The Certificate of Need (CON) meeting with Director General of Health
On the 18 June 2014, representatives of the IPA Foundation, together with other interested parties met with the Director General of Health, at her invitation to discuss the Certificate of Need.
The Director referred to Sections 36 – 40 of the National Health Act (NHA) which was signed into law by president Zuma in April 2014. This is the section of the Act that contains the Certificate of Need (CON).
She pointed out that as CON is now a law of this country, only Cabinet can change it. The Minister of Health’s role is to draft the Regulations to the Act. This role is largely driven by the Director General, (DG) of the Department of Health (DOH).
Before doing so she wanted to have dialogue and frank discussion with all the stakeholders. They will consult with all professional groupings that will be affected by this Act; all in all there are 27 such groupings
DG emphasises the value of the private sector:
She went on to acknowledge that there is recognition in the Act of the value of private healthcare and explained that she did not want to institute a system that is burdensome to doctors and to the department. The CON would therefore be an electronic system; they are considering making it electronic.
The DG made it clear that she has no intention of getting rid of private doctors and that she sees them as absolutely vital to reaching the envisaged outcomes.
As IPAF we believe that the DOH will use the CON to get private participation in addressing the ever increasing Burden of Disease and NHI.
We will actively engage and see where the GP/FP can assist Government in this mammoth task without compromising our autonomy and mandate that we have been given by the practitioners who are members of IPAF.
Burden of Disease and demographics of the Medical Profession and the CON:
The DG was concerned about:
- The Burden of Disease and
- The Distribution of Healthcare Providers in SA.
She wants the Regulations to CON to support improving access to quality healthcare to a larger part of the population via participation of both the public and private sector
The Burden of Disease relates to:
- Lifestyle diseases. These are Non Communicable Diseases (NCD) – Diabetes; Hypertension;
- Infectious diseases like TB; HIV and AIDS;
- Homicide: Accidents and injuries related to assault
- Con applies to Public , Private as well as Pharmacies:
The CON will affect both the private and public facilities which will need to be registered. This should not be confused with Licensing, as doctors are licensed by their professional body - HPCSA
She stated that the CON has already been applied to pharmacists, and it is working well More than 70 000 healthcare establishments have to be registered before end of April 2016
Certain preliminary matters which will be considered by the DOH in drafting Regulations include:
- If you sell your practice, it will only be the change of ownership of CON
- It was proposed that the 24 months deadline to register practices should only commence when the final regulations have been published and could be extended if there are administrative delays; or if there are delays in approval of licenses; all these factors will be taken into consideration by the DG and her office
- It was agreed that we have to submit our inputs to the DG regards how we would like this Act to be regulated; we can contact our legal advisors to help us in this matter. The DG will consider all these submissions in drafting the Regulations to the Act.
- The criteria for allocation of CON need to be made to address the burden of disease and need to be reviewed regularly: Criteria could be drafted more as a guideline instead of the DOH coming with rigid prescription
- Current practitioners/practices will not be moved but rather incentivized to open practices in identified areas where the Burden of Disease is most pressing.
- CON regulations could be written to incentivise doctors who want to start practice to move to outlying areas; rather than denying them the right to practice where they want to.
- It was agreed that we, as Family Practitioners (FP/GPs) have to form a representative forum that will liaise with her and express the concerns of the profession and make contributions that will be considered in drafting the Regulations. This group will meet the DG at least twice a year.