations financially. 13. A single fund is preferable to multiple funds. Three main arguments support the establishment of a single insurance fund instead of many funds. Firstly, low-income countries lack the human resources, experience, and information technology systems required to start one fund properly, so having multiple funds would further dilute the human resource pool. Secondly, having multiple funds would increase administrative costs at both the insurer and provider levels, meaning that fewer of the scarce resources would be spent for health services. Thirdly, a system with multiple funds develops political and bureaucratic barriers to universal SHI with equal access. Thailand’s major hurdle to equalising access is the merger of its various funds. Colombia, Ghana, Kenya, and the Philippines learned from the struggles of more advanced economies such as Germany, Korea, and Taiwan (China) that had multiple SHI funds, and established a single SHI fund. Nonetheless, several economists argue that multiple funds would give people a choice and that competition among funds would promote greater efficiency. 14. Donors could play a valuable role in supporting the implementation of SHI Donors are keen to fund international or national public subsidies to improve the health of the poor. Their traditional approach has been to channel donor assistance to publicly financed and provided health goods and services, on the presumption that these funds will benefit the poor. However, as studies of public funding typically show, the richest households are the ones that benefit the most by “capturing” the public subsidy through having public hospitals built in urban areas where the rich can easily access them. In addition to multilateral and bilateral donors, international NGOs channel large infusions of funds to supply-side provision of public health goods and services, such as much needed vaccinations supported by the Global Alliance for Vaccines and Immunisations, which directly affect 33 | P a g e health status outcomes. Donor support of SHI is needed to complement traditional development assistance, because SHI shifts the emphasis from improving health status alone to improving both health status and financial risk protection. Avenues of support include the following: Writing off debt owed to the donor countries (“debt forgiveness”) in developing countries that are undertaking SHI as a way to subsidise membership by the poor as Ghana planned to do; providing direct grants to SHI that are earmarked for enrolling the poor and the indigent and/or expanding special benefit entitlements to targeted groups, as the Philippines did with directly observed treatment short-courses (DOTS) and maternity benefits; increasing technical assistance to manage and operate SHI in the form of resident, seconded staff who have experience in planning, budgeting, undertaking actuarial analysis, contracting, and monitoring performance. 15. SHI should be linked to a National Health Insurance policy Finally, an important role of government is to formulate a policy that clearly links the initiation of SHI with other risk-pooling mechanisms and other dimensions of health systems development: Firstly, SHI should not be seen merely as a way of mobilising and earmarking more revenue for health and for providing formal sector workers with better health services. It should be seen as a building block in national efforts to provide universal risk pooling and coverage and, where possible, it should be used to connect and integrate risk-pooling initiatives by other groups in society. The clearer the government’s intentions are in this area, the better different stakeholders will be able to assess the current and future benefits of SHI and the more solidarity can be facilitated in the process. Secondly, it is important to recognise and clarify that legislation in support of SHI, as well as laws to implement it, will have nationwide implications for all sources of revenue mobilised for health. Key issues requiring clarity are the extent to which the government will continue to mobilise financing for health from general revenues and other taxes and how it plans to target these revenues more effectively to provide public health goods and services and subsidise the poor. In other words, as SHI evolves, how will it co-exist with core government funding in a way that maximises financial risk protection and assures access to quality care nationwide? Thirdly, the potential or intended role of SHI as an instrument of health sector reform should be specified. SHI can be a powerful instrument for reforming the health care delivery system to improve the efficiency and quality of health care by being an active and prudent purchaser of health goods and services. SHI can also be an instrument for helping to horizontally integrate the many vertical externally funded programs typically found in low- and middle-income countries. 4.6 Country experience within the informal sector In Africa, Community Health Insurance (CHI) Schemes are a common mechanism used to provide health care to low-income earners living in rural areas. It was independently estimated that there were 626 CHI schemes in West Africa alone. (Soors W, 2010) Community Health Insurance Schemes share five characteristics, namely: 1) The schemes are established by communities, of which the individuals share common characteristics such as geographical area, ethnicity, religion, etc. 2) Solidarity principles are applied as opposed to mutuality i.e. contributions to the scheme are not determined based on a member’s risk factors 34 | P a g e 3) Members are involved in decision making and management of the scheme 4) The schemes are non-profit 5) Membership to the scheme is voluntary (Soors W, 2010) In West African countries the establishment and management of CHI schemes has been undertaken by the respective governments which have also instituted enabling legal frameworks. Varying levels of success have been achieved by different countries of which Senegal, Mali, Ghana, Guinea, Burkina Faso, Benin, Togo, Cameroon and Niger are included. Progress has been slow and the success of the entire concept as a means of providing health care to low-income earners who live in areas with limited access to such services has been heavily criticised. (Soors W, 2010) In Central and East Africa, both government and health care providers tend to play leading roles in the establishment and management of CHI schemes. The United Republic of Tanzania, Kenya, Uganda, and Rwanda are some of the countries who also have attempted to provide health care to the informal sector through CHI schemes. Most of these schemes are young and small though, also with varying levels of successful implementation. (Soors W, 2010) Exploring the possible establishment of CHI schemes as a means of providing health care to the informal sector in Namibia would require extensive research and investigation into the nature and size of it and the most appropriate structure for the CHI schemes. 35 | P a g e 5. Collection Methods The NMBF has various options available when it comes to funding the claims and expenses the scheme will incur on an on-going basis. Various countries worldwide take different approaches to funding social/national health insurance schemes. Funding systems are generally a mix of three sources of funds (private, employer-employee contributions, and national/sub-national taxes). These funds are usually notfor-profit institutions run solely for the benefit of its members. In countries such as Canada, payment is made by government directly from tax revenue. In the UK, an additional contribution is collected for all workers, paid by employees and employers based on the level of salary paid. In both of these cases the collection is administered by government. The NMBF may consider a combination of these methods by offering a health care subsidy on contributions paid by employers and employees. In choosing a preferred funding method, the NMBF needs to consider the affordability and the viability of funding through national taxes, as well as the ease of collecting contributions through employers/ employees. 5.1 Tax collection system in Namibia One of the options of funding for the NMBF is via income tax. Individuals are taxed on a progressive marginal scale over a series of income brackets with the highest marginal rate being 35%. The Namibian tax system has undergone continuous reform since independence which has brought about numerous improvements. The tax system is perceived to be equitable and transparent, and after the introduction of the value-added tax in November 2000, tax collection has significantly improved. Currently there are tax allowances where individuals may deduct for contributions to approved pension funds, provident funds and retirement annuity funds, however no deductions are granted to individuals for medical expenses (employers liable for such expenses may deduct them, subject to certain limits). In addition, both employers and employees are required to make social security contributions at a rate of 0.9% of the employee’s basic salary income up to a maximum of NAD 54 per month. A similar structure may be considered when determining the funding method for medical costs. The success of funding the NMBF through income tax will largely be dependent on the tax collection method and how successful Namibia has been at collecting income tax in the past. Namibia has a self-assessment tax system for both income tax and value-added tax, and therefore places the obligation squarely on the taxpayer to submit tax returns by the due date or face the consequence of a penalty for late submission of the tax return. In some cases these penalties are severe. Salaried individuals must file their returns by the end of June. Tax on employment income is withheld by the employer under the pay-as-you earn system and remitted on a monthly basis to the Receiver of Revenue. Individuals who derive income from business or farming activities must register as provisional 36 | P a g e taxpayers. Therefore it is unlikely that tax from employed individuals will not be collected, which is promising for the NMBF if income tax is the funding method of choice. The following table shows how Namibia ranks worldwide with regard to ease of paying taxes. We compare Namibia’s ranking to other countries where Social Health Insurance/National Health Insurance has been implemented. Country World Ranking Ease of paying taxes Tax payments Time to Comply Total Tax Rate Namibia 99 123 149 4 UK 16 15 23 76 Germany 88 53 84 128 Taiwan 87 56 108 100 South Africa 24 24 75 43 Kenya 162 133 153 135 Ghana 78 109 90 53 Philippines 124 149 70 118 Colombia 118 71 80 171 Thailand 91 83 106 78 * www.pwc.com/payingtaxes The amount of taxes and mandatory contributions payable by businesses after accounting for allowable deductions and exemptions as a share of commercial profits.(as defined by The World Bank) Namibia is ranked relatively low in respect of ease of paying taxes compared to the UK and South Africa. However, it is evident that although Namibia needs to improve their collection methods, it is not far behind compared to most other countries in the above table. The big difference is evident in the total tax rate. th Namibia is ranked as the 4 lowest total tax rate in the world. Countries who have implemented Social/National Health insurance typically have a considerably higher total tax rate. If Namibia is to fund the NMBF through taxes it may need to increase the tax rate to accommodate this. However this will have many other implications that will need to be considered such as the effect on GDP and economic growth. Alternatively the government may need to redistribute the current budget in which tax is currently being utilised. 5.2 Current collection methods by medical aid schemes A further consideration for the NMBF is how contributions will be collected via individuals and/or employers. If government fails to collect contributions successfully, they will not be able to cover the claim costs and expenses needed to support the fund. The collection method will be vital to the success of the NMBF. Currently in the Namibian market, medical schemes collect contributions on a monthly basis in advance, and any subscriptions in arrears will result in suspended benefits and accrue interest at the prime interest rate. Contributions for individuals who are part of their employer’s group medical aid are normally paid through the employer, with the contribution deducted from a member’s salary and paid into a revenue fund. Therefore medical schemes generally do not have problems collecting contributions from these individuals. Individuals who are not on an employer’s group medical scheme generally set up a debit order to pay for their contributions on a monthly basis; however this is not always the case in Namibia, with only 62% (FinScope, 2011) of the adult population having a bank account. 37 | P a g e Individuals are not required by law to join a medical aid when employed, and therefore the decision to join is normally a financial one. Medical schemes in Namibia experience the problem that members often default on their payments during months of hardship in order to bring temporary relief to the household budget. When times improve, members continue to pay their contributions, however the contributions in arrears are often not made up. The NMBF will need to devise a strategy in order to overcome this situation and ensure that contributions are collected timeously in full. In South Africa, employed individuals may be required to join a medical aid as a condition of employment. An employed individual will either need to join the specific medical aid their employer supports, whereby contributions are automatically deducted from the member’s salary. Alternatively an individual would need to prove they are a member of a medical aid and will then have contributions automatically debited from their account via a debit order. Unemployed/self-employed individuals are also able to join a medical aid and will also have contributions automatically debited from their account. It is recommended that the NMBF, should they chose to use contributions collected from employers/individuals in order to fund the scheme, use a similar method as the one used in South Africa, whereby all employed individuals must have medical cover, and contributions are collected via employers or direct debit orders. The collection of contributions from the self-employed, however, will be more challenging due to the variability of the income, the inability to verify the accuracy of the income stipulated, as well as the difficulty in locating the self-employed. 38 | P a g e 6. Demarcation between Health Insurance and the NMBF 6.1 Health insurance vs. medical aid Health insurance and medical aid differ significantly, but are essentially both insurance products used to cover expenses relating to healthcare. Health insurance works like a typical insurance product, where cover is paid for, and a defined claim amount is paid out if a specified incident occurs. Health Insurance payment amounts are also typically defined prior to the benefit event occurring and do not indemnify the policyholder from the actual medical expenses incurred. Medical aid is not incident based, and claim payments are made on an indemnity basis subject to certain benefits rules. Medical services and products are paid for on an ongoing basis. 6.2 Demarcation in Namibia In Namibia, medical aid funds are the largest provider of healthcare coverage, with insurance companies playing only a minor role. In general, insurance companies will provide healthcare benefits that bridge the gap between actual medical costs and the benefits provided by a medical aid fund. In certain instances, health insurance products will provide cover for AIDS-related illnesses. Medical aid funds in Namibia are required to comply with the Medical Aid Funds Act, No 23 of 1995 and the regulations of 11 February 1997, and are governed/regulated by NAMFISA. The Act defines a fund as follows: " any business carried on under a scheme established with the object of providing financial or other assistance to members of the fund and their dependants in defraying expenditure incurred by them in connection with the rendering of any medical service, but does not include any such scheme which has been established in terms of an insurance policy” Medical aid funds in Namibia are not allowed to offer long and short term insurance products according to the NAMFISA Circular No PI/MA/2003 of December 2003. Health Insurance is classified as short term insurance in Namibia and therefore falls under the Short-term Insurance Act, No 4 of 1998, but is also governed/regulated by NAMFISA. Medical aid funds and health insurers will therefore have different administrative, regulatory, reporting and capital requirements. 39 | P a g e 6.3 What does this mean for NMBF? The NMBF will act as a medical aid fund rather than provide health insurance and will therefore need to comply with similar provisions to those stipulated in the Medical Aid Funds Act. It will be exempt from the Medical Schemes Act (Act 72 of 1967), except in so far as the Minister determines otherwise (as laid out in the Social Security Act). The NMBF should fall under the regulatory ambit of NAMFISA, as this body regulates all non-banking institutions in Namibia. NAMFISA is an independent regulatory body, whereas if the SSC were to set up its own regulatory function this would result in the SSC regulating itself and thereby foregoing the core regulatory requirement of independence. Regulation pertaining to the NMBF in particular will need to be defined at a high level, however the rules governing the day-to-day running of the scheme will need to be detailed and approved on an annual basis in order to ensure they remain appropriate within an ever changing environment. 40 | P a g e 7. Overview of the Healthcare Environment in Namibia 7.1 Overview Namibia has one of the largest income inequalities in the world, with 10% of the highest income households accounting for over 90% of total household income. This poses a serious health care challenge as a vast majority of the population is unable to afford medical scheme contributions (NPC, 2005). This uneven distribution of wealth also results in a small taxpayer base and hence less tax revenue per capita that the government can spend towards the improvement of public health care services for the population. A direct result of lower funding in the public sector is that health professionals are naturally attracted to the private sector, further exacerbating the dis-equilibriums between the rich and the poor. In 2008 it was estimated that there were 8.8 health workers per 1000 population in the private sector, compared to 2.0 in the public sector (the WHO benchmark is 2.5) (MoHSS, 2008). The table below further illustrates the shortage of health care professionals and facilities in Namibia. Health workforce 2000 - 2010 Number 774 3.7 Benchmark density (per 10 000 1 population) 22.4 5 750 27.8 44.5 Dentistry personnel 90 0.4 6.5 Pharmaceutical personnel 376 1.8 3.7 198 1 4.7 Physicians Nursing and midwifery personnel Environment and public health workers Density (per 10 000 population) Infrastructure Hospital beds (2000 – 2009) - 2.7 36 Radiotherapy units (2010) - 0.005 .014 Note: The benchmark is taken to be the average for upper middle income countries as Namibia is classified as an upper middle income country Source: World Health Statistics 2011, World Health Organization 41 | P a g e 7.2 Public Sector The Namibian government is the main provider of healthcare services in Namibia, with the private sector and mission facilities playing supporting roles. The public healthcare sector is managed at two principle levels: 1. The Ministry of Health and Social Services (MoHSS) head office in Windhoek, and 2. The regional level. The MOHSS is responsible for formulating policy, strategic planning, setting legislation & regulation, and co-ordinating functions. The regional level is split into 13 directorates that oversee the implementation of healthcare policies and the provision of health services within the 34 health districts that exist. There are 30 public district hospitals, 44 health centres and 265 clinics that deliver public healthcare provisions. In addition, the district hospitals are supported by three intermediate hospitals as well as one national referral hospital. (MOHSS, 2008) Given the vast geographical size of Namibia relative to its population, health care outreach is critical in order to provide healthcare services. The public healthcare system addresses this problem by providing mobile clinic services at 1 150 outreach points throughout the country. Various mission facilities also play a significant role in the health care industry, although these missions are completely subsidised by the government and are therefore included in the public sector facility numbers quoted above. 7.3 Private Sector The private hospital sector is largely restricted to urban areas and provides health care through 13 medium sized hospitals, 75 primary healthcare clinics, 8 health care centres, 557 medical practitioners and 75 pharmacies. (WHO, Namibia Health Resource Tracking: 2007/08 & 2008/09, 2010) The medical fund industry is regulated by the Medical Aid Funds Act of 1995. This Act also allowed for the formation of the Namibian Association of Medical Aid Funds (NAMAF) as the representative body for the healthcare funding industry tasked to “control, promote, encourage and co-ordinate the establishment, development and functioning of funds in Namibia.” Ministry of Health and Social Services 13 regional directorates 34 health districts 30 public district hospitals 44 health centres 265 clinics 3 intermediate hospitals National referral hospital 1 150 mobile clinics The Namibia Financial Institutions Supervisory Authority (NAMFISA) is a public body responsible for the regulation and supervision of non-banking financial institutions in Namibia, including pension and retirement funds, long-term insurers, short-term insurers and medical aid schemes. 42 | P a g e There are four administrators operating in the Namibian medical scheme environment, providing administration services to nine medical aid funds as illustrated below: Administrator Methealth Namibia Administrators Medscheme Prosperity Health Paramount Medical Aid Fund Scheme Type Closed Bankmed Namibia Health Plan Open Closed Open NAPOTEL Medical Aid Fund Closed Namdeb Medical Aid Scheme Roads Contractor Company (RCC) Medical Aid Fund Renaissance Health Medical Aid Closed Namibia Medical Care PSEMAS Nammed Medical Aid Fund Closed Open Open Private health insurance products are used mostly as top-up cover to the cover provided by medical aid funds. These products fall under the Short-term Insurance Act of 1998. The medical aid fund population is dominated by the Public Service Employees Medical Aid Scheme (PSEMAS). This is a state run scheme, exempt from the Medical Aid Funds Act, with approximately 80 000 principal members and is open to civil servants only. PSEMAS accounts for over 50% of the medical scheme principal member population, with the other schemes consisting of above 60 000 principal members. The total number of beneficiaries covered by medical schemes, including PSEMAS, was approximately 320 000 people during 2010. Given that the total population in 2010 was estimated by the US census bureau to be approximately 2 million, this implies that approximately 1.68 million uncovered Namibians are forced to make use of public health facilities where an out-of-pocket method of payment is required. Therefore, the health coverage of the population in 2010 is illustrated below. Namibian population PSEMAS 8% Other medical funds 7% Uncovered population 85% 43 | P a g e The 2011/12 budget allocated N$ 3.3 billion to the MoHSS, however PSEMAS alone allocated N$ 1.1 billion in its budget for members over the 2011/12 period. (Haufiku, 2011) PSEMAS is heavily subsidised by the Ministry of Finance as the contributions charged are minimal and insufficient to cover the comprehensive set of benefits that are provided. Given steeply rising healthcare costs, the sustainability of PSEMAS is likely to come under increased pressure going forward which in turn reduces funding available to other institutions serving a greater portion of the population, such as the MoHSS. The introduction of the NMBF could be used as a tool to partially correct the inequalities which currently characterise the Namibian health care environment. It is aimed at providing greater financial protection to the Namibian population against the uncertain costs of ill-health. Further detail on the policy objectives of the NMBF and its influence on the Namibian environment are provided in the sections to follow. 44 | P a g e 8. Policy objectives of the NMBF The NMBF aims to be an active step towards improving and/or achieving the following Namibian health system goals and objectives (IMSA, 2009a): 1. Accessibility Formally, accessibility is defined as the proportion of the population that reaches appropriate health services. Access includes the ability of a sick person to gain entry to the system in order to establish a diagnosis and plan therapy. It then also includes the ability to move between differing levels of the system i.e. from primary care to specialist or even highly specialised care. It should be noted that accessibility as defined above is with regards to the prospective members of the NMBF. 2. Financial Accessibility Financial accessibility measures the extent to which people are able to pay for care. 3. Geographical Accessibility Geographical accessibility measures the extent to which services are available and accessible to the population. It is, of course, linked to the distribution of infrastructure in a given region, but also to the actual offering of these services at these facilities. Geographical accessibility will vary according to local means of transportation, as well as the local topography. 4. Universal access to healthcare Universal access to healthcare refers to all people having an equal opportunity to gain entry to a quality accredited health facility for diagnosis and therapy, regardless of their socio-economic class and ability to pay, ethnicity, or physical disability. Accessibility includes not being obstructed by issues of transportation and affordability. 5. Universal coverage Universal coverage is defined by the World Health Organization as: “access to key promotive, preventative, curative and rehabilitative health interventions for all at an affordable cost” (WHO, 2005). 6. Equity in healthcare Equity in healthcare is about fairness and justice in the distribution of costs, benefits, and opportunities in the health sector. Equity is therefore an ethical and subjective concept. Consequently, there are varied views on what equity in the health sector means. Nevertheless, the dominant perspective on equity is that “everyone should have equal opportunities to maximise their health status (irrespective of socio-economic, demographic, and geographic characteristics of different individuals/groups within the population). Accordingly, the incidence of health care financing should be distributed according to ability to pay, and benefits should be distributed according to need. This view (referred to as the egalitarian perspective) has been the guiding principles for many health systems in recent years and is the basis for the definitions below. 7. Equity in health financing Also termed “fair financing”. This is the case where wealthier groups contribute a greater proportion of their income to the overall financing of the healthcare than poorer groups. Equity in health care financing also advocates for the protection for the poor from catastrophic health expenditure. 45 | P a g e 8. Equity in resource allocation Resources for healthcare (clinics, human resources, hospitals, budgets) should be distributed in such a way that gives greater preference to those that have a greater need for healthcare (most vulnerable – poorer, and/or those with greater disease burden). 9. Quality in healthcare The degree to which health services for individuals and populations increase the likelihood of desired health outcomes and are consistent with current professional knowledge. Quality is a perceptual, conditional, and subjective attribute relating to a product or service. Quality in healthcare includes the delivery of safe care that is consistent with current medical knowledge and customer-specific values and expectations. 10. Responsiveness in healthcare The WHO has defined several dimensions of responsiveness. These are: autonomy; information; confidentiality; dignity; prompt attention; quality of basic care; access to social support network; and choice of providers. Responsiveness reflects the individual’s actual experience with a health system. The fundamental goals of a health care system therefore can be expected to improve health outcomes and respond to the legitimate expectations of the population. 11. Sustainability Sustainability of the health sector refers to the ability of the health system (based on its organization, financing mechanism, structure, etc) to adequately generate resources for the provision of good quality health care today and in the future. Implicit in this is the ability of the health system to change with the changing needs of the population that is served. 12. Protect the nation’s health Ultimately, the government aims to safeguard a healthy and productive workforce. This in turn promotes productivity and a growing Gross Domestic Product. A healthy body is more likely to support an enthusiastic work ethic. So, in this sense, the State healthcare policy should pay for itself. Note of course that there are certain prerequisites which are required for a health system to achieve its goals. These include: Ensuring that there are adequate financial resources; trained staff; appropriate facilities, equipment; and pharmaceuticals. The appropriate allocation and utilisation of resources Regulatory framework ensuring stakeholder participation, and relationship management Infrastructure for continuous monitoring and evaluation and clinical governance The NMBF will aim to mobilise further financial resources for health. A dedicated medical fund regulator in Namibia will also be recommended, who will thereby help ensure stakeholder participation and relationship management. The regulator will also be mandated with continuous monitoring and clinical governance. 46 | P a g e 9. Situational Analysis for SHI If the NMBF is to be implemented, then SHI must first and foremost be desirable and feasible. The purpose of this section of the report is to illustrate some of the most pertinent situational issues, in order to set the context of the investigation for the NMBF and hence SHI. The points set out in this discussion are not meant to be exhaustive, but rather intend to inform predictions of why and how implementation difficulties may arise. The situational issues discussed below will be assessed against the NMBF framework discussed in the previous section of the report. It is important to emphasise first and foremost that this is an opportunity to design and implement a solution to ensure the overall sustainability of the health financing system, in the face of an unsustainable PSEMAS and declining projection of donor funding for healthcare (HIV/AIDS programmes in particular). There is no question that PSEMAS in its present form is unsustainable. At the moment, there is no relationship between contributions and costs. Members pay a flat contribution fee of N$60 per member per month (pmpm) versus comparatively massive average claims cost of N$764 pmpm. The Minister of Finance (MoF) funds the above deficit between claims and contributions generated by PSEMAS, and hence ultimately assumes this risk. The MOF funds an equivalent of about 92% of total claims cost. This is unsustainable because PSEMAS is the largest medical scheme provider in Namibia, and it effectively shares MoF financing with the Ministry of Health and Social Services (MoHSS). The following figure shows the increase in total claims cost for PSEMAS from 2007 to 2010: Total Claim Cost to Service Providers by Year Total claims cost (N$) 1000000,000 804736,808 874842,241 800000,000 657038,272 600000,000 558134,109 400000,000 200000,000 2007 2008 2009 2010 Calendar Year Thus, one recommendation is to either repeal or replace the enabling legislation of PSEMAS so that a more sustainable solution is provided. We understand that significant sticking points will lie ahead as PSEMAS is a “condition of service” for government employees and forms part of their benefit package 47 | P a g e expectations, but we believe that the revision of PSEMAS is critical for the attainment of Namibia’s overall health financing solution. Absorption of PSEMAS membership into the NMBF will have a number of advantages and disadvantages. Advantages: The successful implementation of the NMBF would enable the reformation of PSEMAS which is unsustainable in its current form. Currently the MoHSS and PSEMAS are not aligned in their health sustainability objectives. By absorbing PSEMAS membership into NMBF and aligning the objectives with that of the MoHSS, the MoF funding can be shared between the entities in a more transparent and consistent manner. PSEMAS’s data set and membership are comprehensive and may be used to inform the expected membership and claims profile of the population under the NMBF. PSEMAS’s overall shared in-house and out-sourced administration system works well, and this can be leveraged off The NMBF risk pool will be larger with more contributors, and thus the contributory regime will be more financially stable Help align and give impetus to the many debates that are ensuing in the health sector at the moment e.g.: o Equitable resource allocation requirement for a “minimum service package” o Potentially offsetting the expected downward trajectory of donor funding Disadvantages: PSEMAS is a “condition of service” which forms part of government employee benefit package expectations. The removal or downgrading of this benefit will be a major sticking point with the unions who will look to preserve the current benefits enjoyed by government employees. Government approval is required Legislation must be updated The results of our actuarial scenario-based costing exercise will help inform the merits of absorbing PSEMAS members into the NMBF, or at least revising the existing PSEMAS arrangement. Rather than a re-statement of the many debates ensuing in the Namibian health environment, we hope that the NMBF (and hence SHI, leading to a potential NHI) discussion will bring all these debates under one umbrella and thus generate focus. If SHI is neither desirable nor feasible according to the criteria below, then it is important to rather ask how any deficiencies can be countered, rather than completely disregard the imperative for a sustainable health financing solution for Namibia. Before embarking on SHI, it is worth asking five pertinent questions as suggested by the academic literature (Normand & Weber, 2009): What is the current level of employee taxation i.e. personal income tax i.e. payroll deduction, and is it advisable to impose further charges? What is the current level of unemployment, and the income distribution of those employed? Is the formal sector large relative to the informal sector, and will it be possible and economical to collect SHI contributions from the informal sector? Should the emphasis of the SHI benefits package be on curative care versus basic preventative care and health promotion? Is the economy i.e. GDP expected to grow? 48 | P a g e If the answers to these questions may be “no”, then it is absolutely imperative that one or more of the following is carried out: 1. Sound actuarial costings are performed based on a range of SHI scenarios 2. The impact of shifting the taxation burden to another base, e.g. an employer taxation on company profits in the private sector, is tested 3. A phased implementation approach is considered e.g. SHI can have a part to play initially for some groups of the population, as a first step towards a more comprehensive system 4. Alternative health system financing models are considered Of course, the above counter-actions are important even if SHI is neither desirable nor feasible. But the point is that they become even more crucial if SHI is expected to face significant design and implementation challenges. 9.1 Payroll Deduction i.e. Employee Taxation According to the Ministry of Finance (MoF) only 131 247out of 2.2 million (6.0%) pay personal income tax, which is a small payroll tax base. The MoF feels that taxation room exists only on employers in the private sector. However, this base may already face other tax increases e.g.: for the new Education Act, the taxation system proposed is that 2% of company profit must be paid over Other Acts such as the Child Protection Bill are sound in principle but require costing investigations Thus, it can probably be answered that it is not advisable to impose further charges at this stage, at least without due consideration. Rather, a better approach might be to adopt fiscal discipline and move away from a welfare state (to avoid sovereign bankruptcy like countries are experiencing in the EU, and to attract foreign investment in Namibia). However, one may counter this argument and state that PSEMAS is in itself unsustainable, thus making the existing health financing system in Namibia at present unsustainable (because PSEMAS is a large spender of MoF health expenditure). The key point is that the results of the scenario-based costing investigation will inform this debate. 9.2 Unemployment About half of Namibia's labour force are unemployed – the broad unemployment rate was estimated at 51.2% in 2008 i.e. unemployed persons who are not actively looking for work are included (Ministry of Labour and Social Welfare, 2010). The unemployment rates are higher in the younger age groups and consistently fall in the older age groups. Unemployment in Namibia is of a long-term nature (72.2% of the unemployed have been without a job for 2 years or more). The unemployment rate is higher in rural areas (64.9%) than in urban areas (36.4%) Thus, it can probably be answered that the current level of unemployment is not conducive to SHI, at this stage, at least without due consideration. However, one may counter-argue that “job creation” and “healthcare” are inter-connected, and these two issues should not be considered in isolation. Rather, academic studies have shown that ensuring the 49 | P a g e health of the population can contribute positively to productivity, GDP growth, and hence job creation. Therefore, the NMBF and employment might be considered simultaneously. 9.3 Labour market structure SHI is typically funded by a percentage deduction from income. However, the income of the informal sector and self-employed is difficult to assess because: Income tends to be variable It is genuinely difficult to know when a cost has been incurred by the individual or business There are strong incentives for people to understate income SHI therefore works best in the context of a relatively large formal sector. It is more expensive and more difficult to operate SHI under the conditions of a large informal and self-employed sector. We therefore need to assess the labour market structure in Namibia (Ministry of Labour and Social Welfare, 2010). Namibia has a population of approximately 2.2 million. There is a significant formalinformal split of that population: About 60% of the population operate in informal sector employment, in particular in subsistence agriculture Agriculture and fishing employees make up 29.9% of total employment Agriculture, primarily livestock, is a substantial contributor to the economy, but is particularly prone to fluctuations due to weather extremes, suffering from both drought and flood So, it can probably be answered that the formal sector is not large relative to the informal sector, and it may be difficult and expensive to collect SHI contributions from the informal sector. However, because of mining, tourism, and large commercial farms, the formal sector of the economy is proportionately larger than in many African countries. The formal sector in 2008 included about 250 000 employees, which includes 60 000 government employees. 9.4 Burning health priorities and need: curative care or basic preventative care and health promotion? It is important to investigate the burning health needs of the Namibian population by investigating the most recently available morbidity and mortality data procured by the MoHSS, to inform the NMBF benefits that can match the need. The MoHSS provides us with the following mortality and morbidity data for 2010, as extracted from their Health Information System: 50 | P a g e Rank Main causes of morbidity Number Percentage 1 Other respiratory disease 472,734 22.9 2 Musculo-skeletal system disorder 287,959 13.9 3 Skin Diseases 205,393 9.9 4 Common cold 199,084 9.6 5 Trauma 180,007 8.6 6 Diarrhoea without blood 176,608 8.5 7 Nose and throat diseases 175,743 8.5 8 Other Syndrome 171,486 8.3 9 Other Gastro Intestinal diseases 122,570 5.9 10 Contraception, gynaecology, pregnancy and obstetric 80,907 3.9 2,072,491 100 Number Percentage Grand total Rank Main causes of mortality 1 HIV/AIDS 1,811 20.4 2 Diarrhoea, gastroenteritis, presumed infectious 1,578 17.8 3 Pneumonia 1,483 16.7 4 Pulmonary tuberculosis 1,453 16.4 5 Heart failure including CCF 587 6.6 6 Anaemia 549 6.2 7 Malnutrition 410 4.6 8 Hypertension, essential primary 345 3.9 9 Other respiratory system diseases, pneumoconiosis, lung abscess, etc. 336 3.8 10 Stroke, intracranial haemorrhage, cerebral infarction, CVA 319 3.6 8,871 100 Grand total We have two main reservations of the above data, which warrants further substantiation from other sources that inform the chronic disease profile of Namibia: The morbidity and mortality statistics are not explicitly “linked” or they don’t “talk to each other”. It might be informative to obtain data which demonstrates a closer more explicit link between morbidity and mortality in Namibia. Some may argue that it is not strictly true that someone can die from HIV/AIDS. Rather, they may argue that individuals die from other opportunistic infections and co-morbidities. Therefore, it may be informative to obtain a further breakdown/split of the HIV/AIDS death by their key opportunistic infections. However, the above data suggests that Namibia’s key health needs are preventable. For example, effective preventable measures (against largely preventable conditions such as HIV/AIDS, Diarrhoea and Gastroenteritis, Malaria, Pulmonary tuberculosis, Pneumonia, Malnutrition, other respiratory diseases, Heart Failure, and Stroke) can help reduce or avoid downstream (and hence more expensive) health costs. 51 | P a g e Thus, the health priorities of the nation suggest that a large part of the health needs of the population will be met by the continued introduction of preventative care. However, the academic literature, informed by past country experience, suggest that SHI works best for the coverage of curative care (versus preventative care) in both primary and secondary care settings, because this offers a value proposition to the SHI members i.e. people enjoy the benefits of being guaranteed access to treatment in the event of illness (Normand & Weber, 2009). The literature suggests that it is more difficult to fund basic preventative care and health promotion through SHI insurance, than it is to fund curative care. The literature goes on to suggest that if the highest priority is to expand primary health care (PHC) coverage among scattered rural populations, with an emphasis on basic preventative care and health promotion, then it is unlikely that SHI will help to achieve this. A mixture of government funding, with fees and co-payments by patients, and innovative forms of community financing are likely to be more useful for the expansion of preventative care and health promotion services. However, in rebuttal of the above argument, if a residual part of the health needs of the population will be met with the introduction of a NMBF benefits package that is based on curative primary and secondary care (versus preventative care), then SHI will be useful. This is because such a benefits package can be effective in reducing downstream, more expensive hospitalisation costs. In addition, a focus on preventative care via SHI (i.e. the NMBF and the 10 private medical funds) will allow the State to focus its attention and efforts on curative care. 9.5 Projected GDP growth It was identified previously in the literature that an important enabler for SHI is economic growth. The economy contracted by 0.8% in 2009 owing to a sharp drop in diamond production. The GDP forecasts below, provided by the International Monetary Fund (IMF), are reasonable but not exceptional (Korea took 26 years to achieve NHI, with a very high 10% annual economic growth). In addition, the forecasts are estimated as of April 2011, before fears over a double dip recession owing to the Euro Zone crisis became heated. Thus more recent forecasts might be desirable. The table below illustrates the IMF’s GDP growth forecasts for Namibia (Ndjavera, 2011): 52 | P a g e IMF GDP Percentage Change Forecasts 6 GDP Percentage Change 5 4 3 2 1 0 2010 2011 2012 2013 2014 2015 2016 Year Thus, one could argue that the economy is expected to grow, but not to a sufficient extent to fully support the introduction of the NMBF and hence SHI. However, once again, as stated above, health decisions should not be made independently of job creation decisions. This is because the two issues are interconnected, as supported by findings from academic studies. Hence, health and job creation should be viewed in a holistic manner. 53 | P a g e 10. Design Considerations for the NMBF The literature provides for various recommendations on the design of SHI (Hsiao & Shaw, 2006). The design factors are also informed by the lessons learned from the country experience of the aforementioned 5 countries: Kenya, Ghana, Philippines, Colombia and Thailand. SHI must be designed in a way that is not only sufficiently inclusive in terms of benefits, but so that it is affordable and sustainable over time. Moreover, it must be implemented in ways that do not exceed the capacity of health systems and that can be regulated to assure quality. The design of SHI essentially involves maximising social benefits under financial and political constraints. For example, policy makers have to trade-off between the goal of covering as many poor as possible with the goal of offering them a comprehensive benefits package. Meanwhile, the cost of the benefits package is also determined by how the SHI contracts for and pays providers. Policymakers have to decide on at least seven interconnected groups of major questions in order to pursue the goals of SHI: 1. Size of contributory regime? 7. Healthcare delivery improvements? 2. Coverage of poor? SHI Interconnected Decisions 6. SHI governance and administrative structure 5. Fiscal capacity and projected timetable for universal coverage? 3. Coverage of self-employed and informal sector ? 4. Benefits package definition and cost? 54 | P a g e The following describes the seven major groups of questions, as suggested by Hsiao and Shaw: 1. How many people can be enrolled under the contributory regime, who should these people be, and how can premiums be collected from them? The SHI premiums the insured pay are the new source of financing that provides additional funds for health while pooling their risks. 2. How should “poor” be defined, what portion of the poor should be subsidised, how should the subsidy be targeted, how much will this cost, and how will it be financed? Answers to these questions determine the government budget required for funding SHI for the poor, what portion of the poor will gain equal financial access to health care, and to what extent health gains will be produced. 3. How can non-poor self-employed and informal sector workers be enrolled and how can premiums be collected from them? Decisions on these issues influence whether a nation will be able to achieve universal SHI and pool health risks widely and also have the potential to reduce fraudulent claims, because people who are not covered often “borrow” membership cards of those covered so that they can obtain health services. 4. What is the benefits package for each group and how much will it cost? These decisions determine the premium rates for the contributory regime population, the government budget needed to fund the poor, and people’s access to health care and insurance protection. 5. What is the nation’s fiscal capacity to fund the poor and near-poor to achieve universal coverage, and what is the projected timetable for this? Such planning disciplines decision makers in the adoption of a long-term strategy for SHI and considers the steps that have to be taken to achieve universality. 6. How should SHI be governed? Should the SHI agency be a public agency, a quasi-public agency, or a private non-profit entity? What is the best and most viable administrative structure for SHI? Decisions on these matters influence the efficiency and effectiveness of SHI operations. 7. How can SHI improve health care delivery? How should providers be contracted and paid? Decisions pertaining to these issues influence the efficiency, cost, and quality of health care, and in turn the population’s health, the premium rates, and the government’s budget for subsidising the poor. If SHI design and implementation is to be successful, then SHI must adhere to the following design principles: 1. Maximise the overall percentage of population covered by SHI The success of an SHI system depends largely on: The ability to enrol and collect premiums from the contributing population, and The government’s ability to subsidise premiums for the poor The law should define who is eligible to enrol and pay a premium and who will be subsidised. Higher coverage percentages obtained through time are associated with better performance, all else being equal. SHI for developing countries usually divides the population into three groups: 55 | P a g e Group Target population Enrolment and premium collection Compulsory enrolment and payment (contributory regime) Large employers in the formal sector e.g. banks and manufacturing corporations Relatively easy. Voluntary enrolment and payment (contributory regime) a. Employees of small employers b. Informal sector workers e.g. housekeepers, waitrons c. Non-poor self-employed e.g. farmers, fishermen, hunters, shopkeepers, and day labourers Evasion is a challenge. Fully or partially subsidised (subsidised regime) Poor and possibly non-poor Gradually phase in the poor (in the hope that economy will grow and fewer people will need to be subsidised) Feasible if 10 or more employees at employer (international experience). Either: • Identify the poor with a means test • Subsidise groups where the majority of members are easily identifiable as being poor e.g. farmers in certain poor regions, residents of poor districts, elderly, orphans, children, disabled. Corruption is a challenge e.g. local officials award subsidies to relatives, friends, or political supporters 2. Maximise the percentage of the population covered by SHI, by target group Factors relating to the structure of the economy will impact the level of population coverage. For example, it is typically administratively easier to collect contributions from employees in industry, mining, or services sector than from the self-employed. Hence economies with a larger industry, mining, or services sector are likely to have a higher percentage of the population covered by SHI from the outset. Thus, the NMBF implementers may choose to maximise the percentage of the population covered by target group (versus overall). The following benchmark classification, based on typical groups for SHI membership, may be used: 1 = civil servants (including teachers, police, and military personnel) 2 = employees of private and public enterprises 3 = self-employed professionals 4 = casual and migrant workers, agricultural workers and other self-employed 5 = retired civil servants and employees 6= selected groups of the non-working population (e.g. students, disabled, unemployed) Dependants are included in the various categories. Certain population groups are administratively easier to cover than other groups. Therefore, some extensions or expansions in respect of SHI coverage are easier than others. For example, it may be relatively easy to extend health insurance coverage to previously uninsured dependants. For example, at the time of the introduction of SHI in Colombia in 1993, only 20.6% of the total population was affiliated to social security. Four years later, 53% of the population was enrolled. A significant part of the increased coverage was explained by the enrolment of family members of formal sector workers who were already previously insured. 56 | P a g e 3. Set the ratio of prepaid contributions to total costs i.e. the overall prepayment ratio, of the SHI benefit package, at an acceptable rate Prepayment is typically always preferred to out-of-pocket (OOP) payments because prepayment: Is more likely to include the poor: OOP spending restricts access to only those who can afford it, and is likely to exclude the poorest members of society. In contrast, prepayment improves financial accessibility to health care and it offers better protection against the uncertain financial consequences of health care. Improves financial accessibility to the SHI benefit package: The level of prepayment affects how accessible the SHI benefit package will be to the population. The higher the level of prepayment, the greater the SHI benefit package’s accessibility. In particular, co-payments may be so high that access to a number of health services is limited. In essence, the prepayment ratio is important as a measure of financial accessibility. Is a requirement for risk pooling Prepayment is also preferable to OOP payments as it is a requirement for pooling of risks amongst people. Under SHI schemes, prepayment is combined with risk pooling. Thus, a higher prepayment ratio (i.e. the ratio of prepaid contributions to the claims cost of health services under the SHI benefit package) suggests a better performing SHI scheme. However, there are three main caveats: The SHI benefits package must still remain adequate A very high prepayment ratio may imply that the benefit package is very restricted. This is because the state may need to limit the benefit package to allow for financing constraints resulting from subsidising a larger prepayment amount. This is undesirable because many families may still be left to bear significant health care costs OOP, or they simply cannot afford to gain access to certain health services. Therefore, a high ratio of prepaid contributions to the total cost of the SHI benefit package indicates a wellperforming SHI scheme only if the SHI benefit package offered is simultaneously comprehensive. A comprehensive package is generally comprised of outpatient care (primary care, selected specialist services, essential drugs) and inpatient care (including essential drugs and ancillary services, such as laboratory tests). Counter moral hazard with the use of co-payments Moral hazard suggests that individuals may have an ‘excess’ demand for health care at the point of consumption. This is because the price of healthcare for these individuals has been subsidised. However, it can be argued that moral hazard is not that pronounced in health, as one should expect people to prefer being healthy to demanding care. Nevertheless, moral hazard remains an important consideration as once sick, people may want to obtain as much care as possible. Introducing some level of co-payments can counter moral hazard behaviour to some extent. 57 | P a g e Patients may bypass primary care levels and access the health system at inefficient secondary or tertiary levels of care. This can be countered through a gatekeeper mechanism. When there are no financial barriers to demand health care at the various levels of the health care system, families may want to bypass the primary care level and instead enter the health system at a more specialised secondary or tertiary care level. Such practice is inefficient and is likely to contribute to increasing health care costs unnecessarily. Policymakers may assign a gatekeeper role to certain providers, such as GPs, whereby access to higher levels of the health care system is given only in case of need, and upon referral from the GP gatekeepers. For the first two reasons above, a 100% maximisation of the prepayment ratio is not necessarily the best policy. For example, in most European SHI systems, co-payments for health services up to 30% are quite common. Higher co-payments are even possible in the case of certain categories of pharmaceuticals. There is no “one size fits all” prepayment ratio. The need to take account of moral hazard may differ between countries, resulting in different levels of co-payments, and hence different prepayment ratios. Furthermore, the prepayment ratio will depend on a country’s income level. Lower income SHI countries may decide to introduce lower levels of co-payments for certain health services, given that these are unaffordable by the population. International SHI experience is useful in making a recommendation. However, international prepayment ratio data that specifically relate to the SHI benefit package is not explicitly available. As a proxy for the prepayment ratio, data from SHI countries on the ratio of general government expenditure to total health expenditure can be used. The average of these ‘prepayment’ ratios in 27 countries is 71.1%, with 16 countries having a ratio from 70% to 91.9%. The latter range is deemed a sensible guideline for developing countries, in terms of financial protection against health care costs (WHO). The literature therefore recommends the following range for the prepayment ratio in developing countries: 70% to 91.9%. 4. Set the prepayment ratio by target group, at acceptable levels Policymakers may choose to vary the prepayment ratio by target group due to: Different levels of insurance membership between these groups Risk pool fragmentation resulting in different levels of financial risk protection The existence of alternative prepayment mechanisms (such as community based health insurance schemes) that are used more by certain target groups It is however important to aim for similar prepayment ratios for all target groups in order to maintain fairness. 5. Minimise the percentage of households with catastrophic spending Catastrophic spending is defined as 40% or more of a household's effective income, net of subsistence (food) expenditure. Better-performing SHI schemes minimise the percentage of households with catastrophic spending. This is desired as it ensures that prepaid contributions and/or co-payments are affordable to all. 58 | P a g e The prepayment ratio remains important as a measure of financial accessibility. However, minimising the percentage of households with catastrophic spending guarantees the affordability of health care payments, and hence gives a more fundamental measure of the success of a SHI scheme. 6. Minimise fragmentation of the NMBF pool Fragmentation is the existence of too many small risk pools. A fragmented risk pool will: Receive a lower overall amount of contributions Possess limited risk pooling ability If the NMBF offers many benefit options, then this may result in a more limited risk pool per option, and hence the SHI benefit package per option will need to be limited to reduce claim volatility, which places more restrictions on access to health care benefits. In addition this introduces opportunities for anti-selection whereby individuals can select their benefits based on healthcare need. Therefore, it is recommended to rather aim to minimise the level of fragmentation under the NMBF. The NMBF’s target population equals all employees in the formal sector (including self-employed) including those lives who are already insured, and as such is a sufficiently large risk pool in its entirety. Care should be taken when considering options which could excessively fragment this risk pool. A SHI scheme can be made up of either: multiple risk pools/funds, or a single risk pool/fund Given that the NMBF together with the 10 open and closed private medical funds in Namibia will achieve SHI, it is worthwhile considering the advantages and disadvantages of a single fund versus multiple funds. The main argument in favour of multiple risk pools: Competition between funds may result in greater efficiency (under risk adjusted risk equalisation but not without post risk sharing risk equalisation) However, single fund systems remain the most attractive to policy makers because: Minimising the level of fragmentation maximises risk pooling Less money is spent on administration Funds are centrally allocated Even though branch offices in different regions or provinces may not contain costs, financial incentives can encourage efficient administration and contracting with providers Even though regulation (such as open enrolment) is required to limit cream-skimming in a single fund system with branch offices, equivalent regulation would be required under a multiple fund system 7. Make membership compulsory Several problems will arise if membership is voluntary. 59 | P a g e SHI contributions are not risk-based but are instead based on ability to pay. Hence, there will be a significant anti-selection risk IF membership is voluntary. If membership is voluntary, then: • • Higher risk lives and poorer lives are likely to want to join the SHI scheme Lower risk lives and richer lives are not likely to want to join the SHI scheme e.g. in DRC, the wealthiest population group was under-represented in the scheme’s membership Thus, the result is an on average unhealthier risk pool and higher contributions would be required by those who contribute. If this high risk profile is not anticipated and priced for when contributions were set, then financial strain on the NMBF is likely to follow. The fund’s administrators must then intervene to ensure the financial security of the fund, by: • • Revising or restricting the SHI benefit package, or Increasing the SHI contributions paid However, neither of these interventions are solutions to the initial anti-selection problem, but are instead reactive measures that are likely to accentuate the initial problem. The above two interventions are not solutions because there is a risk that any subsequent lapsation/withdrawal is selective. Normal lapsation differs to selective lapsation. Under selective lapsation, the healthier lives lapse or fail to renew their SHI contract instead of paying the increased SHI contribution or accepting the restricted SHI benefit package, while those in poorer health agree to continue or renew their SHI contract. The NMBF must be wary of the better risks choosing to leave, which will cause the overall morbidity experience and hence claims experience for the NMBF as a whole to deteriorate. The fund’s administrators may therefore in the future need to once again increase contributions by a greater than anticipated margin, which would exacerbate the initial problem, as a second bout of lapsation may once again be selective (“vicious circle” or “death spiral” scenario). Selective lapsation can therefore have a destabilising effect on the health profile of the risk pool. The key take-home message from the above discussion is that membership of the SHI funds (whether the NMBF or one of the 10 open and closed schemes) should be compulsory as opposed to voluntary. 8. If the NMBF is going to be priced on solidarity principles, then legislation is required which also imposes such cross-subsidies from rich to poor on all existing open and closed funds to limit anti-selection on the NMBF. It is always possible in setting the prices to be charged to socially-engineer the table to provide relief for vulnerable groups. In medical schemes, elderly pensioners or lower income workers typically favour restricted schemes. This is because an income-rated contribution table provides relief for lower income earners and often pensioner members fall in these lower income groups. It is not usually feasible to do so in open schemes because of the potential anti-selection if only some open schemes follow this route. This is where Government needs to play a role in regulating acceptable crosssubsidies that all open schemes must implement (IMSA, 2009b). 60 | P a g e 9. Ensure the effective collection of finances The chosen sources of funding drive the equity or fairness of the SHI scheme. Equity is also driven by the way SHI contributions are distributed between families with different incomes. The main funding source for SHI schemes are contributions from: Employees Self-employed Typically salary-related and paid in part by the employer Typically flat-rated (much easier to administer) or income-rated (arguably fairer) Those with a higher income will accordingly pay higher contributions. Thus, income-rated contributions are fairer than flat-rated contributions. On the reverse, flat-rated contributions, particularly in countries where it is very hard to properly estimate income for the self-employed, can be time saving and easier to administer. A trade-off between efficiency and equity thus exists. Under an income-rated design, contributions are more equitable but at the expense of higher administrative costs. A compromise would be to have a series, or bands, of flat-rates as an alternative to either a pure income-rated or flat-rated design. This accounts to some extent for individual’s ability to pay, without making administration too expensive and time consuming. Society as a whole may limit the overall degree of equity. When all contributions are pooled and the benefit package is universal, differences in contributions between groups may be excessive and unacceptable to certain individuals. If a significant percentage of the population is reluctant to accept an important implicit redistribution of wealth, then public buy-in and the sustainability of the SHI scheme will be threatened. One way for a SHI scheme to place a limit on the financial solidarity underlying a society is to cap the absolute amount of the salary which is used to calculate contributions. Differences in contribution levels by salary band are therefore reduced. Salary-rated contributions are a relatively sustainable source of revenue, since the contributions increase along with the employees’ income. Salary-rated contributions are subject to fewer yearly budgetary negotiations than general taxation funding. However, salary-rated contribution funding is not completely stable. Under a salary-rated contribution structure, the SHI scheme will collect less revenue in recessions if the workforce shrinks. The revenue amount generated will still depend on the prevailing economic condition, and so the revenue stream is still subject to some volatility. For SHI, the unit of subscription or registration for the above contributions is typically either at the: Family level, or Individual level 61 | P a g e Family level Individual level Advantages: • Increases coverage (due to administrative ease) • Reduces anti-selection (since unhealthy individuals are less likely to register themselves if they have to also register their entire family) Disadvantage: • Likely to incur the highest administrative cost e.g. a health insurance card needs to be delivered to each individual Nonetheless, individual registration may be a better option if fraudulent use of the SHI system can be avoided. However, an important disadvantage is: • Potential fraud, whereby non-contributors claim to be members of a registered family when they are not. • To mitigate this fraud risk, a family and its constituent dependants need to be clearly defined. However, policy makers often wish to cover more of the population than just those who have contributed, such that payroll contributions alone do not produce adequate revenues for SHI financing. Such population groups may include the unemployed, pensioners, students, and the poor, however the inclusion of these broader groups leads to the creation of a National Health Insurance system in which the entire population is eligible for benefits but only those who can afford to contribute do so . Hence in most SHI systems, payroll contributions are supplemented by other revenue-generating mechanisms. Government subsidies through general taxation are typically the primary supplementary funding source. Contributions may typically be supplemented by the other alternative funding sources to ensure equity and sufficient resource generation: Government subsidies and general taxation Earmarked consumption taxes. Earmarked consumption taxes on harmful tobacco and alcohol products and activities can help cover the health care costs incurred from such products and activities. Such taxes can also help alter consumer behaviour. External aid e.g. donors. External aid may be useful in funding specific once-off projects. However external funding is, by nature, only a short-term solution. Co-payments are not a revenue source for the NMBF. Co-payments are used to directly and indirectly control costs. The level of SHI expenditure is directly impacted by the co-payment level. Insured expenditure is lower, the higher the level of the co-payments, all else equal. Claims cost is also indirectly affected through the influence of co-payments on consumer incentives, as in the case of moral hazard above. However, co-payments are not typically a revenue generator for the SHI scheme. Instead, the health care providers typically directly receive the co-payment revenues. Advantages and disadvantages of government subsidies through general taxation: Advantages May be used to subsidise the cost of care for the unemployed, pensioners, students, and the poor in the non-contributory subsidised regime, thereby securing affordability of health care to a greater number of lives. To the extent that vulnerable groups contribute less given their lower ability to pay, government subsidies also improve equity. 62 | P a g e Disadvantages Typically more volatile due to yearly budgetary negotiations, although salary-rated contributions will decrease in a recession. Reduces the independence of the SHI fund from the government budget. May create friction between contributing employees and the subsidised self-employed. For example, in the Republic of Korea in early 1989, SHI membership became compulsory for the urban self-employed. Heated debates on how feasible it was for the government to subsidise the self-employed, ensued between stakeholders. Friction arose, as employees did not like the possible subsidisation of the self-employed. SHI financing for the different population groups therefore became a political issue. Ultimately, a compromise was reached, and government subsidies were implemented to a limited extent only. In 1995, government subsidies amounted to 35% of the urban self-employed health insurance fund. Assessing the fiscal requirements for funding SHI, and the potential to achieve universal coverage is absolutely essential. The major technical issue pertaining to the viability and sustainability of SHI relates to its costs and whether sufficient funding can be provided for it. While the goal may be to establish SHI to achieve universal & equitable access to reasonable health care, the tax funds required to finance it could be prohibitively high. Planning a sustainable SHI requires several rounds of analysis, each of which requires a careful specification of those eligible to be covered, a detailed delineation of the actual benefits package and an actuarial analysis of its costs, as well as an assessment of how the costs will be financed. This process is when noble visions, however worthy, face a reality check. The Kenya case illustrates the fiscal challenge facing the government. The legislation intends to provide universal SHI. Employees in the formal sector will pay a percentage of their wages to cover the full cost of their premiums and others will pay a flat-rate premium. The government planned to impose an 11% value added tax to fully subsidise the poor, who account for around 30% of Kenyans. Even though the president proposed legislation to establish SHI and parliament passed it, the president delayed signing the legislation into law because he was uncertain that the contribution rate will be sufficient to fund SHI in the long term. Ghana established an SHI program in 2003 and issued regulations clarifying the intent of the law in 2004. Ghana’s strategy differs from that of Kenya. Ghana plans to enrol 20% of the total population in three years and 50% of its citizens in 15 years. These seemed to be realistic goals, but whether the Ghanaian community-based insurance scheme can overcome the difficulties of enrolling the poor, non-poor farmers, and informal sector workers to achieve the 50% goal remains to be seen. The Philippines passed a law and established a universal SHI program in 1995, intending to achieve universality by 2005, but 40% of the population still remains uncovered. Most of these are the nearpoor, the non-poor self-employed, and workers in the informal sector. The government stated that its goal was to achieve universality by 2010. Colombia implemented SHI in l993 with the intent of achieving universality within a few years by compromising the benefits package for the poor, who account for 40% of the population. This entailed giving the poor half the benefits that employed workers received. Nevertheless, 11 years later, only 67% of the population was enrolled. The near-poor and informal sector workers have largely remained uncovered by SHI. 63 | P a g e Thailand has just achieved universal coverage. The successful candidate for prime minister in 2001 put universal SHI at the top of his election promises. Once elected, the prime minister allocated sufficient government funds to pay the premium for all the poor, the near-poor, and the non-poor informal sector workers. Nonetheless, their benefits package is less than those employed in the formal sector, which leaves Thailand with a multi-tiered system. Realistically, developing nations may achieve universal coverage in two or three decades if their economies grow rapidly. SHI can first cover civil servants, formal sector employees, and the poor who are being fully subsidised, then move step-by-step to include other groups until universal coverage has been achieved. Worldwide experience indicates that SHI can be effectively implemented in developing countries for formal sector workers plus those who are largely subsidised by the government budget, such as the poor and the near-poor. Enrolling and collecting premiums from non-poor workers in the informal sector and farmers are the major hurdles for universal coverage. It seems that universal coverage can only be attempted with a chance of success when a nation’s economy has grown to approximately US$3,000 per capita per year (as exemplified by Costa Rica and Thailand). 10. The benefits package should adhere to certain broad principles A key policy decision in designing SHI involves what services the benefits package covers. The pooled SHI contributions are used to purchase a specified benefit package to which all insured lives are entitled. The specified benefit package must be clearly defined in a contract between the SHI scheme and the healthcare providers at the respective levels of the health system. Costs are directly related to the comprehensiveness of the benefits package. This issue immediately raises the question of what is affordable for different population groups, for example, self-employed workers may not be able to afford the same benefits package that can be financed by employer and employee contributions. The issue often becomes a choice between: 1. comprehensive benefits with fewer people covered, versus 2. less extensive benefits with more people covered When a country adopts SHI, its government is often unwilling or unable to allocate enough tax funds to finance the same benefits package for the poor as for others. As a result, the poor and the selfemployed often get a much smaller benefits package than those who are employed in the formal sector. As the five country cases illustrate, all five nations except the Philippines have different benefits packages for different groups, with the poor getting much less. In the Philippines, SHI for the poor became a key presidential election strategy to solicit votes from the poor, so full benefits were extended to them. Indeed, the poor are the only group with outpatient benefits. In designing an affordable benefits package, the question arises as to what services should be included. In determining the actual components of the benefit package, the following principles should be followed. The benefit package’s specification should aim to: 3. Be as comprehensive as possible, given the budget constraints of the SHI scheme. 4. Ensure members receive the health benefits that they need. 64 | P a g e 5. There should be no under-provision or over-provision of health care, as this is not in the interest of the patient and the SHI scheme respectively. Therefore, regular monitoring of under- and overprovision is a necessary task of the SHI administration. 6. Account for society’s preferences regarding efficiency and equity, so that resources are used optimally. 7. Policy makers need to decide the relative importance of different efficiency and equity criteria. Clarity on the criteria used is of benefit to all stakeholders who have an interest in the SHI system. A health financing discussion paper (WHO, 2004) proposed the following efficiency and equity criteria: Cost-effectiveness Significant positive impact on an individual’s health or severe health conditions Equality in health over a lifetime Poverty reduction Horizontal equity, defined as “equal treatment for equal need” Collective versus individual responsibility It is very important that efficiency-equity trade-offs are recognised and well understood. For example, very expensive treatments may be part of the benefit package, provided that insurance against the costs of such treatments benefits the vulnerable population and thus contributes to poverty reduction. The relative weighting given to each criterion should broadly reflect the society’s particular preferences. In other words, policy makers may prefer less efficiency in exchange for a greater degree of equity. 11. Put monitoring mechanisms associated with the benefits package in place The following monitoring systems are needed to help ensure that the benefit package is fully received by all the insured lives that are entitled to it: Full information on claimant rights Claimant rights information should be easily available so that members are more likely to access the full range of health services in the SHI benefit package. A patient appeals mechanism This mechanism allows members to complain through the appropriate channels when they feel that they have received inadequate care. A peer review committee to counter under-provision Information on claimant rights and a patient appeals mechanism do not guarantee that patients obtain the correct treatment when they become ill. Patients still need to rely on the health care provider to recommend the appropriate type of treatment, given that the provider is better informed to make such a recommendation. There is an asymmetry of information between the health care provider (the “agent”) and the patient (the “principal”), and the provider makes decisions on behalf of the patient. This is an example of an “agency relationship”. 65 | P a g e In circumstances where the provider has a limited budget and the intervention required is expensive, the agency relationship can lead to the provider under-providing i.e. not providing interventions included in a benefit package to a patient even when the interventions are necessary. A peer review committee can review whether providers have given adequate care, often through analysis of cases brought up through a patient appeals mechanism. A claims review process to counter over-provision Over-provision is also possible, particularly when the provider is reimbursed by the SHI fund on a feefor-service basis. This arises once again due to asymmetric information, yet this time between the insurance fund (the principal) and the health care provider (again the agent). A claims review process, where qualified health personnel employed by the SHI scheme independently review insurance claims, will help ensure that claims made by health care providers are justified. 12. To minimise risks, legal contracts between the NMBF and its providers need to be welldefined. The nature of the contract between the provider and the SHI fund also needs to be carefully designed. The precise terms and conditions in the contract are important, especially because the ultimate decision on whether a patient should receive a particular treatment or not lies with the provider. The potential contestability of the contract is also important. A contract which is regularly contestable is preferable to a long-term fixed contract. This is because contestable contracts would put pressure on the providers to provide good quality care. 13. Ensure that the mix of reimbursement methods promotes optimal resource allocation The purpose of this section is to describe the features and merits of the main reimbursement or payment methods so that an optimal mix of these methods can be chosen. 66 | P a g e Capitation Fee-forservice Per diem Salaries Diagnosis Related Groups (DRGs) Budgets The choice of reimbursement method is a fundamental driver of the provider’s behaviour and can significantly impact both the cost and quality of care provided. Care should be taken to ensure that appropriate incentives are in place that will align the interests of the provider and the scheme. Reimbursement mechanisms utilised can affect the performance of SHI schemes, particularly in relation to potential over- and under- provision of services by providers. The choice of reimbursement method is therefore crucial in guaranteeing optimal resource allocation. It is impossible to unanimously state which provider reimbursement mechanisms are better or worse than others, as each have their relative advantages and disadvantages. Appropriate remedial strategies should be used to ensure that each type of reimbursement method gives the optimal impact on cost containment and quality of care. For each reimbursement method, a brief description and design remedies to ensure better performance are presented. The success of any reimbursement system should be measured by both: The system’s accuracy and lack of bias The extent to which the reimbursement system incentivises provider behaviour in line with social objectives 13.1 Fee-for-service Description: Fee-for-service is a reimbursement method whereby providers are paid for each service provided to a patient. This method encourages providers to provide health services and is perceived to thus be advantageous in terms of service quality. However, this incentive effect is also the method’s main 67 | P a g e source of criticism. Fee-for-service is often criticised for encouraging an overproduction of health services (i.e. supplier-induced demand) because providers are paid for each service given. For the same reason, there is a tendency to reduce the time spent by activity and/or delegate to less qualified health professionals, so the provider can maximise their income. In addition, administrative costs associated with billing costs, reimbursing fees, and monitoring/adjusting fee schedules, are likely to be high. Design remedies: The following strategic interventions can counter over-production: Combining fee-for-service with budgets Adjusting fees after a specified level of services is exceeded Using co-payments for patients Monitoring, such as peer reviews, can also help counter inappropriate delegation and insufficient time spent per activity. Competition between providers can counter the negative quality aspects as a poor quality of service will lead to patients choosing other providers. However, this is limited by the patients’ ability to differentiate between a good and poor quality of service. Such methods have been used in countries such as Japan, Germany, Belgium and Canada. 13.2 Capitation Description: Under a capitation agreement, providers receive a fixed fee per person for services delivered over a specified period. Capitation can be used for both ambulatory and inpatient care. Capitation is easy to administer. However, this is not necessarily the case if the payment is adjusted to reflect the expected morbidity of the population. As providers are not reimbursed according to the quantity of services given to the patient, there is no incentive to over-service. However, capitation encourages underproduction as providers will want to contain costs to improve their profits. Furthermore, referrals and transfers of cases to higher levels of care, which may not be subject to capitated reimbursement, limits this method’s ability to control total claims cost. Design remedies: The following strategic interventions can counter under-provision: Monitor utilisation and occupancy rates Capitate groups of individual providers together, reducing the incentive for any single provider to under-produce Encourage competition between providers, which will motivate providers to provide good quality service For referrals and transfers, monitoring is less essential if capitation payments are paid, not just to one level, but to many levels in an integrated referral system. Use of an integrated referral system is a key design remedy. 68 | P a g e According to Mr Karl Whey of Paramount, it is currently the case in Namibia that only one private medical fund (Nammed, administered by Paramount), has entered into a hospital capitation fee arrangement with a provider group (Medi-Clinic). Since 2008, Nammed entered into a hospital capitation agreement with Medi-Clinic as its Preferred Service Provider. On a monthly basis, the fund looks at the total membership profile. Then, the fund allocates all the lives into age bands e.g. 0-19, 19-39 etc. Thereafter, the fund allocates a risk premium for hospital benefits to each beneficiary. The total risk premium is then calculated and paid to Medi-clinic. During the month, if certain members go to non-Medi-Clinic facilities, then Medi-Clinic pays the non-Medi-Clinic service provider according to the normal NAMAF structure, and subtracts the payment amount from the Medi-Clinic prospective capitation fee payment. During the month, Medi-Clinic submits a summarised monthly account. The fund does not pay these claims because of the capitation agreement. The capitation contract’s duration is the same as the financial year of the fund. It can be expected that this arrangement reduces the volatility of claims payments from the medical scheme. 13.3 Daily (per diem) payment Description: Daily payment of hospital services is simple and cheap to administer. However, if unregulated, then costs may be difficult to control. This is because there is an incentive to extend the length of stay of patients, and to increase the number of admissions or re-admissions. If there is a lack of competition or monitoring, then poor quality services can result. This is because hospitals have an incentive to reduce input costs. Design remedies: In order to provide incentives to shorten the average length of stay, the daily payment can be progressively reduced as the length of stay increases. This is the case in Japan, where basic hospitalisation fees have been progressively reduced, with the per diem rate after ninety days being less than half of the first fourteen days. Competition between providers and monitoring are the main methods for achieving good quality services. 13.4 Diagnosis Related Groups (DRGs) Description: Under DRGs, hospitals are prospectively paid an inclusive flat sum for a patient’s treatment according to the patient’s diagnostic group. DRGs were developed to classify hospital cases into a number of groups. An example of a DRG is “Renal Failure”. This method encourages cost containment because providers are incentivised to be efficient. However, the potential of DRGs to contain costs is limited because providers are incentivised to: Increase the number of admissions (if diagnosis is broadly defined) Diagnose more severe and thus more profitable cases for the provider Transfer the more complicated cases needlessly towards other providers 69 | P a g e Design remedies: To avoid unnecessary admissions, DRGs need to be clearly defined. This however depends on the availability of well coded data. Monitoring will ensure patients are diagnosed correctly and that complicated cases are not needlessly transferred. 13.5 Budgets Description: Budgets, which are often based on historical costs, can be set for providers. If strictly fixed, budgets help control costs. This is because the provider’s reimbursement does not depend on the quantity of health services given to the patient. However, their ability to control total costs is limited if the budget is inadequate and results in others having to provide the necessary care. Furthermore, if budgets are not strictly set, then there may be little incentive for providers to control costs. Transfer or referral of cases, under-production, and waiting lists are also likely. Design remedies: Budgets must be strict. They should not only be based on historical costs, but also primarily on the population’s size and profile and expected morbidity. Regular monitoring is needed to counter under-production and inappropriate referral or transfer of cases. However, monitoring is less essential if budgets are applied to not just to one level, but to many levels, in an integrated referral system. A single budget for an integrated referral system is a key design remedy. 13.6 Salaries Description: Salaries are administratively simple. However, salaries only cover the costs of human resources, and no other provider costs, such as medication and medical equipment. Over-provision is unlikely but under-provision is likely, given that health professionals will be less motivated to earn their salary. In the extreme, providers may decide to additionally or alternatively contract with the private sector. Design remedies: In order to ensure quality, salaries should be linked to performance. Regular monitoring is needed to counter under-production. 70 | P a g e Conclusion Each reimbursement method has advantages and disadvantages. An important consideration is whether the reimbursement method encourages over- or under-provision of services. Therefore, a mix of reimbursement methods is likely to be desirable. For example, policy makers could adjust a basic salary with capitation weighting. This could be combined with fee-for-service reimbursement for particular services, such as immunisations, where high production is clearly preferred. A well-performing SHI system must ensure that providers face appropriate incentives so that optimal resource allocation is achieved. In summary: Reimbursement method Fee-for-service Likely level of provision Over-provision Capitation Daily payment DRGs Budgets Under-provision Over-provision Over-provision Under-provision Salaries Under-provision Key design remedies Combine with budgets Adjust fees when specified quantity is exceeded Integrated referral system Decrease daily payment as length of stay increases Clearly defined diagnostic groups Strict budgets that are not based on historical cost allocations Integrated referral system Link salaries to performance 14. Minimise the percentage of total expenditure on administration expenses Administration expenses arise from the following functions: planning, management, regulation, fund collection, and claims management. In addition, a certain amount of funds should be kept as reserves. These reserves should be sufficient to cover all expected future liabilities, and to act as a cushion against unexpected claim costs. However, the reserves should not be excessively high to ensure that the greatest number of benefits can be paid for. Lower administration expenses do not necessarily translate into a better-performing SHI scheme. This is because additional factors, such as information on claimant rights, claims reviews, a patient appeals mechanism, and a peer review committee are also important for ensuring optimal resource use. However, these monitoring tools come at the expense of increased administrative expenses. The fund administrators must set a target percentage of funds for administration expenses as a benchmark that can be monitored. There is no “one size fits all” percentage. However, the table below provides a recommendation based on the international SHI experience in 20 selected OECD countries. 71 | P a g e Phase of SHI development Objective Before maturity Administration expenses are expected to decrease as SHI is extended (economies of scale and technological advancements). Aim for a minimum of 0.1% reduction per annum. Mature SHI Aim for a maximum percentage of 6-7% Based on international experience data, the average share of administration expenses in health expenditure was 4.2% for a selection of mature SHI systems, with a range from 2% (Japan) to 6.6% (Switzerland). However, it is important to emphasise that some of these expenses may have been under-estimated. The percentage associated with the selected SHI systems demonstrated a decreasing trend over time. Average claims processing expenses decreased over time due to economies of scale and technological advancements. For example, in the Republic of Korea, administration expenses in health expenditure were 11.9% in 1990, but by 1999 had fallen to 6.4%. Furthermore, in a preliminary analysis of 20 OECD countries over the same period, the share of administration expenses reduced on average by 0.1% per annum. Therefore, a maximum percentage of 6-7% is only recommended once a country is already at the later phases of SHI development. Before maturity, administration expenses are expected to decrease as SHI is extended, and this performance must be regularly monitored over time. A minimum of 0.1% reduction per annum, based on the international experience in the selected OECD countries, could be the objective. Performance with respect to the above objectives must be regularly monitored over time. It is important to consider other ways to reduce administration costs, and/or to promote administrative efficiency. For example, the NMBF may choose to exclude particular low-severity high-frequency interventions from the SHI benefit package, which will lead to reduced transaction and hence administration expenses. If such interventions meet the efficiency and equity criteria used to define the SHI benefit package, then policy makers may choose to omit these interventions only if the interventions are easily affordable, and so can be paid for OOP even by the poorer families. The following table provides a high level summary of the countries with national health systems, the type of national health system and the levels of non-healthcare expenditure. This table is not exhaustive and in some instances, no information is available (Colombo & Tapay, 2004). 72 | P a g e Country Australia Canada System Non-health care costs Public health expenditure (% total health expenditure)2 Single-payer National health insurance Medicare in Australia 3.7% of contributions in the year 2001-02. 67.0% (2005) Single-payer Medicare of 0.6% of total public health expenditure (1999) Private insurers (13.2% OECD, 2004a) 70.2% (2005) 2.2% of total public health expenditure (1999) 83.7% (2005) Social insurance models Denmark Single payer National health insurance France Single-payer Social health insurance models Germany Multiple-payer Social health insurance models Ghana 79.9% (2005) Private insurers (14% OECD, 2004a) 77.0% (2005) Multiple payer Proposed national health insurance Kenya Multiple payer National health insurance Mexico A budget of 8% of the total expenditures of the National Social Health Insurance Fund (NSHIF) in 2003 Multiple payer National health insurance Netherlands Multiple payer Combine universal coverage with private insurance and regulated market competition 5% of premiums Private insurers (10.4% OECD, 2004a) South Korea Single payer National Health insurance 3.96% of total health expenditure in 2003 53.7% (2005) Single payer 2.4% of total public health expenditure (1999) 70.6% (2005) Spain National Health insurance Sweden Single payer 81.7% (2005) National Health Service Switzerland Taiwan UK USA Multiple payer Combine universal coverage with private insurance and regulated market competition 5.3% of total public health expenditure (2001) Single payer National Health insurance 1.6% to 3% of total contributions Single payer National Health Service Multiple payer Liberal model – private insurance and public funded programmes, Medicaid and Medicare 2 59.6% (2005) 86.9% (2005) Insurance overheads of 11.7% of premiums. Medicare of 3.6% and Medicaid 6.8% of premiums (Woolhandler et al., 2003). 45.1% (2005) OECD Health Statistics Database 73 | P a g e 15. Ensure an effective governance structure is put in place Governance can be defined as “the structure and processes of the control mechanisms used to hold the SHI agency accountable to beneficiaries and funders (that is, the government and employers) of the scheme” The following critical choices have to be made in relation to SHI governance: Ownership of the SHI agency e.g. public, quasi-public, or private non-profit. Ownership drives an organisation’s motives and purpose. Public organisations are controlled by the government and closely tied to politics and are thus subject to political influence, while private non-profit organisations are more independent and insulated from political interference. Organisational structure, with emphasis on the composition, election, and accountability of board. The organisation can be analysed using principal-agent theory. Beneficiaries and premium payers act as the principals who select and contract the board of directors as their agent to represent and pursue the principals’ interests. In turn, the board contracts with the chief executive officer (CEO) as the agent to pursue the goals set by the board. Hence the composition and election of board members and the determination of how they are accountable to beneficiaries and premium payers become the paramount concern in relation to organisational design. Management structure, which must be given discretion in financial and personnel decisions. The management team must be given discretion in financial and personnel decisions so that it has the power to use financial and human resources to achieve the goals of the SHI agency. For example, if employees of the SHI agency are civil servants, then civil service rules on hiring, promotion, and firing would tie the management team’s hands. Government supervision, with emphasis on society’s interests, original objectives, and funding. The state has to regulate and monitor the operations and performance of the SHI agency for two reasons: first, to assure that SHI serves society’s interests and the original purposes for which it was established and second, to supervise the SHI agency as the government is usually a principal funder of SHI. When a nation decides to establish an SHI agency as a public or quasi-public organisation, it has at least three choices as to which ministry should be responsible for SHI. One of two existing ministries may be responsible for SHI, and each structure has potential problems, inter alia: Ministry Ministry of Health Ministry of Labour and Social Security Challenge Medical Professionals on board are more concerned about the welfare of the supply side than of the demand side The additional revenues generated by the SHI often largely benefit providers Insurance viewed simply as a payment mechanism, rather than as a prudent, organised purchaser for the insured Alternatively, a new independent ministry – the SHI agency – can be established. Most developing nations have placed their new SHI agency under the Ministry of Health, but with other ministers also serving on the supervisory board. Each structure has potential problems. Several studies of SHI agencies organised under the Ministry of Health found discouraging performance, as the ministries were dominated by medical professionals who were more concerned about the welfare of the supply side than of the demand side and the additional revenues generated by the SHI often largely benefited the suppliers of medical services. For example, a study of Colombia (General Comptroller of the Republic 2002) found that the salary of health staff increased by more than 40% in real terms during the initial years of SHI. Similarly, a study of the Philippines (Gertler and Solon 2002) found that 86% of the increased funding for health that became available due to SHI financing went to providers as profits or higher salaries. 74 | P a g e The Ministry of Health and Social Services may not be able to manage SHI any better, however. SHI managed by the Ministry of Labour tends to view insurance simply as a payment mechanism, rather than as a prudent, organised purchaser for the insured. SHI usually focuses on the fund’s balance by controlling what the SHI will pay and shifts the remaining liability to patients. Providers are not prevented from “balance billing” and “extra billing” patients. These SHI systems tend to have low loss ratios and accumulate large surpluses in the SHI fund. In other words, the premiums are not necessarily used for the benefit of the insured. When the Ministry of Health manages SHI, the ministry has to undergo a major transformation because SHI changes the Ministry’s role from a financier and operator of public sector services to one that sets policies and regulates all providers. Generally, Ministries of Health have focused on financing and managing public facilities and their staff, while paying less attention to patients’ wellbeing. Some ministries of health tend to protect the interests of public providers and take a laissezfaire attitude toward private sector providers. If a Ministry of Health starts at such a point, then it will require a major change in its corporate culture for the Ministry to represent patients’ interests effectively. Moreover, to become an effective purchaser requires the Ministry to reorganise its functions and operations. As explained earlier, when developing countries adopt SHI, they generally have to divide the population into different eligible groups, each of which may have a different benefits package, premium and subsidy rate, and enrolment procedures. Hence the question arises whether a nation should have just one fund or separate funds and administrations for each group. This issue often generates furious bureaucratic competition between the Ministry of Health and the Ministry of Labour and Social Security over who controls the fund or funds. In summary, according to the literature, satisfaction of the above key performance indicators and design features will help ensure that SHI achieves its aims and is therefore successful. 75 | P a g e 11. Macro-economic factors impacting the NMBF In order to consider how changes in the macro-environment will affect the implementation of the NMBF, it is necessary to analyse how the: Size Socio-economic status Age structure, and Dependency structure of the Namibian tax paying population will be affected by macro-economic factors. 11.1 Population Demographics The population pyramid below illustrates the age and gender structure of the Namibian population using population statistics as forecasted by the US Census Bureau. Namibian population 2010 100+ 95-99 90-94 85-89 80-84 75-79 70-74 65-69 60-64 55-59 50-54 45-49 40-44 35-39 30-34 25-29 20-24 15-19 10-14 5-9 0-4 -150000 -100000 -50000 Female Population 0 50000 100000 150000 Male Population This population pyramid is characterised by the large proportion of young Namibians. There is significant tapering in the population numbers in age bands above 29 years. The pyramid also narrows in age bands below 10 years, which illustrates the decline in fertility rates experienced in the country. Further evidence on the decline in fertility rates is provided in the Namibia Demographic and Health survey where it was observed that fertility rates declined from 5.4 children per woman in the early 1990s to 3.6 children per woman in 2005-07. 76 | P a g e This young population, combined with the low infant and middle aged to old population numbers has the following direct consequences: 1. Young growing workforce 2. Low dependency ratio 3. Ageing Population Young growing workforce A large portion of the labour force is young and the labour force is likely to grow further with time as these lives age and large cohorts in the younger age bands enter the workforce. As the NMBF will draw its membership base from a subset of the workforce, the NMBF membership structure will assume demographic characteristics similar to the labour force. It is therefore likely that the NMBF will have a young and growing membership base. In medical schemes, it is the young lives which naturally subsidise the older lives in the scheme as young lives are typically healthier and have lower medical claim costs. Therefore, a young membership base will benefit the NMBF in terms of having low average claim costs which will in turn lead to low contribution rates. A growing membership base will place pressure on the schemes administrative and management systems going forward. A robust and scalable administrative system will be required to maintain the schemes administrative integrity as the schemes membership base increases over time. In addition, a growing membership will result in a larger risk pool which will in turn provide greater stabilisation of claims experience over time. Low dependency ratio Namibia is currently enjoying a population structure which is characterised by a low dependency ratio. This means that there is a low proportion of very young and very old lives (i.e. people who are not in the labour force) relative to the population in the labour force. This implies that the average number of dependants on the NMBF will be relatively low. It is important for the NMBF to be aware of the dependency structure of the population when planning for the future and making strategic decisions. In particular, the dependency structure will inform the structure and level of the contributions. The graph below illustrates the US Census Bureau’s projections for the Namibian dependency ratio, where the dependency ratio is defined as the ratio of children aged 0-14 and persons aged 65 years and older per 100 persons in the age group 15-64 years old. It can be seen that the dependency ratio is expected to decline over time until it levels off at 40%. 77 | P a g e Overall dependancy ratio 100.00% 90.00% 80.00% Percentage 70.00% 60.00% 50.00% 40.00% 30.00% 20.00% 10.00% 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 0.00% Year Ageing Population These population demographics are favourable for the NMBF in the short term. However, should the fertility rate continue to decline, the population will experience an aging effect where an increasingly larger proportion of the population is in the older age bands. This will place increased pressure on the workforce to support the older population which usually experience higher average claim costs due to deteriorating health. Therefore, greater subsidisation will be required between the young and the old to support the increased claim costs. In light of recent research confirming the effectiveness of Antiretroviral Treatment in combatting HIV/AIDS and extending the lifetimes of HIV positive people, this aging effect will be further pronounced as the life expectancy of young lives will be extended. 11.2 Economy Economic policy Employment is at the forefront of the political agenda in Namibia, as it is in most developing countries around the world struggling to recover from the aftermath of the global financial crisis. The growth of a nation’s economy along with a growth in its real GDP should result in the creation of more jobs and hence an expansion of the employed portion of the labour force. This means that the membership base of the NMBF should be closely linked to the general state of the economy and level of employment. However, a growing economy does not necessarily translate into an increase in employment. This was noted in the Namibian governments Fiscal Policy Framework for 2009/10 – 2011/12: “Gross Domestic Product (GDP) has maintained an upward trend since 2000/1, but economic growth did not translate into significant employment creation”. Reasons for this disconnect between economic growth and employment is largely due to the inability of recent economic growth to absorb all the new entrants entering the market (i.e. unemployment is outpacing economic growth) Monetary policy Namibia is part of the Common Monetary Area where the member countries’ currencies are pegged to the South African rand (R1 = N$1). This is aimed to ensure that price stability is imported from South Africa as an unpegged currency will be very sensitive to large foreign flows of capital into and out of the relatively small Namibian economy. 78 | P a g e Therefore, In order to analyse the effect of Namibian monetary policy on the NMBF, one will have to consider it in light of the South African monetary policy. This lack of independence limits the Namibian central banks’ ability to achieve economic objectives, such as increasing employment, by utilizing expansionary monetary techniques. However, the South African government has also placed increasing employment on the front of its political agenda, so the countries’ economic objectives are currently aligned. Fiscal policy Following successful fiscal consolidation over the past decade, the Namibian government has recorded fiscal surpluses in 2006/7 and 2007/8. These surpluses have left space for the government to increase expenditure earmarked for targeted sectors of the economy as laid out by the National Planning Commission’s Targeted Intervention Program for Employment and Economic Growth (TIPEEG) document. This 3 year plan, commencing in 2011/12, is aimed at creating jobs for the unskilled youth population in the short term by allocating more resources to labour intensive projects. The document estimates that as many as 104,000 jobs will be created albeit temporary jobs. This surge in employment will directly impact on the NMBF membership base should all go as planned, however the temporary nature of the employment opportunities may mean that the membership base will deplete once the projects are complete. The NMBF administration systems will need to remain flexible in order to effectively handle possible fluctuations in the membership base without compromising the integrity of the administration systems. Fiscal policy may also require adjustment in order to fund the NMBF. This redistribution of the fiscus will impact the current fiscal spending strategies as less money is available for distribution elsewhere. 11.3 Other influences Tax The NMBF may be funded from tax revenue. The level of tax collected will be directly related to the rate of economic growth. A growing economy will be accompanied by a rise in tax revenue, however it may also be accompanied with a growth in employment and hence a larger NMBF membership base. In order to fund the NMBF, the tax rate itself may need to increase. A higher tax rate will also have implications for economic growth, as the population will have less disposable income to spend and drive the economy. This may therefore result in lower economic growth. Healthcare inflation The level of healthcare inflation will impact the cost of claims and hence, future changes in the contribution rates. An inflation level that is higher than expected, will adversely affect the solvency position of the scheme. Furthermore, the majority of healthcare equipment is imported, making the cost of healthcare sensitive to currency movements, in particular, the US dollar and the Euro. Should the Namibian dollar depreciate relative to these two currencies, the cost of healthcare in Namibian dollars will increase. There is therefore significant currency exposure for the NMBF which the Namibian government will be unable to directly affect using monetary operations due its pegged exchange rate. Scheme investments The funding position of a medical scheme is determined by the difference between the scheme investments and the schemes liabilities (including expenses). The larger the investment base relative to the schemes liabilities, the healthier the funding position will be. 79 | P a g e In a fast growing economy, the scheme investments are expected to grow and improve the funding position of the scheme. A growing economy will also bring about higher tax revenue which could result in increased funding for the NMBF. On the other hand, a slow growing or recessionary economy is likely to negatively impact the funding position as the investment returns may remain stagnant and tax revenues may decrease. These effects are particularly significant for the NMBF compared to other private medical schemes which are not dependent on tax revenue as a funding mechanism. 11.4 Social trends and technology The trend towards healthy living has been well documented in developed countries, with the adoption of healthier eating habits as well as the development of more active lifestyles leading to less illness and longer life expectancies. These trends have been instituted into medical scheme structures by the inclusion of wellness packages as part of the overall medical scheme package offered to members. A wellness package typically offers members benefits such as reduced gym rates and other related deals which are meant to improve the members’ health and hence reduce the probability of claim while keeping the scheme highly marketable. A big concern of these packages is that they are expensive to implement, and the reduced claim benefits are typically only recognised over a long period of time. However, given the social trend towards more healthy lifestyles, the wellness packages act as powerful marketing tools which attract lives interested in the benefits of a wellness package (and therefore are more likely to be, or become, healthier). The argument is therefore that the wellness packages pay for themselves and more over the long term. One of the risks identified above is that if the NMBF is implemented in an environment where private schemes exist as direct competitors there will be a risk of anti-selection if more risky lives opt to join the NMBF, due to factors such as a cheaper contribution rate compared to private schemes for a similar package of benefits. By using a wellness program as part of the NMBF benefit package, this antiselection effect can be mitigated and possibly turned into a positive effect. 80 | P a g e 12. Administration of the NMBF The process of administration consists of a number of functions. The following graphic illustrates the functions at a high level with the corresponding flow of information. 12.1 Technical requirements Correspondence management services i. Implementation and maintenance of an accurate receiving, routing, recording and distribution system for all paper and electronic correspondence, including complaints, submitted to the NMBF by beneficiaries, healthcare service providers and stakeholders sent from within and outside Namibian borders. 81 | P a g e ii. Ensure the availability of Call Centre services with representation of all the official languages including the implementation of an efficient record keeping of all calls and correspondence by capturing and maintaining all data and documentation. iii. Establishing information and data management control processes including the maintenance of an audit trail for correspondence management and records. iv. Ensure that all NMBF communication with beneficiaries, healthcare service providers and stakeholders is undertaken in simple and easily understandable language for the elimination of ambiguity and misunderstanding. v. Provision for comprehensive off-site data storage, back-up and disaster recovery processes in compliance with accepted industry norms and standards. Membership management services i. Implementation and maintenance of an accurate receiving and processing system for all applications for membership enrolment and alterations. Membership resignations will not be applicable. ii. Contributions a. Implementation and maintenance of a contribution management system that ensures accurate billing and contribution collection according to the Scheme Rules. b. Successful integration with the various payroll management systems of participating employers. c. Implementation of framework to actively manage debt and ensure the distribution of debt letters and/or emails to debtors. d. Correct suspension of member benefits when contributions and monies owed are not paid within the period specified by the NMBF and/or the relevant legislation. iii. Implementation and maintenance of an information and data management system including the establishment of control processes. iv. Implementation and maintenance of a communication management system to ensure that all NMBF communication to beneficiaries and healthcare service providers regarding the processing of membership and claims information is carried out accordingly as determined by the NMBF. v. Ensure the availability of complete and accurate historical membership and claims data to the NMBF for the purpose of analysis as determined by the NMBF. vi. Provision for comprehensive off-site data storage, back-up and disaster recovery processes in compliance with accepted industry norms and standards. Claims management services i. Implementation and maintenance of an accurate receiving and processing, including real-time processing, system for all claims submitted either electronically or by paper to the NMBF. The system must facilitate accurate and consistent processing of claims against all benefit categories and option rules; the validation thereof and the maintenance of comprehensive and accurate patient records. 82 | P a g e ii. The management of claim submission errors and claim processing errors through the verification of services delivered, correct claiming behaviour and claims processing practices and the maintenance of sound controls for the reprocessing of claims. iii. Ensure regular and ad-hoc claim service audits. iv. Provision for comprehensive off-site data storage, back-up and disaster recovery processes in compliance with accepted industry norms and standards. Financial management services i. Provision for a sound financial investment strategy for beneficiaries’ contributions in full compliance with the relevant legislation and/or regulation. ii. Making suitable use of custodianship agreements for the assets of the NMBF. iii. All transactions and payments to and from the NMBF are to be handled in accordance with any applicable tax legislation. The technical requirements as presented above are not exhaustive and are meant to illustrate the core functions of administration of a medical aid fund. 12.2 Model options The administration of the NMBF could be carried out by implementing one of the following model options: Agency Model (Outsourcing) Self-Administration A combination of the above A “phased-in” approach The option chosen would have to accommodate the technical requirements of the administrative functions as set out above. Outsourcing Advantages of outsourcing the administration of the NMBF would include being able to leverage off the technical and functional expertise and experience that the administrator would have in administering medical aid funds. In doing so the SSC would obtain more certainty over the administrative expenses of the NMBF, since fees would be negotiated in advance, and hence would experience a lower risk of expense overruns. Though, an important consideration regarding this notion would be that fees charged by the administrator may be high, especially at times of renegotiation. The loss of control of the daily operations of the NMBF and the associated limitations to making desired changes to these operations would be a disadvantage that could be managed and countered in establishing detailed Service Level Agreements with the administrator to minimise this loss of control. An additional negative consideration would be that there is a risk that the administrator would provide either no or poor data to the SSC regarding the NMBF when requested. As a result of the above mentioned issues, it is worth noting that the relationship with the administrator would have to be constantly managed to achieve the desired outcomes. If the SSC decides to outsource the administration of the funds, the SSC will need to look for an administrator with the following key characteristics: 83 | P a g e Good reputation Fit and proper management Financially sound Sufficient past experience with the funds requiring administration Appropriate infrastructure and systems to support the requirements of the funds and very importantly, which have the capacity to undertake the scale of membership expected. It is likely that no matter which administrator is chosen, their systems will need to be adapted to the structure of the funds. Self – Administration The primary advantage of self-administering the fund would be having absolute control over the operations of the NMBF and the associated costs. However, doing so requires extensive experience and expertise in the administration of these types of funds and their respective complexities in order to function effectively. Significant initial costs would be incurred in deciding to self–administer the NMBF including: upgrading the current IT systems and infrastructure to the sophisticated systems that would be required in order to carry out effective operations, recruiting and training new staff (including training current staff), and possibly purchasing or building new office space in order to accommodate the new staff. A social advantage to this notion though, would be the resulting job creation and development. Combination of Self-administration and Outsourcing Under this scenario, the SSC would decide which funds and functions to self-administer and which to outsource to a third party. This decision would be based on all of the considerations outlined in the selfadministration and outsourcing sections, as well as the expected time to implementation of the NMBF which will be the ultimate determinant of what is feasible within that timeframe. For example, should the SSC improve its systems to the extent that the backlogs are removed and data quality is improved prior to the introduction of the NMBF, then it may choose to self-administer these funds. However if these problems persist the option to outsource administration will need to be seriously considered. Certain functions are likely to be outsourced regardless of the SSC, such as the investment management of the NMBF’s assets. It may be advisable to appoint an investment consultant able to provide advice on the suitable placement of assets with asset managers in accordance with relevant NAMFISA regulations. It is important to consider this option in light of the current situation where there is a lack of integration between the operational and financial systems. By outsourcing one function and keeping another related function in-house, this integration problem could be further worsened and hence pushed further outside of the SSC’s control. It is therefore important that the combination of functions selected to outsource are chosen wisely to prevent a worsening of integration issues. The SSC will also need to ensure that members are made aware of which functions are outsourced and which are performed internally and the separation of functions needs to be reasonable to prevent any confusion. It is also crucial that there is clear communication between the fund and the outsourced administrator to ensure that each party understands their duties. In addition, each party’s functions should be clearly defined, e.g. with the use of detailed Service Level Agreements, to ensure the smooth operation of the NMBF. Outsource with the intention of phasing in Self-administration This option would provide the SSC with sufficient time to build the appropriate systems and functions, source the necessary skills and staffing requirements, and accumulate the start-up funds required to 84 | P a g e administer the fund. It presents a natural solution to the situation where the NMBF would be implemented prior to the suitable improvement of the current SSC IT systems and processes. During this period, the SSC would also be able to assess the strengths and weaknesses of the administrative methods and systems adopted by the third party administrator, and use this knowledge to improve on their own envisaged structures. Although the SSC would have limited control of the administration of the funds and possibly pay high administrative fees, this initial cost would be small in comparison to the amounts that will be saved once self-administration is phased in. The phasing-in process will however be quite complex and intricate as all the data would need to be transferred from one system to another without disrupting the ability of the SSC to perform its functions. Furthermore, beneficiaries and other key stakeholders would need to be informed of all developments in the process. Legal considerations The Social Security Act of 1994 contains two stipulations which may prohibit, or restrict, the extent to which outsourcing of the administration system is permissible: “15. (1) Every person engaged in carrying out any provision of this Act shall preserve and aid in preserving secrecy in relation to all matters that may come to his or her knowledge in the exercise of the powers or the performance of the duties and functions conferred or imposed upon him or her in terms of any provision of this Act, and shall not communicate any such matter to any other person or permit any other person to have access to any documents in his or her possession or custody, except in so far as any such communication (a) is made in the ordinary course of the exercise of his or her powers or the performance of his or her duties under this Act or any other law, or is required by an order of a competent court; (b) is effected with the prior permission in writing of the person concerned.” “16. (1) The Commission shall, in accordance with sound business principles, administer every fund referred to in paragraph (a) of subsection (1) of section 9.” It is recommended that legal advice is obtained before embarking on an outsourcing strategy which may be in contravention of the above stipulation. Furthermore, clarity on the scope for any such outsourcing activity permissible under the act should be obtained. Considerations to be made in deciding whether to outsource the administration of the NMBF: As mentioned above the consequences of the possible legal restriction stipulated in the Social Security Act of 1994 should first be explored as this could completely rule out the use of outsourcing or a combination of outsourcing and self-administration along with the advantages of using these approaches. Subject to the above statement, the key characteristics of a suitable administrator to which the administration could be outsourced (mentioned under “Outsourcing” above) should be considered. In particular it should be investigated whether one administrator has the capacity to solely administer the NMBF or, failing this, whether different functions of the administration process should be outsourced to a number of different administrators. 85 | P a g e An independent assessment of the time and cost that would be required in order to establish an adequate in-house administrative function should be done and the results should be compared to the expected cost of outsourcing the administration to a third party administrator. A compromise of either a combination approach or outsourcing with the intention of phasing in self-administration should be considered as this may be an appropriate and practical way to successfully achieve the aim of the SSC to self–administer the NMBF, 86 | P a g e 13. Investment Strategy The investment return assumption used in our financial model depends on the investment strategy assumed for the NMBF. Given that the contribution rate each year will change, the NMBF can be seen to contract with its members on an annually renewable basis. As such, the NMBF can be viewed as a medical fund with short-term liabilities. Normally, traditional private medical insurance (PMI) and its variations (such as the NMBF) are short-tail businesses with little scope for significant investment return. The reserves will be relatively small and the investment period is relatively short. The reserves are relatively small because it is hoped that, at least approximately, the premium income from all the members should be sufficient to pay for the claims of the unfortunate few, and to cover the company's expenses. However, assets will still be required, so normally a mixture of cash and securities such as short-term fixed-interest bonds would be suitable. Short-term assets are appropriate for most of these indemnity short-term liabilities. In addition, the NMBF may occasionally need to establish reserves where it is aware of future treatment that could persist over some future years, as well to allow for large unexpected future claims. It then becomes important to monitor the likely costs arising from the various treatments which are covered under the NMBF. The amounts payable will be unknown at the time of setting these provisions, and any current costs will escalate in line with medical inflation (often higher than price inflation) prior to final settlement. Hence the assets recommended in these circumstances should be those that are expected to provide a "real" return over the period until the case fully runs off the books. Index-linked bonds may go some way to matching the liability in these cases, although claims costs may inflate at a greater speed than the index (medical inflation is likely to be greater than price inflation). If this is the case, then other asset classes that traditionally give higher long-term real returns may be more suitable, such as equities and property. However, the volatility of such assets needs to be borne in mind. 87 | P a g e 14. Stakeholder considerations The formation of the NMBF and the various forms which it could assume will have different effects on the various stakeholders involved in the process. This section identifies the main stakeholders which will be affected by the implementation of such a fund and attempts to crystallize the high-level significance of the NMBF from their points of view. Social Security Commission The SSC is a direct stakeholder in the NMBF. The founding legislation of the SSC contains a requirement to set up a National Medical Benefit Fund. The SSC faces the challenge of fulfilling the charge placed upon it by the Social Security Act as well as developing an equitable solution taking account of all stakeholder views. This need to find an equitable solution is enhanced by virtue of the fact that the commissioners of the SSC are represented by individuals who in turn represent diverse interest groups (for example both the MoHSS and Ministry of Labour have SSC representatives). Ministry of Health and Social Services The MoHSS receives its funding from the Ministry of Finance. Given the decrease in donor funding from USAID to Namibia after being classified as middle-upper income country, as well as a decrease in future donor funding due to poor international economic conditions, the Ministry of Finance funding is crucial. The establishment of an NMBF will also likely be funded by the Ministry of Finance. The implications are that the MoHSS could receive a smaller proportion of financing going forward as the NMBF is allocated its share of funding. The MoHSS will also want to ensure that Namibian healthcare outcomes, following the establishment of the NMBF, do not face any threats due to funding issues going forward. NAMFISA The Namibia Financial Institutions Supervisory Authority (NAMFISA) is responsible for the regulation and supervision of non-banking financial institutions in Namibia, including pension and retirement funds, longterm insurers, short-term insurers and medical aid schemes. NAMFISA has expressed a willingness to regulate the NMBF, assuming that the NMBF is run like a medical aid. NAMFISA will then also be faced with the role of educating the public regarding the NMBF. It will also need to consider the legislation which will govern the NMBF. If the NMBF is to be exempt from the Medical Schemes Act, as is currently the case for PSEMAS, then NAMFISA will need to consider what laws are applicable to inform regulation of the NMBF. NAMFISA may need to table new legislation or create regulations aimed at providing a legal structure within which the NMBF must operate. 88 | P a g e PSEMAS PSEMAS is a key stakeholder in the formation of the NMBF for many reasons. PSEMAS and the NMBF will share funding which is received from the Ministry of Finance. The form the NMBF will take is particularly relevant to PSEMAS because it could be decided to merge the two groups or keep them separate. A merging of the schemes will beg the question of whether or not the benefit structure and contribution rates will remain unchanged. The current unsustainable nature of PSEMAS could therefore worsen considerably with the addition of new lives from the NMBF. Alternatively the introduction of the NMBF as a merged fund with PSEMAS could present an opportunity to develop a more sustainable design structure which can also benefit further from a larger risk pool. Ministry of Labour The Ministry of Labour and labour unions will be concerned how the NMBF will impact the workforce. In particular, the labour unions will be concerned about a potential decrease in benefits offered by PSEMAS as a result of it potentially being merged with the NMBF. Namibian government employees have an expectation of excellent medical benefits upon employment due to the PSEMAS benefit package (“a condition of employment”). Labour unions will be opposed to a reduction in these benefits as it negatively affects the labour union members, a large portion of who work for the Namibian government. However, to a certain extent, labour unions will be attracted to the idea of subsidized healthcare for their members assuming that the NMBF contributions incorporate an element of contribution subsidization. Employers Employers will be faced with additional legislative as well as administrative requirements to ensure all their employees are on a registered medical scheme. There may be other concerns for employers as far as co-payments or higher tax charges may apply in order to fund the NMBF. Taxpayers The taxpayer stakeholders can effectively be broken down into two groups: those that are currently already members of a medical aid fund (covered lives) and those that are uncovered. The covered taxpayers will be influenced by the NMBF to the extent to which the NMBF is subsidized based on deductions from all employees’ salaries (for example, a higher income tax or an explicit NMBF deduction) 89 | P a g e Uncovered taxpayers will be directly affected as they are the target population. If membership of the NMBF is made compulsory for uncovered taxpayers then this group will be affected in terms of being forced to join the NMBF. This will be associated with the compulsory contribution rates payable to the NMBF or higher income tax rates depending on the chosen financing method. 90 | P a g e 15. Design of the NMBF 15.1 Overview: Defining a target population The health care environment has changed substantially from that which was envisioned when the legislation was originally created. There is an established private medical scheme sector which provides coverage to a fair portion of the employed population including a large state fund (PSEMAS) that provides comprehensive coverage to over a quarter of the estimated employed population. Medical scheme enrolment is not mandatory and thus a significant portion of the employed population remains uncovered. The NMBF aims to address this issue. In specifying the target population for the NMBF, all the relevant stakeholders must be considered as well as the overarching objective of the legislation which is to ensure that the entire employed population has medical coverage in the first step towards achieving universal coverage. The current medical scheme environment and distinct population groupings, identified in the illustration below, form the building blocks for a variety of potential target populations for the NMBF. Furthermore, the subgroups below were used as a basis for the costing exercise performed and informed the demographic and claims profile expected under the NMBF. Total Namibian population 2 165 828 Total employed population (including self employed) 279 446 Covered population (principal members) 149 696 PSEMAS (principal members) 85 885 Total unemployed population 1 886 381 Uncovered population 115 938 Other medical schemes (principal members) 63 811 *Please note that these estimated numbers are as at 2012. *The total employed population does not divide equally between the sub-blocks due to uncovered population including all beneficiaries, whereas the covered population will only include principal members. 91 | P a g e In terms of defining a population for the NMBF, the Social Security Act of 1994 states the following regarding the membership of the NMBF: “…every employer shall, in the prescribed manner and within the prescribed period, register (a) himself or herself with the Commission as an employer; and (b) every employee employed by him or her, as an employee,” Critically, Section 20 (1) of the existing Social Security Act firmly defines the envisaged target population for the NMBF as follows: The NMBF requires registration of every employee of every employer “Except if he or she is a member of any other medical aid fund or scheme approved by the Minister on recommendation of the Commission” Therefore the legislation defines the target population to be all employed lives, including the selfemployed, that are not currently members of a medical scheme. It is important to consider the status of PSEMAS in so far as medical scheme status is concerned. PSEMAS is exempted from the Medical Schemes Act and therefore by implication also from the ambit of NAMFISA, the regulator for the medical scheme environment. Therefore PSEMAS is not necessarily a medical scheme in terms of its legal status, however it does provide coverage for medical costs to the government employees of Namibia. The population can therefore also be divided along the lines of those employed by government and those that are not. This is shown below diagrammatically. Total Namibian population 2 165 828 Total employed population (including self employed) 279 446 Government employees 122 483 PSEMAS (principals) 85 885 Total unemployed population 1 886 381 Non-government employees (including self employed) 156 963 Non-PSEMAS (uncovered) 36 598 Non-medical scheme (uncovered) 79 339 Medical scheme 63 811 *The government employee data is as provided by the Ministry of Finance income data, whereas the PSEMAS principals were provided by the PSEMAS administrator. * The non-government employees population does not divide equally between the sub-blocks due to uncovered population including all beneficiaries, whereas the covered population will only include principal members. 92 | P a g e The objective of the NMBF is to provide medical cover for those employees who do not currently have medical scheme coverage. We recommend that a phased approach be adopted as follows: Phase 1: The current PSEMAS population forms the basis of the NMBF. Phase 2: The NMBF is extended to include government employees who are currently not covered by PSEMAS or another medical scheme (for example through their spouses’ medical scheme membership) Phase 3: Solidarity is achieved through the inclusion of non-government employees (with the selfemployed) who are not members of a medical scheme The above therefore ultimately covers all employed individuals that are not members of a medical scheme. This is outlined in the graphic below. Phase 1: PSEMAS lives Phase 2: Government employees not on a medical scheme Phase 3: Employed not on a medical scheme The details of the phased approach are outlined below: Phase 1: NMBF coverage commencing with PSEMAS We recommend that the NMBF be based on the current PSEMAS lives. This could be achieved by adjusting the current benefits of PSEMAS to provide a benefit design that meets the needs of the government employees and their dependents while at the same time controlling costs. We recommend that benefit package continue to provide for hospitalization benefits in the public sector. There are advantages and disadvantages of this approach. Advantages The risk pool created is large thus enabling effective risk pooling and cross subsidization. The Ministry of Finance would no longer be required to bear the responsibility of financing and managing PSEMAS. The coverage of this population enables the restructuring of PSEMAS so that it can be managed on a more sustainable basis. The SSC could negotiate favourable tariffs on behalf of the NMBF thus improving the management of costs. This group of lives provides a platform for the building of the NMBF. 93 | P a g e Disadvantages PSEMAS is a benefit available to all government employees. Any alterations to the structure of this benefit will require approval and the necessary buy-in from relevant stakeholders. The Namibian population, for the purposes of eligibility of the fund would become divided along type of employment which may create distortions in the medical scheme risk pools. There may be anti-selective movements by currently employed and covered individuals towards the NMBF if this package is deemed to be more attractive financially compared to current medical scheme benefits available in the market (for government employees). NMBF would need to demonstrate an ability to improve the claims costs of current PSEMAS lives in order to create an appropriate basis for this fund. Phase 2: NMBF coverage extended to include government employees who are not on PSEMAS Once the SSC has established the NMBF based on the current PSEMAS group of lives, it is recommended that the risk pool be expanded to include all government employees (and their dependents) who are not covered by PSEMAS. This group of lives consists mostly of lower income lives who have not joined PSEMAS due to affordability constraints. These lives are also correspondingly older compared to the covered lives. These demographic features are summarized in the following section of the report. The inclusion of more lives within the existing PSEMAS risk pool may enable more cross subsidization and thus improve the achievement of better healthcare for more individuals. This further enables bulk tariff negotiation and expansion of healthcare benefits in this risk pool. The Fund becomes an effective basis for the creation of a solidarity environment. The expected claiming costs of this group of lives is not known. It is likely that the claims for these lives may be lower than that of the existing group during the first few years of joining the fund. Thereafter, their costs may increase, the extent of which depends on changes in demographics, claims behavior, availability of benefits and knowledge of benefits. Phase 3: Inclusion of those employed but not on a medical scheme We recommend that the final phase of coverage for the fund be for those who are employed but not a member of a medical scheme. This includes the self-employed. The characteristics of the employed uncovered lives are not known. There is a risk of anti-selective movements from existing medical schemes towards the NMBF should this package be deemed more attractive than medical scheme benefits. Therefore, the eligibility for the NMBF will need to take this into account. The mandate of the SSC for the NMBF precludes the coverage of the medical scheme population; therefore this risk pool remains within the existing medical scheme environment. 94 | P a g e 15.2 Estimating the covered population size and profile Data The following data sources were used to estimate the size of the various population groups: Data Employed population Current medical scheme beneficiaries Current spouses per principal member Population growth rates Government employees income data Year Source 2008 Namibian Labour Force Survey 2010 Methealth, Medscheme, Prosperity Health and Paramount administrators 2008 - 2012 2012 UN population projections to 2025 Ministry of Finance Methodology This section provides a description of each subgroup of the population that was considered as a potential target population for the NMBF and hence, an input into the costing exercise performed. In addition, this section specifies the methodology utilized and the assumptions required to estimate the size and demographic profile of these subgroups. Covered population The covered population encompasses the total number of principal members currently on medical schemes in Namibia (including PSEMAS lives). This population was calculated via a detailed analysis of medical scheme data provided by all the medical aid fund administrators in Namibia for the 2010 calendar year. This number was then increased by the growth rate implied by UN projection numbers to arrive at the mid-year 2012 total covered taxpaying population principle member numbers, split by age and gender. Therefore the assumption applied is that the medical scheme lives increase in the same proportion as the total population. This may not be the case in practise as medical scheme participation rates are dependent on a number of factors including affordability, necessity etc. PSEMAS population The total number of principal members currently on PSEMAS is a subset of the covered population data described above. This number was then increased by the growth rate implied by UN projection numbers to arrive at the mid-year 2012 total covered PSEMAS principal member numbers, split by age and gender. The assumption applied is similar to the above. Employed uncovered population 95 | P a g e The estimation of the number of employed lives currently not on a medical scheme presented a challenge due to a lack of data available. Preliminary research failed to identify existing literature which empirically estimated the uncovered taxpaying populations at a level of detail sufficient for our purposes. The original data analysis involved the use of taxpayer data from the Ministry of Finance (based on tax returns). However when comparing this data to the medical scheme population data, as well as the 2008 Namibian Labour Force Survey, these numbers appeared too low to serve as an initial estimate of the potential medical scheme population. Therefore, the following five-step process was used to estimate this population: Step 1: The total full-time employed population was taken as per the Namibia Labour Force Survey 2008. This amounts to 269,491 (as at 2008) people. The full-time population excludes temporary employed persons who are unlikely to form part of the medical scheme population. The age distribution was assumed to be the same as the employed population as per the Namibia Labour Force Survey 2008. Step 2: This number of full time employed people was then increased by the growth rate implied by UN population projection numbers to calculate the mid-year 2010 full-time employed population. This was done to ensure that the estimated population, based on 2008 labour force data, was consistent with the 2010 medical scheme data used later in the analysis. The resulting estimate of full time employed people is therefore 274,626. Step 3: The number of 2010 principal members on medical schemes in Namibia, split by age band and gender, were then subtracted from the above to leave the number of uncovered taxpayers. However, this number will include employed people who are covered as dependents on their spouse’s scheme. Step 4: Due to poor quality data being provided by medical aid scheme administrators, the number of married principal members and hence the number of spouses on medical schemes in Namibia had to be estimated. This was carried out by assuming that if a principal member had an adult dependant of the opposite sex and whose age was within seven years of the principal member’s age, then this adult dependant was treated as the spouse of the principal member. The result implies that about 23% of all principal members are married and 74% of all adult dependants in the medical scheme industry are spouses. In order to obtain the total uncovered tax-paying population, the number of employed spouses need to be subtracted from the resultant figure of Step 3. The number of employed spouses were estimated by multiplying the total number of spouse dependants on current medical schemes by 50%. The 50% adjustment estimate was not based on an empirical data analysis due to a lack of relevant data. A 100% adjustment would imply that all spouses of medical scheme members are employed, which is an unlikely occurrence so we would expect this adjustment to be somewhat less than 100%. Another factor to consider when estimating this percentage adjustment is that the lower the assumed percentage, the higher the estimated NMBF target population, and hence the more prudent the assumption. 96 | P a g e Given the relatively small effect of this adjustment, due to a small percentage of spouses, as well as a desire to avoid spurious accuracy, a 50% adjustment was deemed satisfactory for the purpose of this exercise Please see the appendix. We are now left with the total uncovered taxpaying population. Step 5: This number was then increased by the growth rate implied by UN projection numbers to arrive at the mid-year 2012 total uncovered taxpaying population numbers. It is therefore effectively assumed that the number of medical scheme lives and uncovered taxpaying lives increase at the same rate as the total population as implied by the UN projections. Total taxpaying population This is the sum of the covered and uncovered population groups described above. Government employed uncovered population The government employed uncovered population refers to all government employees who are not PSEMAS members. Older age bands were assumed to be equal to the number of people in the estimated uncovered population (this adjustment was applied only where the age band totals would have been higher than the corresponding uncovered population numbers). This adjustment was made to allow for the following concerns: The income data did not confirm if a particular government employee is a member on a medical scheme other than PSEMAS. Given the relative ease for a government employee to leave and rejoin PSEMAS as required, the income data was deemed to underestimate the effective membership claiming exposure. There were a high proportion of government employees at older ages (15% were older than 60; 4.5% older than 65) which suggests that they were retired yet have still been captured in the data. Uncovered including PSEMAS This is the sum of the uncovered and PSEMAS population groups described above. Results Total population estimates The estimated total population sizes for 2012, split by gender, are provided below. 97 | P a g e Population group Males Females Total Covered population (incl. PSEMAS)* 84 006 65 690 149 696 Employed uncovered population 63 712 52 226 115 938 PSEMAS* 45 090 40 795 85 885 Total taxpaying population 147 718 117 916 265 634 Employed uncovered incl. PSEMAS 108 801 93 020 201 822 Government uncovered population 14 215 14 754 * this estimate refers to principal members only, therefore excludes dependents 28 969 These estimated total population numbers are illustrated in the diagram below. Approximately 44% of the taxpaying population is estimated to be uncovered. Split of taxpaying population Covered (excl. PSEMAS) 24% PSEMAS 32% Uncovered 44% * Please note that the above covered and Psemas numbers do not include dependents. Detailed population estimations by age band are provided in Annexure A. Age distribution The analysis of Namibian medical scheme data revealed a distinct dip in principal medical scheme lives below the age of 30. This reveals that many young, employed individuals in the Namibian work force do not join a medical scheme. The estimated uncovered population should therefore be larger at these younger age bands to account for these young employed lives currently not on medical schemes. 98 | P a g e The age profiles of the principal members on PSEMAS compared to government employees not on PSEMAS is shown below. It can be seen that the latter are older on average. The age profile of the PSEMAS dependents reflects that most dependents are children. Very few dependents are parents of the government employees on PSEMAS. The population pyramids below reflect the age differences by gender for the uncovered and covered populations. 99 | P a g e Uncovered population 65+ 55-59 45-49 35-39 25-29 15-19 20 000 15 000 10 000 5 000 0 Female 5 000 10 000 15 000 20 000 Male Covered population 65+ 55-59 45-49 35-39 25-29 15-19 15 000 10 000 5 000 0 Female 5 000 10 000 15 000 Male When considering the taxpaying population as a whole, the population pyramid is more reflective of the entire Namibian population age structure as it is less biased towards older or younger members: Covered & Uncovered population 65+ 55-59 45-49 35-39 25-29 15-19 30 000 20 000 10 000 0 Female 10 000 20 000 30 000 Male 100 | P a g e Gender distribution The gender distribution of PSEMAS lives is very similar to government employees not on PSEMAS. Medical scheme lives (excluding PSEMAS) have a significantly higher proportion of male beneficiaries older than 60 years. Percentage of female beneficiaries Gender profile of Beneficiaries 90.0% 80.0% 70.0% 60.0% 50.0% 40.0% 30.0% 20.0% 10.0% 0.0% Gov employees not on PSEMAS PSEMAS Principals Members Medical fund industry (excl. PSEMAS) Income distribution Income information was provided to Deloitte for government employees. We were able to split out PSEMAS lives and non-PSEMAS lives. The income distributions is significantly different with the latter showing more lower income lives. There are however higher income lives who are not on PSEMAS which could possibly reflect anti-selective behavior. One of the objectives of the NMBF is to provide social solidarity therefore it is necessary to cover this group of lives. 101 | P a g e Note: This graph is based on all uncovered government employee lives prior to the abovementioned adjustment to the older age bands. The effect of changed tax thresholds on population projections Since the population projection methodology uses the full time employed population, as per the 2008 Labour Force Survey, and not the number of taxpayers, our calculations will not be affected by a change in tax thresholds. The table below compares the total number of taxpayers in 2008, as provided by the Ministry of Finance, to the 2008 full-time employed population used in this analysis: Full-time employed population 2008 Taxpayers 2008 269 491 156 935 Not all full time employed Namibians pay tax, therefore, depending on the funding approach to be taken, the use of taxpayers only would under-represent the employed membership base, while on the other hand, the use of the full time employed population would overstate the number of tax payers that could support this through personal income tax. MSD membership vs. Estimated full-time employed population The total estimated full-time employed population in this report (279 446) differs to the membership figure for the MSD fund (398 786) stated in a draft of the report concerning the effects of contribution changes to the ECF and MSD funds. The report was submitted to the SSC by Jacques Malan Consultants & Actuaries (Jacques Malan) in April 2012. (Jacques Malan Actuaries & Consultants, 2012). However, the age distribution of the estimated full-time employed population as stated in this report is closely consistent with the age distribution of the MSD membership stated in the Jacques Malan report, as is illustrated in the diagram overleaf. As the estimated NMBF costs are sensitive to the age distribution, rather than the absolute population size, this difference in population sizes does not affect the results of the costing exercise. In addition the MSD data that Deloitte has received is not consistent with the reported membership statistics in the Jacques Malan report. This could be attributed to a number of reasons, the main 102 | P a g e contributing factor being the poor quality of the MSD membership data: unreasonable ages for employees and unreasonable income e.g. N$ 1. 15.3 Membership Options This section explores the various possible membership base combinations for the NMBF, detailing the advantages and disadvantages of each membership base. The membership bases considered here are: PSEMAS PSEMAS and uncovered government employees Uncovered population Uncovered and Medical scheme population Uncovered population and PSEMAS Uncovered, PSEMAS and Medical scheme population Prior to analyzing the different membership bases, it is necessary to draw a distinction between nongovernment employed uncovered lives and government employed uncovered lives. This distinction is important when considering the advantages and disadvantages of various membership bases as the options available to the two groups differ. Government-employed uncovered lives will have an option to join PSEMAS whereas currently uncovered non-government lives do not have this option. This distinction bears particular relevance to the following membership bases: Uncovered plus medical scheme lives Uncovered lives This is further discussed below within the two affected membership base sections. 103 | P a g e PSEMAS Description: This group represents the current PSEMAS membership and their dependents. Advantages No reform. Under this arrangement the medical fund industry remains unchanged, thereby avoiding a reform of the industry required under other scenarios which require a consolidation of the medical schemes industry. PSEMAS reform PSEMAS in its current form has been described as unsustainable. This may represent an opportunity to re-visit the pricing and financing structure of the PSEMAS structure and create one which is more sustainable in the long run. Avoids implementation resistance (PSEMAS). This option also avoids the implementation risks posed by altering the PSEMAS structure. PSEMAS is an employee benefit so it will be very difficult to remove or reduce the benefits. (e.g. resistance from labour unions, political resistance and legal resistance). Disadvantages Implementation resistance (PSEMAS). Should the PSEMAS benefit and contribution structure change as it is transitioned to an NMBF package then this could encounter strong political and legal resistance. Legislative risk. This membership base will not satisfy the SSC Act in its current form as it does not include currently uncovered lives. It is therefore not consistent with legislation. 99 | P a g e PSEMAS and Uncovered Government Employees Description: The current PSEMAS membership in addition to the uncovered government employees and their dependents. Advantages No reform. Under this arrangement the medical fund industry remains unchanged, thereby avoiding a reform of the industry required under other scenarios which require a consolidation of the medical schemes industry. PSEMAS reform PSEMAS in its current form has been described as unsustainable. This may represent an opportunity to re-visit the pricing and financing structure of the PSEMAS structure and create one which is more sustainable in the long run. Avoids implementation resistance (PSEMAS). This option also avoids the implementation risks posed by altering the PSEMAS structure (e.g. resistance from labour unions, political resistance and legal resistance). Ease of extension to uncovered government employees. By making PSEMAS membership compulsory for all government employees, this option will be able to extend cover to uncovered government employees relatively easily. However there will likely be need for greater subsidies in order to make the contributions affordable to the uncovered government employees. Disadvantages Buy-down risk (cross benefit option). There is a risk of buydown between NMBF benefit options. For example, healthier people may choose the less comprehensive benefit option leaving the comprehensive benefit option with a more risky risk pool. Implementation resistance (PSEMAS). Under this arrangement the increased financing requirements involved with a larger membership base will likely result in the current subsidy arrangement enjoyed by PSEMAS members to be drastically reduced. This proposition is likely to meet political and legal resistance. Older lives. The uncovered government population has an older age structure compared to the PSEMAS lives. An older population will be more prone to disease and other health related expenditure hence resulting in higher costs and higher contributions rates. Financing. One reason these lives may not be PSEMAS members is because they cannot afford the already heavily subsidised premiums. Therefore the contributions will need to be further subsidised to make it affordable to this group, thereby leading to financing risk. Legislative risk. This membership base will not satisfy the SSC Act in its current form as it does not include currently uncovered lives from the private sector. It is therefore not consistent with legislation. 100 | P a g e Uncovered Description: Consists of those employed individuals who are not members of a medical scheme nor are they PSEMAS members. Under this scenario a distinction needs to be drawn between uncovered-government employees and other uncovered employed. This is because uncovered government employees will have a choice of joining either PSEMAS or the NMBF, dependent on which fund ultimately provides a better value proposition. Advantages Younger members. The uncovered population has been estimated to have a young age structure. A young population will be less prone to disease and other health related expenditure hence resulting in lower costs and lower contributions rates. However the effects of HIV AIDS in eroding age cross subsidies (as AIDS prevalence is generally higher in younger age groups) will tend to counteract this advantage. No reform. Under this arrangement the medical fund industry remains unchanged. This means that a reform of the entire medical scheme industry, as required under other scenarios explored later, is avoided. Avoids implementation resistance (PSEMAS). This option also avoids the implementation risks posed by altering the PSEMAS structure (e.g. resistance from labour unions, political resistance and legal resistance). Disadvantages Small risk pool. This will result in a small and concentrated risk pool. The age distribution is heavily skewed to younger ages and they are expected to be in lower income groups. Hence there will be limited scope for risk and income crosssubsidisation. Buy-down risk (cross sector). There is a risk of buy-down between sectors, where people move from the private medical fund industry into the NMBF as it may be cheaper (due to contribution subsidies). The subsidised contributions may mean that the medical fund industry is not able to compete on a cost basis with the NMBF, thereby leading to an eventual transformation of the industry into catering to people seeking more comprehensive cover. This competitive concern may result in opposition from the medical fund industry hence there will be a trade-off between subsidised contributions (and medical fund industry opposition) and un-subsidised contributions (leading to lack of NMBF affordability). Pricing risk. The lack of data regarding the uncovered population means that the demographics of the population used in setting and costing benefit packages may be different to that expected. This could lead to inappropriate costing of the benefit packages resulting in pricing risk. This is worsened by the lack of information regarding the claiming patterns of the uncovered population. 101 | P a g e Uncovered and Medical Schemes Description: Combines the current medical scheme population with those employed who are not currently on a medical scheme. Under this scenario a distinction needs to be drawn between uncovered-government employees and other uncovered taxpayers. This is because uncovered government employees will have a choice of joining either PSEMAS or the NMBF, dependent on which fund ultimately provides a better value proposition. Advantages: Large risk pool. The risk pool under this option will be large and varied. The benefits of a larger and more varied risk pool are a more stable claims experience (which limits the extent of pricing risk) as well as greater opportunities to allow for income and risk cross-subsidisation when setting contribution rates. Younger members. The uncovered population has been estimated to have a young age structure, which will allow for risk cross-subsidisation between the new younger members and the older medical scheme members. However the effects of HIV AIDS in eroding age cross subsidies (as AIDS prevalence is higher in younger age groups) will tend to counteract this advantage. Avoids implementation resistance (PSEMAS). This option avoids the implementation risks posed by altering the PSEMAS structure (e.g. resistance from labour unions, political resistance and legal resistance). Disadvantages Reform. This arrangement will require a consolidation of the medical scheme industry. The necessity for reform will likely encounter substantial political and legal resistance from the medical scheme industry. Affordability. There will likely be extensive income crosssubsidisation between current medical scheme members and the uncovered members in order to keep it affordable for the uncovered population. This is based on the assumption that a large portion of the uncovered population currently forgoes medical scheme coverage due largely to income constraints. The result will be higher contribution rates for medical scheme members, compared with what is currently paid, in order to subsidise the uncovered members’ contributions for affordability reasons. The nature of the income cross-subsidisation will depend on the financing method chosen. Buy-down risk (cross sector). There may be buy-down risk. Uncovered-government and covered-government employees will face a choice between the NMBF and PSEMAS membership. Should the NMBF cost/benefit ratio be superior to PSEMAS then they will be likely to join the NMBF and vice versa if the cost/benefit ratio is inferior. 102 | P a g e Uncovered and PSEMAS Description: Consists of those taxpayers who are not members of a medical scheme in addition to the current PSEMAS members. Advantages Large risk pool. This will result in a larger and more varied risk pool than PSEMAS currently consists of. The benefits of a larger and more varied risk pool are a more stable claims experience (which limits the extent of pricing risk) as well as greater opportunities to allow for income and risk crosssubsidisation when setting contribution rates. Younger members. The uncovered population has been estimated to have a young age structure, which will allow for risk cross-subsidisation between the new younger members and the older PSEMAS members. However the effects of HIV AIDS in eroding age cross subsidies (as AIDS prevalence is generally higher in younger age groups) will tend to counteract this advantage. No reform. Under this arrangement the medical fund industry remains unchanged, thereby avoiding a reform of the industry required under other scenarios which require a consolidation of the medical schemes industry. PSEMAS reform. PSEMAS in its current form has been described as unsustainable. This may represent an opportunity to re-visit the pricing and financing structure of the PSEMAS structure and create one which is more sustainable in the long run. Disadvantages Implementation resistance (PSEMAS). Under this arrangement the increased financing requirements involved with a larger membership base will likely result in the current subsidy arrangement enjoyed by PSEMAS members to be drastically reduced. This proposition is likely to meet political and legal resistance. Buy-down risk (cross sector). There is a large risk of buydown between sectors, where people move from the private medical fund industry into the NMBF as it may be cheaper (due to contribution subsidies). The subsidised contributions may mean that the medical fund industry is not able to compete on a cost basis with the NMBF, thereby leading to an eventual transformation of the industry into catering to people seeking more comprehensive cover. This competitive concern may result in opposition from the medical fund industry hence there will be a trade-off between subsidised contributions (and medical fund industry opposition) and un-subsidised contributions (leading to lack of NMBF affordability). 103 | P a g e Uncovered, PSEMAS and Medical Schemes Description: The largest possible target membership base (i.e. the total employed population). This group will ensure that the entire taxpaying population is on one medical fund. The literature review on social health insurance models highlights the principle of compulsion which ensures that the social security system operates at an optimal level. This membership base is formed by making it compulsory for all taxpayers to join the NMBF and is therefore the optimal grouping within a social solidarity context. Advantages: Large risk pool. This option represents the largest and most varied risk pool, and as such would benefit the most from a stable experience as well as risk and income crosssubsidisation opportunities. PSEMAS reform. PSEMAS in its current form has been described as unsustainable. This may represent an opportunity to re-visit the pricing and financing structure of the PSEMAS structure and create one which is more sustainable in the long run. Achieves social health insurance. This grouping includes all employed people and hence satisfies the definition of social health insurance. An important advantage of this position is that, should the political will exist, Namibia will be faced with a less daunting task in order to achieve universal coverage via national health insurance in the future. Disadvantages Reform. This arrangement will require a consolidation of the medical scheme industry. The necessity for reform will likely encounter substantial political and legal resistance from the medical scheme industry. Implementation resistance (PSEMAS). Under this arrangement the increased financing requirements involved with a larger membership base will likely result in the current subsidy arrangement enjoyed by PSEMAS members to be drastically reduced. This proposition is likely to meet political and legal resistance. Buy-down risk (cross benefit options). There is a risk of buydown between NMBF benefit options. For example, healthier people may choose the less comprehensive benefit option leaving the comprehensive benefit option with a more risky risk pool. 104 | P a g e 15.4 Actuarial costing of benefit packages The feasibility of the NMBF rests in the design and level of benefits offered and its associated costs. This report has detailed the design of the Fund from a Social Health Insurance perspective and expands on the key requirements and principles to be met. This section of the report details the design and its implication from an actuarial and insurance perspective, including the benefits to be offered under various health packages and its associated cost implications. In general, healthcare benefits on a medical fund/scheme can be classified into the following high-level benefit categories: Hospital benefits Emergency evacuation Chronic care Day-to-day benefits Major disease benefit The cost of a healthcare benefit package is a function of a number of factors including: The type of benefits offered e.g. Are day-to-day benefits included? Will chronic care be covered? etc. The limits applied to the various benefits e.g. Will hospital benefits be unlimited? What limits are applied to out-of-hospital diagnostic and preventative care? etc. Re-imbursement of service providers e.g. Will providers be reimbursed at 100% or higher than the NAMAF tariff? etc. Demographic and health profile of the lives to be covered Thus, balancing the cost of a benefit package and providing comprehensive benefits is a delicate task. In designing the benefit package, the following factors need to be considered: past utilisation patterns amongst the covered lives occupational health priorities of employer groups disease burden of the country competitor product offerings This approach to benefit design will most likely result in a benefit package that is marketable and addresses the health needs of the concerned population. However, benefit design alone does not provide sufficient tools for ensuring both cost-effective healthcare delivery as well as sustainability of the Fund. The Fund will need to consider a range of more direct interventions such as managed care and contracting with providers to control claim costs whilst still maintaining quality of care. These recommendations will be discussed in a later section of the report. Based on the above considerations, we have considered three illustrative benefit packages for the NMBF, namely: 106 | P a g e 1) “Hospital” benefit package which covers: a. Hospital benefits (private hospitalization) b. Emergency evacuation c. Major disease benefit 2) “Hospital plus Day to Day” benefit package which covers: a. Hospital benefits (private hospitalization) b. Emergency evacuation c. Chronic care d. Day-to-day benefits e. Major disease benefit 3) “Adjusted PSEMAS package” which covers: a. Hospital benefits (public sector only) b. Day-to-day benefits It is important to note that PSEMAS affords cover only in Windhoek Central Hospital (public sector hospital) while the Hospital and Hospital plus Day to Day packages are based on private sector hospitalization. Data received We received the following data for the purposes of costing benefits for the NMBF: Medical scheme demographic and claims data per benefit option covering all Namibian medical scheme benefit options. PSEMAS demographic and claims data. Demographic data for all the government employees The above claims data sets are for the calendar year 2010 and are therefore fully run off. 107 | P a g e “Hospital” benefit package In order to understand the total costs associated with a hospital benefit package, the claim experience of a number of hospital options in Namibia were analyzed. In doing so, the benefits offered and risk profiles were compared to ensure consistency across the different options. Costs were standardized to allow for differing benefit levels and age distributions between options, where applicable. Based on the data provided, practice code descriptions were subsequently used to map claim costs to various benefit categories as per the benefit schedules. However, this approach limited the extent to which certain hospitalization benefits such as maternity, major diseases etc. could be identified. On further analysis it was confirmed that these costs were implicit in the hospitalization practice code. Once practice codes were mapped to the various benefits, claim costs were modeled by calculating the claim frequency and severity using past experience for the various benefits. This provided an initial cost per family based on the benefit offering. In order to extrapolate this experience to be applicable to the proposed covered lives on the NMBF, statistical models were applied to unpack the drivers of claim experience. Due to limitations in the data provided we were only able to allow for the impact of a difference in age profile between the investigated population and that to be covered on the NMBF. In the absence of a desirable volume of relevant medical scheme data with respect to Hospital benefit packages having definite reliability and consistency, the representative benefit package was also adjusted in light of comparable South African experience to ensure the reasonability of the constituents of the benefit package. It is important to note that the South African medical scheme database used accounts for approximately 4 million beneficiaries ensuring that the sample size is sufficient. In addition, benefit schedules were reviewed to ensure that benefits are comparable in this regard and hence claim costs will not be distorted by the availability of benefit. In addition, the costs implicitly reflect current management practices and hence improvements in claim costs associated with better benefit, case and hospital management have not been included. Therefore it should be noted that future management practices will have an impact on the level of costs arising from the NMBF. Apart from the costs, the age profile of the South African database was compared to the medical scheme population of Namibia, to ensure that claiming behavior would be comparable and claim costs not distorted due to differing risk profiles. This is shown below: 108 | P a g e Age A: Under 1 B: 1-4 C: 5-9 D: 10-14 E: 15-19 F: 20-24 G: 25-29 H: 30-34 I: 35-39 J: 40-44 K: 45-49 L: 50-54 M: 55-59 N: 60-64 O: 65-69 P: 70-74 Q: 75-79 R: 80-84 S: 85+ South African Database 0.00% 0.00% 0.00% 0.00% 0.04% 3.29% 13.07% 16.67% 19.09% 16.68% 13.07% 9.01% 5.24% 2.43% 0.84% 0.38% 0.14% 0.03% 0.01% Medical Scheme Population Namibia 0.01% 0.01% 0.03% 0.06% 0.54% 7.32% 13.88% 15.28% 14.18% 13.36% 13.34% 9.68% 5.83% 2.99% 1.52% 1.01% 0.58% 0.27% 0.11% From the above table, it can be seen that the underlying age distribution is negligibly different between the South African database and the medical scheme population in Namibia. Therefore the application of the South African database is deemed reasonable for the purposes of this study. Benefit package based on Hospital plan costs It is important to note that the claim costs shown below are based on 2010 claim experience. The costs are grossed up by approximated health care cost inflation to reflect 2012 values. Costs shown are based on tariff amount and not claimed amount i.e. the costs assume that the Fund would pay a 100% of NAMAF tariffs. In addition, the costs implicitly reflect current management practices of the underlying benefit packages used in the calculations as explained above. This implies that differences in claim costs associated with better or worse benefit, case and hospital management have not been included. The table below summarises our recommended Hospital benefit package and the associated costs per family per month. The benefit package has been designed to ensure consistency with current benefit levels offered in the market and simultaneously address the basic health concerns of the Namibian employed population. 109 | P a g e *All benefits are subject to prior approval and the overall annual limit **Private Wards are excluded *Benefit Overall Annual Limit (OAL) Recommendation 1.5 million per family General Hospitalisation **Accommodation and Theatre Fees Medicine Blood Transfusions Expected Cost per family per month Unlimited (subject to OAL) Maternity Confinement fees - including full procedure 2D Sonar Scans Unlimited (subject to OAL) maximum of 3 days for normal delivery and 4 days for caesarean 2 Scans N$793.64 Oncology All services (including chemicals) N$300 000 per family Internal Prosthesis Includes all materials used and actual cost of prosthesis N$30 000 per family Specified Illness Condition Organ Transplants - Full procedure N$400 000 per family Renal Dialysis N$150 000 per family HIV/AIDS (in-hospital) Unlimited (subject to OAL) General Practitioners/Medical Specialists Consultation Unlimited (subject to OAL) Procedures Dentistry Maxillo Facial Unlimited (subject to OAL) Oral/Trauma Surgery Diagnostics Advanced Radiology (in and out-of-hospital) N$10 000 per family Basic Radiology and Pathology (in-hospital) Unlimited (subject to OAL) Mental Health Mental Health Psychiatric Treatment (inclusive of medication) N$20 000 per family Other Services (subject to OAL) Physiotherapy (in-hospital) Unlimited (subject to OAL) Private Nursing N$3000 per family Emergency services Unlimited (subject to OAL) Total 2010 Total 2012 N$174.31 N$0.40 N$95.63 N$0.51 N$8.20 N$1.95 N$17.21 N$1091.86 N$ 1196.68 Furthermore, the costs for the South African experience shown below provide a comparative basis and a reasonability check on the expected base costs (as described above) per family per month for the hospital benefit packages currently found within the medical scheme environment in Namibia. 110 | P a g e Costs are shown per family per month as at 2010 which are again increased by approximate health care inflation to reflect 2012 values. South African Experience Per family per month Expected Hospital benefit Per family per month R820.84 N$793.64 R201.32 N$174.31 R0.40 N$0.40 Diagnostics R123.94 N$95.63 Mental Health R14.53 N$0.51 Physiotherapy (in-hospital) R20.44 N$8.20 Private Nursing R10.92 N$1.95 Benefit General Hospitalisation Maternity Oncology Internal prosthesis Specified Illness Condition General Practitioners/Medical Specialists Dentistry Emergency services R16.39 N$17.21 Total 2010 R 1208.78 N$1091.86 Total 2012 R 1324.82 N$ 1196.68 Overall, it can be seen that the expected cost of this package is reasonable and consistent with industry experience. The differences in mental health and physiotherapy claim costs are a function of “medical practice/culture” in South Africa. “Hospital + Day to Day” benefit package A similar analysis as per the Hospital package was performed to determine the costs associated with a Hospital + Day to Day benefit package i.e. the claim experience of a number of options with comparable day-to-day benefits in Namibia were analyzed. In doing so, the benefits offered and risk profiles were compared to ensure consistency. Costs were standardized to allow for differing benefit levels and age distributions between options, where applicable. It is important to note that the costs shown below are based on 2010 claim experience. These costs are grossed up by approximated health care cost inflation to reflect end of year 2012 values. Costs shown are based on tariff amount and not claimed amount i.e. the costs assume that the Fund would pay a 100% of NAMAF tariffs. Due to limitations in the coding of the medical scheme data, in-hospital and out-of-hospital claims could not be segregated at the desired level. However, based on the discipline and practice code, claims were mapped to the various benefit categories. In addition, the costs implicitly reflect current management practices and hence improvements in claim costs associated with better benefit, case and hospital management have not been included. As stated above, it should be noted that future management practices will have an impact on the level of costs arising from the NMBF. 111 | P a g e Similarly to the hospital option, to ensure that the cost per family quoted below is both reasonable as well as consistent with industry experience, a comparison to the South African medical scheme industry was performed. It is important to note that the South African medical scheme database used accounts for approximately 4 million beneficiaries ensuring that the sample size is sufficient. In addition, benefit schedules were reviewed to ensure that benefits are comparable. The table below summarises our recommended Hospital + Day to Day benefit package and the associated costs per family per month. The benefit package has been designed to ensure consistency with current benefit levels offered in the market and simultaneously address the health needs of the Namibian employed population. 112 | P a g e Benefit Recommendation Overall Annual Limit (OAL) 1.75 million General Hospitalisation Accommodation and Theatre Fees Medicine Expected Cost per family per month Unlimited (subject to OAL) Blood Transfusions Maternity Unlimited (subject to OAL) maximum of 3 days for normal delivery and 4 days for caesarean 2 Scans Confinement fees - including full procedure 2D Sonar Scans Oncology All services (including chemicals) N$758.91 N$300 000 per family Internal prosthesis Includes all materials used and actual cost of prosthesis N$35 000 per family Specified Illness condition Organ Transplants - Full procedure N$400 000 per family Renal Dialysis N$150 000 per family HIV/AIDS (in-hospital) Unlimited (subject to OAL) General Practitioners/Medical Specialists Consultation and Procedures (in-hospital) Unlimited (subject to OAL) Consultations and out-of-hospital services (out-of-hospital) N$384.66 N$5 500 per family Dentistry Maxillo Facial Unlimited (subject to OAL) Oral/Trauma Surgery Basic Dentistry (out-of-hospital) Specialised Dentistry (out-of-hospital) Limit of N$11 000 per family with sublimit of N$4 500 for basic dentistry Orthodontics Dental Implants - Full procedure N$118.09 Optical N$2 700 per family over two year benefit cycle i.e. frame every two years Eye Examinations/Consultations Spectacles and Lenses N$67.74 Diagnostics Advanced Radiology (in and out-of-hospital) N$12 500 per family Basic Radiology and Pathology (in-hospital) Unlimited (subject to OAL) Basic Pathology and Radiology (out-of-hospital) N$187.58 N$4 500 per family Mental Health Mental Health Psychiatric Treatment (inclusive of medication) N$25 000 per family N$3.85 113 | P a g e Allied Health Services Chiropody, Psychology, Dietician, Homeopath (consultation only),Occupational therapy, Speech Therapy, Physiotherapy (out-of-hospital),Podiatry, Chiropractor, Social Worker N$10 000 per family N$68.19 Medication Acute Medication (out-of-hospital) N$5 000 per family N$442.59 Acute Medication (in-hospital) Unlimited Chronic Medication N$ 17 500 per family N$250.32 Other services (subject to OAL) Physiotherapy (in-hospital) Private Nursing Emergency services Total 2010 Total 2012 Unlimited (subject to OAL) N$8.20 N$28 000 per family N$6.32 Unlimited (subject to OAL) N$17.21 N$2313.67 N$2535.78 Due to marketing considerations as well as the need to cater for different health profiles etc. the day-today benefits offered differed. Nonetheless, we have provided a comparison to the South African environment and noted the differences that were benefit driven. 114 | P a g e South African Experience Expected Hospital plus day-to-day benefit cost R867.84 N$758.91 General Practitioners/Medical Specialists R466.25 N$384.66 Dentistry R72.98 N$118.09 Optical R76.59 N$67.74 Diagnostics R206.33 N$187.58 Mental Health R14.53 N$3.85 Allied Health Services R15.99 N$68.20 Medication R222.20 N$692.91 Physiotherapy (in-hospital) R20.44 N$8.20 Private Nursing R10.92 N$6.32 Emergency services R16.39 N$17.21 Total 2010 R 1990.47 N$ 2313.68 Total 2012 R 2181.56 N$ 2535.78 Benefit General Hospitalisation Maternity Oncology Internal Prosthesis Specified Illness Condition From the above table, it appears that for the level of overall benefit offered on the Hospital + day-to-day benefit package, the associated cost per family per month is consistent with industry experience. However, what is evident is the impact of availability of benefit on claim costs for categories such as dentistry, diagnostics and allied health services. This is a function of a number of factors including: Supplier induced demand particularly for radiology and pathology i.e. service providers perform unnecessary tests and scans due to the availability of benefit. As such we have recommended limits that aim to reduce this behavior. Different “medical culture” i.e. we have seen significant utilisation of allied health services in Namibia compared to the South Africa and such behavior has been incorporated in the estimation of the expected cost of the NMBF under the Hospital + day-to-day benefit package 115 | P a g e Benefit package and membership base combinations: Risk Matrices This section combines the analysis performed for the potential membership bases and the benefit package options into risk matrices, showing the significant risks faced for each benefit–membership combination. Included in the risk matrices are the expected costs for each combination, based on the actuarial costing performed in the previous section. The key below provides an indication of the level of risk for each colour-coded element of the risk matrix: High risk Medium risk Low risk The risks will have varying levels of significance on the overall effect of the combination chosen. For this reason the risks have been grouped into “Design” risks and ‘Implementation” risks. Design risks refer to risks due to the benefit-membership combination not meeting fundamental insurance principles. The Implementation risks stem from risks in actually enforcing the chosen combination and the potential hurdles to pass prior to NMBF implementation. An overall risk rating has been given to the Design and Implementation risk headings in order to provide a weighted effect of the risks on the overall result. Costings Methodology The Hospital benefit package costs presented in section 16.4.2 and the Hospital + Day-to-Day benefit package costs presented in section 16.4.3 serve as the base costs from which the expected per family per month(pfpm) costs for the different membership groups in section 16.4.5 are calculated. These costs are determined as follows: Base cost is as described in section 16.4.2 and 16.4.3 respectively. The proportion of principal members in each age band for each target membership group is calculated. Through the use of Generalized Linear Modeling, a statistically derived factor which is based on the population underlying the relevant base cost (described above) is calculated. Using this information, an appropriately weighted adjustment is determined and applied to the base cost to obtain the expected pfpm cost for the applicable membership group. The expected cost allows for approximate health care cost inflation to reflect the value as at 2012. The methodology used was deemed appropriate due to the following: The statistical exercise employed to obtain the cost adjustment factors is a generally accepted method for determining average claims costs used in the medical scheme industry. However, the specific application thereof applied for the purposes of this report results in the implicit assumption that the family sizes of the underlying base cost populations are representative of all other populations costed as per section 16.4.5. 116 | P a g e However, the analyses shown below provides comfort in that sufficiently similar average family sizes of the population underlying the base cost and the membership groups to which the expected costs apply can be seen. Hospital benefit package 2.33 Average Family Sizes Hospital + day-to-day PSEMAS benefit package 2.45 2.13 Medical Scheme Population 1.88 The average family size of the Uncovered and Government Uncovered principal members is assumed to be the same as that of the lives underlying the Hospital and Hospital + Day-to-Day packages. Hence, a vast deviation from the estimated cost is not expected due to significantly differing family sizes. In the absence of data of the desired detail the method is deemed to be sufficiently rigorous. 117 | P a g e Public hospital benefit package* Uncovered Uncovered + PSEMAS Uncovered + PSEMAS + Medical Schemes Uncovered + Medical schemes PSEMAS PSEMAS + uncovered government Design risk Limited risk pool Pricing risk Affordability risk (for members) Buy-down risk (between options) Buy-down risk (between sectors) Insufficient risk cross-subsidisation Insufficient income cross-subsidisation Financing risk Implementation risk Legal risk Political risk Provider supply capability Sustainability Extent of reform required * Costs cannot be determined for this benefit package due to the data limitation of not being able to extract public hospital costs from the PSEMAS data. 119 | P a g e Adjusted PSEMAS benefit package Uncovered Uncovered + PSEMAS Uncovered + PSEMAS + Medical Schemes Uncovered + Medical schemes PSEMAS PSEMAS + uncovered government Design risk Limited risk pool Pricing risk Affordability risk (for members) Buy-down risk (between options) Buy-down risk (between sectors) Insufficient risk cross-subsidisation Insufficient income cross-subsidisation Financing risk Implementation risk Legal risk Political risk Provider supply capability Sustainability Extent of reform required Estimated costs pfpm (N$) 725.61 841.85 874.43 815.02 998.46 972.89 Total costs per annum (N$) 1 009 503 250 2 038 841 237 2 787 336 170 1 757 992 568 1 029 023 245 1 340 876 911 These costs are based on PSEMAS claims experience and hence indicate the costs expected if the PSEMAS benefit package were to be extended to the above populations. PSEMAS benefits are provided at either ninety-five percent of the 2008 NAMAF tariff (less ten percent 3 payable) or ninety-five percent of the cost . The benefits to which these rules apply are stated in the PSEMAS benefit schedule. 3 Information provided by PSEMAS 120 | P a g e Private Hospital benefit package Uncovered Uncovered + PSEMAS Uncovered + PSEMAS + Medical Schemes Uncovered + Medical schemes PSEMAS PSEMAS + uncovered government Design risk Limited risk pool Pricing risk Affordability risk (for members) Buy-down risk (between options) Buy-down risk (between sectors) Insufficient risk cross-subsidisation Insufficient income cross-subsidisation Financing risk Implementation risk Legal risk Political risk Provider supply capability Sustainability Extent of reform required Estimated costs pfpm (N$) 898.74 936.35 954.73 939.25 987.13 979.23 Total costs per annum (N$) 1 250 369 966 2 267 706 827 3 043 300 735 2 025 955 828 1 017 346 429 1 349 614 959 121 | P a g e Private Hospital plus Day-to-Day benefit package Uncovered Uncovered + PSEMAS Uncovered + PSEMAS + Medical Schemes Uncovered + Medical schemes Estimated costs pfpm (N$) 1850.87 2146.90 2222.12 2067.11 2546.53 2506.05 Total costs per annum (N$) 2 575 018 648 5 199 487 143 7 083 237 596 4 458 742 137 2 624 480 264 3 453 940 921 PSEMAS + uncovered government PSEMAS Design risk Limited risk pool Pricing risk Affordability risk (for members) Buy-down risk (between options) Buy-down risk (between sectors) Insufficient risk cross-subsidisation Insufficient income cross-subsidisation Financing risk Implementation risk Legal risk Political risk Provider supply capability Sustainability Extent of reform required 122 | P a g e Limitations and considerations: Population covered The costings are based on the claims experience of a subset of the current medical scheme population and PSEMAS. These costs therefore take into account the health seeking behavior of these lives. The healthcare costs relating to the uncovered employed population who would be covered by the NMBF are not accounted for explicitly in these costs as there is an absence of data for this group. This limitation is fairly commonplace in countries where detailed public healthcare sector data is not available. Therefore it is necessary to conduct further research to understand the healthcare claiming of these lives. The cost of claims may be higher for this group since on entry to an insured environment, their health seeking behavior may increase as they seek to use the benefits available to them, potentially at a lower cost than previously available to them. Alternatively, their costs could be lower as they may not be aware of the insurance benefits or how to access them. The uncovered lives may also be younger thus requiring lower healthcare consumption. Benefits The benefits costed in this report are a hospital option and a hospital plus day-to-day option. The NMBF is expected to comprise one set of healthcare benefits only. The use of multiple benefit options is commonplace within medical schemes in which members can select their benefit option, often on the basis of affordability and health requirements. This leads to anti-selection whereby the sicker lives buy the more expensive options which may lead to a worsening of the risk profile on these lives as the costs of claims increases and the younger and/or healthier lives buy down. For a social fund such as the NMBF the use of benefit options bears no relevance as the aim is to provide a standard package of care to the covered population. Co-payments and balance billing In order to fulfill the requirement of maximizing pre-funding of healthcare costs, the use of co-payments needs to be minimized. Therefore, the design of the NMBF does not explicitly make use of co-payments. However, to the extent that benefit limits used are lower than the cost of claims, beneficiaries will be required to fund the balance out of pocket. The NMBF costings have taken into account the claiming patterns of the medical scheme lives in Namibia. The extent to which copayments are used within these benefit options to contain costs are reflected in the data. Balance billing occurs when benefits are set in relation to a tariff which is lower than the scheme agreed rate and service providers bill members the difference between the tariff and the service provider rate. This results in additional out-of-pocket costs for members. This practice undermines direct reimbursement agreements and impacts negatively on members. This should be taken into account in the management of the Fund. Role of medical schemes Medical schemes currently provide a wide range of cover to beneficiaries, from basic hospital packages to comprehensive cover including hospitalization and day-to-day out-of-hospital benefits. There is 123 | P a g e significant variation in the latter, with some benefit options offering very comprehensive cover. With the introduction of the NMBF covering the employed population, excluding those currently covered, the role of medical schemes is expected to remain similar. However, anti-selective movements off medical schemes to the NMBF must be managed, for the benefit of both risk pools. Deloitte has not explored the likelihood and consequences in detail of lives currently on private medical schemes with similar benefit packages to that of the suggested NMBF Hospital benefit package resigning and joining the NMBF. Factors to consider would include: The negative impact on private medical schemes as their risk pools diminish Resistance from the private sector as they struggle to compete on a cost basis against subsidized NMBF contributions If the benefit package is based in the public sector then there may be capacity concerns if a portion of the private sector suddenly becomes dependent on public sector facilities The potential strain on the administrative capability of the NMBF’s administrator Complimed cover The Complimed product underwritten by Prosperity Life provides top-up hospital cover through two products: Complimed Private Hopsital Gap Plan (For members of PSEMAS Medical Aid Fund): If the service is available in the public sector but the scheme member wishes to have the service provided at a private hospital then PSEMAS will review the case and decide what portion of the cost will be covered. Complimed will cover the rest subject to benefit limits. Complimed Plus Private Hospital Gap Plan The gap in the cost of the procedure and the tariff amount paid by the member’s medical aid fund will be covered by Complimed Plus subject to benefit limits. If the NMBF is structured to provide public hospital benefits, then there is a significant advantage available in Complimed gap cover being available to members who would prefer to make use of private hospitals. The existence of this gap cover may limit the provision of overly comprehensive benefits to NMBF members but in the same breath provides incentive to design a package with limited benefits. The number of people currently receiving Complimed cover (2010 data): Scheme Number of members Private schemes 14 601 PSEMAS 45 Total 14 646 It is clear from the data that the utilization of the Complimed product by PSEMAS members is very low. 124 | P a g e Subsidy arrangement Appendix B contains an analysis of what the estimated net contribution would be if the budgeted PSEMAS subsidy, received from the Ministry of Finance, were made available to the NMBF. Given that the PSEMAS conributions include the non healthcare component while the estimated NMBF amounts only refer to healthcare contributions, this leads to an overstatement of the subsidy by the amount of the non healthcare expenses. Total annual non-healthcare costs in the Namibian medical fund industry The total average non-healthcare expenditure cost per principal member in the Namibian medical funds industry was N$ 258.8 per member per month in 2010 (this figure was calculated using the figures provided in the NAMFISA 2011 annual report). The graph below illustrates the increasing trend of non-healthcare expenditures in the Namibian medical funds industry since 2006: Historical trend of Namibian medical funds' non-healthcare expenditure Cost per member per month (N$) 270 250 230 210 190 170 150 2006 2007 2008 2009 2010 * The above figures were sourced from the 2011 NAMFISA annual report This report cannot at this stage estimate non-healthcare costs for the NMBF until the structure is decided upon. However it is important to note that non-healthcare expenditures vary by scheme depending on various factors such as: Economies of scale Efficiency of administration systems Extent of managed care activities adding to costs 125 | P a g e Quality of administration Number of scheme options Complexity of benefit design rules A comparison of possible NMBF contribution costs with current medical fund contributions Due to a lack of information regarding the income distribution of the possible NMBF membership bases it is not possible to directly compare NMBF contributions with current medical fund contributions. This is mainly due to the fact that Namibian medical fund contributions differ by income band. In other words higher income earners pay higher medical fund contributions, all else equal. This lack of comparability is compounded by the wide variation in benefit package compared to what the envisioned NMBF benefit packages will offer. This is also particularly due to the fact that Namibian medical schemes have benefit packages served by the private sector, while PSEMAS enables access to public hospitalisation. Furthermore, schemes experience different non-healthcare costs and also include allowances for reserves and solvency all of which are not included in the NMBF estimated healthcare cost. For example, medical schemes in South Africa are legislated to set aside 25% of total contributions for solvency purposes which would be required to be funded from the contributions in addition to the non healthcare expenses. 126 | P a g e 16. Conclusions and Recommendations 16.1 The enabling legal framework for the NMBF The Social Security Act 34 of 1994 provides for the establishment, constitution, powers, duties and functions of the Social Security Commission. The Act paves the way for the establishment of a National Medical Benefit Fund (NMBF) which is to provide for the payment of medical benefits to employees. Section 20 (1) of the existing Social Security Act firmly defines the envisaged target population for the NMBF as follows: • • The NMBF requires registration of every employee of every employer “Except if he or she is a member of any other medical aid fund or scheme approved by the Minister on recommendation of the Commission” However PSEMAS is exempt from the Medical Schemes Act and so may be considered not to be excluded from the NMBF membership base. This distinction is vital and has far reaching consequences for the eventual form and feasibility of the NMBF. The research conducted takes into account both options for the purposes of illustrating the impact and constraints of including PSEMAS in the NMBF. 16.2 Health insurance models Of the four main health care models (NHI model, SHI model, Beveridge model, Out-of-pocket) it is the SHI model which is aligned with what the NMBF is meant to achieve. The NMBF is intended to ensure that all employed persons are members of a medical fund. Based on the literature review of international experience the objectives of the NMBF are consistent with the Bismarck Social Health Insurance (SHI) model where all employed persons form part of a prepaid health arrangement. It is therefore distinct from more universal health systems such as National Health Insurance which is extended to the unemployed population, and in which all have access to healthcare facilities and services irrespective of ability to pay. The Social Security Act paves the way for the NMBF, which essentially aims to insure the currently uninsured in the formal sector. Once the NMBF is implemented, it is envisaged that, a mix of private medical funds and a single State fund (the NMBF), will cover all members employed in the formal sector and their dependants (thereby achieving SHI). 127 | P a g e 16.3 International experience with SHI A detailed literature review of international experience was performed, illustrating the path to achieving universal coverage, as well as important lessons that have been learnt from such experience. SHI was found to be one of the main funding models used for healthcare financing. Many SHI initiatives have taken place in Africa, Asia, and Latin America. A total of twenty seven countries have introduced the overriding principle of universal coverage via SHI (Hsiao & Shaw, 2006). The following factors were found to contribute positively to an enabling environment for SHI (Hsiao & Shaw, 2006): Large formal sector employment High wages and salaries Low poverty rate Small family and/or household size Efficiently functioning provider networks Strong human resource capabilities Strong administrative support Government capacity to regulate The literature review identified the following major challenges to implementation of SHI, which need to be accounted for in the implementation of the NMBF in Namibia: Enforcing the collection of contributions Contributing members may not afford contributions in respect of dependents Actuarial costing of the benefits package requires technical skills and data, and is essential to determine the financial sustainability and survival of SHI Enrolment of those in the informal sector and the self-employed, since mandatory enrolment is not easily enforceable Defining, certifying, and subsidising the poor Supply will have to be built up progressively if clients in semi-urban and rural areas are to have access to adequate health care Provider payment mechanisms that aim to shift the financial risk of provision to the provider, will have to be continuously monitored and evaluated Administrative efficiency improvements e.g. associated with the consolidation of existing social insurance and other risk-pooling schemes Leakage of SHI funds because of corruption will be a perpetual threat. 16.4 Collection methods for the NMBF The Namibian tax system is perceived to be equitable and transparent, and after the introduction of the value-added tax in November 2000, tax collection has significantly improved. Countries who have implemented Social/National Health insurance typically have a considerably higher total tax rate. However if Namibia is to fund the NMBF through taxes it will need to consider the increase to the tax rate to accommodate this. This will have many other implications that will need to be considered such as the 128 | P a g e effect on GDP and economic growth. An alternative option is for the government to redistribute the current budget in which tax is currently being utilized. A further consideration for the NMBF is how contributions will be collected via individuals and/or employers. If government fails to collect contributions successfully, they will not be able to cover the claim costs and expenses needed to support the fund. It is recommended that the NMBF, should they chose to use contributions collected from employers/individuals in order to fund the scheme, use a similar method as the one used in South Africa, whereby all employed individuals must have medical cover, and contributions are collected via employers or direct debit orders. 16.5 Legislative considerations: NMBF Target population From a membership base perspective, it is important to consider whether the proposed membership base will achieve the ideal that all employed, uncovered lives are covered under the NMBF, as laid out in the Social Security Act. The target population is defined as all employed persons “Except if he or she is a member of any other medical aid fund or scheme approved by the Minister on recommendation of the Commission”. (SSA, Section 20 (1)) As PSEMAS is exempt from the Medical Schemes Act, it is important to distinguish between whether PSEMAS will be classified as a medical fund or not for the purposes of the NMBF. This definition has far reaching implications for the NMBF in terms of its design and implementation risks. Scenario: PSEMAS is classified as a medical fund From a costing perspective, insuring the currently uncovered population (including government uncovered) only under the NMBF would, it seems, incur the lowest average member cost to the SSC. However, the cost as represented does not take sustainability into account; it merely gives an indication of the expected cost arising from past experience. The small risk pool, poor cross-subsidization and buydown risks identified in the risk matrices illustrate that this group is the worst option in terms of sustainability and feasibility. Scenario: PSEMAS is not classified as a medical fund If one considers the scenario that PSEMAS is not classified as a medical fund, then the membership base will extend to the uncovered population as well as PSEMAS. If the lives currently on PSEMAS are included in the NMBF population this would substantially increase the size of the risk pool, thereby reducing the variability in claims and cost experience. In addition this would present the opportunity to better manage the benefits and costs of PSEMAS which, in its current form, is financially unsustainable. However there remains implementation risk due to employee and union resistance should the current PSEMAS subsidization rate and benefit package be scaled back in order to become more financially sustainable. There is also the possibility that medical scheme members “buy-down” by leaving their medical schemes and joining the NMBF. This factor will depend largely on the financing and contributions structure of the NMBF, in particular the extent to which subsidized contributions result in the NMBF presenting a benefit package and contribution rates which medical schemes are unable to compete with. 129 | P a g e The risk matrices illustrate that, in the absence of implementation resistance, this option is a superior choice to the “Uncovered” option. It is recommended that a phased approach be used to implement the NMBF within this scenario. The NMBF can initially begin as a reform of PSEMAS, after which coverage can be extended to the uncovered government employees and finally to all uncovered taxpayers. This allows the NMBF to fine tune its pricing and administration systems prior to being expanded to the full membership base. Scenario: Legislation is revised and medical scheme members are no longer excluded Purely from a design perspective, including the entire taxpaying population represents the most superior option. The literature review repeatedly illustrated the importance of compulsion to ensure social solidarity and a well-functioning social security system. By compelling all taxpayers to be NMBF members, this option avoids many risks faced by the other membership group options. For example, there will be no buy-down risk, the risk pool will be large, there will also be scope to benefit from extensive income and risk cross-subsidization which in turn will serve to reduce the financing requirements and enhance contribution affordability. However there will be a need for substantial reform of both the medical schemes industry as well as of PSEMAS for this to occur. This will also require a revision of the current social security legislation, which combined may make this option practically unviable. 16.6 Benefit package recommendations Affordability From current medical scheme members’ point of view, the health care facilities and perceived quality of care in the private hospitals makes a benefit package with private hospital cover a necessity. However the costs of extending private hospital type benefits to the uncovered population, who we expect on average to be poorer, may be too prohibitive from a contributions and financing point of view, especially if the package also contain day-to-day benefits. The cost of the “Hospital + Day-to-Day” benefit package is almost certainly prohibitively high, making the “Hospital” benefit package the natural choice with regards to cost containment. In providing this benefit package a reasonably priced minimum level of cover will be provided to those who previously did not enjoy these benefits. However this package may not be deemed adequate as it does not include day-to-day benefits. The “Adjusted PSEMAS” benefit package makes allowance for these benefits, yet is still cheaper than both the “Hospital + Day-to-Day” benefit package as well as the “Hospital” benefit package because it is based in the cheaper public sector. Based on costs alone, the “Adjusted PSEMAS” benefit package is the superior option and is the most applicable to the uncovered population which we assume to be on average poorer than the covered population. Public versus Private sector 130 | P a g e The choice of benefit package has implications beyond the initial affordability and sustainability concerns. The foremost implication is the funneling of funds into either the public or the private sector. A public hospital benefit package allows the NMBF to channel funds into the public sector where they are most needed. More funds and patients being channeled into the public sector will attract more healthcare practitioners back from the private sector and thereby go some way towards correcting the current imbalances in the Namibian health care environment. An uplifted public sector will be better equipped to serve the unemployed population which uses these public facilities out of necessity. Therefore the choice of sector will determine the channeling of funds to health care facilities and this choice must be considered at a strategic level in terms of how the NMBF will improve both health infrastructure and access to healthcare for the target population while achieving goals on the NMBF. 16.7 A phased implementation approach A key lesson learnt from the literature review was to limit the level of fragmentation of the risk pool when implementing an SHI fund. In terms of the risk matrices a direct resultant risk of industry fragmentation is “buy-down” risk where people move to/from the NMBF into PSEMAS or medical funds depending on the membership base and cost/benefit ratio (driven largely by the rate of contribution subsidization). However implementing the NMBF at its full membership base level from the outset faces many practical problems and leaves little room for error in terms of administration systems, pricing correctly, collecting contributions and taxes and ensuring optimal service delivery of benefits. It is therefore recommended that a phased approached be adopted by gradually adding various population sub-groups until the target population is reached and the legislation’s objectives are met. The costings performed above contains information for various sub-groups which alone do not represent a membership base consistent with the SSA (for example “PSEMAS + government uncovered” and “PSEMAS”) however they are included for purposes of comparison and also to be used when considering a phased approach to implementation. For example an initial step towards the NMBF could be to ensure all government employees are PSEMAS members and then move on and add other sub-groups such as non-government uncovered lives. In summary, the SSC is faced with the delicate challenge of achieving a balance between choosing a benefit package which meets the population’s health care needs yet is affordable from a financing and contributions point of view. This balance extends to applying this package to a membership group which is consistent with the social security legislation yet also sound from a design and implementation point of view. The choice of funding method as well as the extent of contribution subsidization will have a direct impact on the success of the NMBF as well as the extent to which the risks identified in the risk matrices become a reality. 131 | P a g e Thank you for giving us the opportunity to help you in this important analysis. Please do not hesitate to contact us with further enquiries. ________________________ Ashleigh Theophanides Bcom (Hons) FIA FASSA In my capacity as an actuary and Director of Deloitte Consulting Actuarial & Analytical Solutions _______________________ Lara Wayburne MSc FFA FASSA In my capacity as an actuary of Deloitte Consulting Actuarial & Analytical Solutions _______________________ Fatima Badat In my capacity as a Manager of Deloitte Consulting Actuarial & Analytical Solutions June 2012 Woodmead 132 | P a g e Bibliography Colombo, F., & Tapay, N. (2004). 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Windhoek, Namibia and Calverton, Maryland: MoHSS and Macro International Inc. Ndjavera, S. (2011). NAMAF Conference. Sustainability of the Public Service Employees Medical Aid Scheme (PSEMAS) in context of Contribution and Compliance. Normand, C., & Weber, A. (2009). Social Health Insurance: A Guidebook For Planning. NPC. (2005). Namibia Household Icome & Expenditure Survey. Windhoek: Central bureau of statistics. WHO. (2004). Clarifying efficiency-equity tradeoffs through explicit criteria, with a focus on developing countries , Discussion Paper, Number 5. WHO. (2004). Reaching universal coverage via social health insurance: key design features in the transition period, Discussion Paper, Number 2. WHO. (2010). Namibia Health Resource Tracking: 2007/08 & 2008/09. Windhoek: Abt Associates Inc. 133 | P a g e Annexure A: Population groups Uncovered population Age Band Male Female E: 15-19 4484 2026 F: 20-24 13817 9915 G: 25-29 15513 11204 H: 30-34 12287 8410 I: 35-39 9533 10002 J: 40-44 4851 6531 K: 45-49 1779 1543 L: 50-54 492 1707 M: 55-59 957 888 N: 60-64 0 0 O: 65+ 0 0 Covered population Age Band Male Female E: 15-19 440 374 F: 20-24 5777 5193 G: 25-29 11077 9721 H: 30-34 13108 9795 I: 35-39 11905 9343 J: 40-44 10901 9122 K: 45-49 11102 8884 L: 50-54 8689 5817 M: 55-59 5431 3309 N: 60-64 2675 1802 O: 65+ 2903 2329 134 | P a g e PSEMAS Age Band Male Female E: 15-19 228 147 F: 20-24 3058 2535 G: 25-29 5403 5093 H: 30-34 7027 5380 I: 35-39 6139 5599 J: 40-44 6070 6390 K: 45-49 6994 6750 L: 50-54 4998 4227 M: 55-59 2668 2218 N: 60-64 1248 1205 O: 65+ 1256 1250 Covered + Uncovered Age Band Male Female E: 15-19 4924 2400 F: 20-24 19593 15107 G: 25-29 26590 20926 H: 30-34 25394 18205 I: 35-39 21438 19346 J: 40-44 15752 15653 K: 45-49 12881 10427 L: 50-54 9181 7524 M: 55-59 6388 4197 N: 60-64 2675 1802 O: 65+ 2903 2329 135 | P a g e Covered + Uncovered - PSEMAS Age Band Male Female E: 15-19 4696 2253 F: 20-24 16535 12573 G: 25-29 21187 15833 H: 30-34 18368 12825 I: 35-39 15298 13746 J: 40-44 9681 9263 K: 45-49 5887 3677 L: 50-54 4183 3297 M: 55-59 3720 1979 N: 60-64 1426 597 O: 65+ 1647 1079 Uncovered + PSEMAS Age Band Male Female E: 15-19 4712 2174 F: 20-24 16875 12450 G: 25-29 20917 16297 H: 30-34 19313 13790 I: 35-39 15672 15602 J: 40-44 10921 12921 K: 45-49 8772 8292 L: 50-54 5489 5933 M: 55-59 3625 3106 N: 60-64 1248 1205 O: 65+ 1256 1250 136 | P a g e Covered - PSEMAS Age Band Male Female E: 15-19 212 227 F: 20-24 2718 2658 G: 25-29 5674 4629 H: 30-34 6081 4415 I: 35-39 5765 3744 J: 40-44 4831 2732 K: 45-49 4109 2134 L: 50-54 3691 1591 M: 55-59 2763 1091 N: 60-64 1426 597 O: 65+ 1647 1079 137 | P a g e Annexure B: PSEMAS subsidy The Ministry of Finance currently subsidizes the contributions of PSEMAS members. This section provides an analysis of what the cost of the NMBF is estimated be under each benefit package and membership base under the assumption that the same subsidy is paid to the NMBF. The table overleaf summarizes the effect that such a subsidy will have on the NMBF contribution. Please note that the NMBF amounts do not include non-healthcare expenses while the MOF contributions to PSEMAS do include these costs in its subsidy. The negative subsidized NMBF costs indicate instances where the PSEMAS subsidy, if applied to the NMBF, will more than cover the cost of expected claims (excluding non-healthcare expenditure). The total PSEMAS subsidy (2012/2013) figure used (N$1 302 036 000) was provided by the Ministry of Finance in their PSEMAS budget. 138 | P a g e Uncovered + PSEMAS + Medical Schemes Uncovered + Medical schemes PSEMAS PSEMAS + uncovered government Adjusted PSEMAS Uncovered Uncovered + PSEMAS Estimated costs pfpm (N$) 725.61 841.85 874.43 815.02 998.46 972.89 Total costs per annum (N$) 1 009 503 250 2 038 841 237 2 787 336 170 1 757 992 568 1 029 023 245 1 340 876 911 Total MoF-PSEMAS subsidy (2012/2013) 1 302 036 000 1 302 036 000 1 302 036 000 1 302 036 000 1 302 036 000 1 302 036 000 Subsidised NMBF cost pfpm (N$) -210.27 304.23 465.96 211.39 -264.90 28.18 Private Hospital Uncovered Uncovered + PSEMAS Uncovered + PSEMAS + Medical Schemes Uncovered + Medical schemes PSEMAS PSEMAS + uncovered government Estimated costs pfpm (N$) 898.74 936.35 954.73 939.25 987.13 979.23 Total costs per annum (N$) 1 250 369 966 2 267 706 827 3 043 300 735 2 025 955 828 1 017 346 429 1 349 614 959 Total MoF-PSEMAS subsidy (2012/2013) 1 302 036 000 1 302 036 000 1 302 036 000 1 302 036 000 1 302 036 000 1 302 036 000 Subsidised NMBF cost pfpm (N$) -37.14 398.73 546.26 335.62 -276.23 34.52 Private Hospital plus day-to-day Uncovered Uncovered + PSEMAS Uncovered + PSEMAS + Medical Schemes Uncovered + Medical schemes PSEMAS PSEMAS + uncovered government Estimated costs pfpm (N$) 1850.87 2146.9 2222.12 2067.11 2546.53 2506.05 Total costs per annum (N$) 2 575 018 648 5 199 487 143 7 083 237 596 4 458 742 137 2 624 480 264 3 453 940 921 Total MoF-PSEMAS subsidy (2012/2013) 1 302 036 000 1 302 036 000 1 302 036 000 1 302 036 000 1 302 036 000 1 302 036 000 Subsidised NMBF cost pfpm (N$) 914.99 1 609.28 1 813.65 1 463.48 1 283.17 1 561.34 123 | P a g e 123 | P a g e
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