Submission to the Competition Commission on the Draft Terms of Reference for Market Inquiry: Private Healthcare Sector
1.1. The Helen Suzman Foundation (HSF) hereby submits its comments to the Competition Commission of South Africa (CC) on the Draft Terms of Reference for Market Inquiry: Private Healthcare Sector.
1.2. The HSF is an independent civil society organisation with a mandate to promote liberal constitutional democracy, and respect for human rights and the rule of law. The HSF begins with the premise that access to healthcare is a fundamental human right. The HSF has been involved in matters relating to healthcare since 2009. Its interventions include a detailed submission on the National Health Insurance Green Paper; interventions on the issue of demarcation between medical schemes and health insurance products; and consultations and submissions on the Health Professions Council of South Africa‘s (HPCSA) Proposed Guideline Tariffs for Medical Practitioners and Dentists.
1.3. Given the combination of lobby groups, vested interests and areas of regulatory or policy stagnation, there is a clear need for organisations and members of civil society, such as the HSF, to engage in this matter in order to assist in promoting and protecting the public interest.
1.4. Although the vast majority of South Africa’s population rely on the public health system to deliver their healthcare, at least 8.5 million peopleiv who are beneficiaries of medical schemes, rely on the private healthcare system for their healthcare. This figure does not include the many who use the private healthcare system and pay for it out of pocket. It is thus very important that the private healthcare system functions efficiently and effectively and plays its part in the provision of the right of access to healthcare.
1.5. It is in this light that the HSF welcomes the Private Healthcare Market Inquiry and the opportunity it presents to gain a better understanding of the market and the challenges and appropriate remedies which may emerge.
1.6. The HSF’s assumption is that the Inquiry will be conducted systematically, transparently and fairly and will involve all relevant stakeholders.
1.7. In this submission, the HSF comments strategically only on specific areas of the Terms of Reference (ToR). The submission follows the order of the ToR by using the same headings for ease of use by the CC.