ATTENTION: DR A. MOTSOALEDI NATIONAL DEPARTMENT OF HEALTH, SOUTH AFRICA email@example.com
RE: White Paper on National Health Insurance
Good afternoon Dr Motsoaledi
This letter serves as the official comment from the South African Private Ambulance and Emergency Services Association (SAPAESA) on the White Paper on National Health Insurance (NHI), as published in the Government Gazette on 11 December 2015.
While it needs to be noted that SAPAESA is not opposed to the objectives of the National Health Insurance system, it does need to be stated that SAPAESA is opposed to the contents of Paragraph 245, contained within Chapter 6.9 on Page 44 of the White Paper on NHI.
The two points specifically that are of concern to SAPAESA are as follows:
- “A key feature of the new EMS is that all medical emergency vehicles will be of a standard colour regardless of whether they are publically or privately operated…”
- “…there will be a single national emergency number to serve both public and private operators…”
SAPAESA believes both of the statements mentioned above are in direct contradiction to the National Patients Rights’ Charter, and as such we oppose them in the strongest terms. More specifically SAPAESA believes that these statements conflict with Chapter 2.5 of the National Patients Rights’ Charter: “Choice of Health Services”. Chapter 2.5 states the following: “Everyone has the right to choose a particular health care provider for services or a particular health facility for treatment, provided that such choice shall not be contrary to the ethical standards applicable to such health care provider or facility.”
SAPAESA believes that by displaying one standard colour of signage on an emergency vehicle, that the Department of Health will deprive the patient of the ability to distinguish between providers and as such, depriving the patient of his or her right to choose a particular health care provider for services. Private ambulance services must be entitled to display their own choice of colours, logos and designs on their respective emergency vehicles.
SAPAESA further believes that by only allowing for a single, national emergency number that patients will be further deprived of their right to choose a particular health care provider.
Private ambulance services cater to specific client bases, aside from others, and it is of utmost importance that a patient that falls within one of these client bases is able to utilize a unique emergency number to access his or her contracted emergency care provider when required. This requirement is in line with Medical Schemes Act, 1998 (Act No 131 of 1998) Regulations. Chapter 3: Contributions and Benefits, of the Medical Schemes Act Regulations makes allowance for a medical scheme to appoint a health care provider or group of healthcare providers, selected by the scheme, as the preferred provider, or providers, to its members. The single national emergency number will be it virtually impossible for a patient to contact the designated service provider of the scheme directly in the event of an emergency and as a result the stipulation for a single emergency number is in contradiction with the Medical Schemes Act, 1998 as described above.
SAPAESA is not opposed to representatives from private ambulance services working together with representatives from the provincial ambulance services in a single call center for the purpose of efficiency and improved communication, however this would only be under the express condition that the various private ambulance services would still be allowed to continue operate their own individual emergency telephone numbers, continue to operate independent emergency call centers and would be allowed to dispatch and co-ordinate their own emergency vehicles without interference or undue influence from other private or provincial ambulance service representatives, the National or Provincial Departments of Health, or other representatives of Government.
I would like to formally confirm that SAPAESA is very concerned that there was no engagement with ourselves with regards to the content of Chapter 6.9 prior to the White Paper on National Health Insurance being published by the National Department of Health. SAPAESA would urge a more inclusive engagement process between SAPAESA and the National Department of Health in future with regards to any decisions regarding the structure of how private ambulance services will be included in any National Health Insurance policy documents.
I trust that this will serve to clarify our position with regards to Paragraph 245 of the White Paper on National Health Insurance. I wish to confirm that SAPAESA reserves our right to comment further on our objections noted herein above as and when the need may arise at any stage in the future.
I remain available to engage with the National Department of Health on the matter and look forward to a constructive discussion regarding a solution that is agreeable to all parties involved.
Chief Executive Officer