Staff Writer 
THE Zimbabwe Medical Association (ZiMA) has submitted what it calls “The case for prohibiting vertical integration of Medical Aid Societies” to the Parliamentary Portfolio Committee on Health and Child Care, urging the passage of a proposed Section 14A to SI 330 of 2000, which would prohibit medical aid societies from owning healthcare facilities.
Dressed in constitutional language and adorned with references to the World Health Organisation and the South African Medical Schemes Act, the document reads like a dispassionate policy brief from a neutral public interest body. Except that it is nothing of the sort.
ZiMA’s paper is a lobbying document from an organisation whose members — independent doctors — stand to gain directly and materially from the very regulation it advocates. That does not make its arguments automatically wrong. But the paper’s refusal to acknowledge this interest, while presenting itself as a guardian of patients, should concern every parliamentarian who reads it.
Who benefits?
Let us begin where ZiMA’s paper does not: with the question of cui bono — who benefits? If medical aid societies are forced to divest from their clinics and hospitals, the immediate winners are independent healthcare providers, who would inherit the patient volumes currently served by medical aid-owned facilities. Independent healthcare providers are, overwhelmingly, ZiMA’s own membership.
ZiMA’s paper frames the entire debate as a patient versus profit. But it overlooks recent reports that over 10,000 jobs could be lost, and more than US$200 million in healthcare investment could be wiped out. At an AHFoZ engagement last week, an Institute of People Management of Zimbabwe (IPMZ) representative cited the case of a patient who avoided a US$600-per-night bill (or shortfall) at a private hospital after transfer to a medical aid-owned facility, paying just US$30 after three days. “That kind of cost protection is what is at stake,” she said.
ZiMA’s paper does not engage with this reality. It does not ask: where will these patients go? What will they pay? Who will absorb them? These are not minor omissions. They are the central questions of the debate.
The four harms that never happened
The heart of ZiMA’s argument rests on what it has listed as four “real patient impacts”: a delayed referral, a missing test, a trapped civil servant, and an early discharge. These are presented as self-evident truths — vivid, emotionally charged scenarios that any reader would find alarming.
There is just one problem: not even one of these four is supported by evidence. No case study. No patient complaint record. No clinical audit. No Health Professions Authority finding. No date, no hospital, no outcome.
ZiMA asks us to accept these as “real” impacts on the basis of, at best, clinical intuition and, at worst, adversarial speculation about how medical aid-owned facilities must operate. In a document submitted to Parliament to justify a structural prohibition on an entire category of healthcare investment, the absence of a single documented case is not a minor gap. It is a disqualifying one.
If these harms are as systemic as ZiMA claims, where are the complaints? Where are the medical negligence cases? The silence is telling.
The constitutional stretch
ZiMA’s paper leans heavily on Section 76 of the Constitution, which provides that “every citizen and permanent resident has the right to basic healthcare services” and that “the State must take reasonable legislative and other measures to progressively realise this right.”
From this, ZiMA extracts the remarkable proposition that prohibiting medical aid societies from owning clinics is a constitutional obligation. This is a stretch of constitutional interpretation that would make even the most activist jurist pause.
Section 76 speaks of access — of progressively realising the right to healthcare. It says nothing about the structural architecture of healthcare financing. It does not prescribe the separation of funders and providers any more than it prescribes a particular model of hospital ownership.
More critically, if the amendment results in the closure of facilities that currently provide affordable care to civil servants and low-income members — which AHFoZ and multiple stakeholders have warned it will — then it is the amendment itself that risks violating Section 76 by regressing access. ZiMA’s constitutional argument, in other words, could just as easily be turned against its own position.
The misleading international tour
ZiMA points to South Africa, the United Kingdom, and the World Health Organisation to argue that Zimbabwe would merely be “aligning with standards already governing its neighbouring jurisdictions.”
This is misleading on every count. South Africa’s Medical Schemes Act operates in a healthcare economy roughly twenty times the size of Zimbabwe’s, with a private hospital sector dominated by large, listed companies like Netcare, Mediclinic, and Life Healthcare. The prohibition on scheme-owned facilities might be justifiable within a market where alternative providers are abundant. Zimbabwe’s private healthcare sector is fragile, underfunded, and haemorrhaging professionals. Transplanting a regulatory prohibition from a fundamentally different market without transplanting its preconditions is not policy alignment — it is policy disingenuity. But, wait for it, the Medical Schemes Act of South Africa, actually DOES NOT prohibit vertical integration as is claimed by ZiMA. In the very definition section of the Act, the business of a medical scheme, is defined, in part, to mean the “rendering of a relevant health service, either by the medical scheme itself, or by an supplier or group of suppliers of a relevant health service or by any person, in association with or in terms of an agreement with a medical scheme”. That last part (agreement with a medical scheme) is a whole debate on its own. It speaks to preferred provider networks, an area that addresses long standing tariff disparities. Needless to say, it is another area where ZiMA has constantly failed to collaborate with medical aid societies.
The UK comparison is even less persuasive. The NHS is a publicly funded, universal healthcare system. Zimbabwe does not have a national health insurance scheme in operation. Invoking the NHS’s healthcare provider system in a country where the public healthcare system is in crisis and medical aid coverage is a lifeline for those who can access it is, frankly, irrelevant.
As for the WHO, its health system governance guidance does identify the separation of purchasing and provision as a feature of “well-performing systems” — but as an ideal-type principle in mature health systems, not as a prescription to dismantle existing infrastructure in developing countries with fragile provider networks.
On Clinical independence
ZiMA also argues that “Patient safety requires clinical independence. Clinical independence requires structural separation of financing and provision.” This is a neat slogan, but it collapses several different ideas into one chain of necessity — and each link is contestable. Curiously, if ZiMA are right, then their position is a direct indictment on the NHS and other systems that their argument relies on because, in those systems, the concept of preferred provider networks and relevant contracting is enforced. Clinical independence means clinicians can make decisions based on evidence and patient need without being overruled by financial managers. That can be achieved through clinical governance, professional regulation, audit requirements, and enforceable sanctions. It does not logically require that the payer and provider can never sit under the same corporate umbrella.
If ZiMA believes medical aid-owned facilities systematically override doctors, discharge early, or block referrals, the correct policy response is to present documented cases and demand targeted enforcement: clinical audit trails, complaint statistics, morbidity and mortality reviews, and regulator findings. A blanket structural ban is a remedy without a record.
In a fragile system with limited private capacity, forcing divestiture can shrink the provider network, raise co-payments, and reduce access — which is itself a patient-safety risk. A patient who delays care because they cannot afford it is not “safer” because the clinic’s ownership structure satisfies a textbook principle.
If Parliament’s goal is clinical independence, it should legislate and enforce independence: mandatory clinical governance charters, protections for whistleblowers, independent complaint channels, disclosure and ring-fencing rules, and outcome reporting — not a prohibition that assumes the only way to protect patients is to dismantle bricks-and-mortar capacity.
ZiMA also says: “The same entity that decides how much to pay for care also decides what care is given.”This line sounds alarming because it suggests a single actor controls both the purse and the prescription. But in real clinical systems, “what care is given” is never decided by one entity — it is the product of clinical judgment, rules of cover, patient consent, and, ultimately, what is medically indicated. A funder can decide what it will reimburse, but it cannot unilaterally “decide what care is given” to a patient in a consultation room. Clinicians diagnose, recommend, and document; patients consent; regulators set standards. Funding rules influence choices, but they do not replace clinical decision-making.
Whether the payer and provider are separated or integrated, there will still be benefit limits, formularies, pre-authorisation requirements, and exclusions. ZiMA’s claim quietly treats these as unique to vertical integration, when they are simply how pooled-risk financing works.
The tariff grievance hiding in plain sight — and the inconvenient truth ZiMA omits
Perhaps the most revealing section of ZiMA’s paper is its discussion of the “supply destruction” caused by low tariffs, delayed payments, and administrative burdens imposed by medical aid societies. ZiMA frames this as a one-sided oppression: AHFoZ sets tariffs “unilaterally,” doctors are underpaid, and independent practices collapse as a result.
This framing collapses under even basic scrutiny.
The tariff problem in Zimbabwe’s healthcare sector is not a story of villainous funders and victimised providers. It is a story of a market in which neither side has ever been able to agree on what healthcare should cost — and in which providers themselves have done remarkably little to put their own house in order.
Here is what ZiMA’s paper does not tell Parliament: there is no common tariff among providers. Doctors in Zimbabwe do not charge a standardised rate for consultations, procedures, or specialist services. A GP consultation in Borrowdale may cost one amount; the same consultation in Avondale, another; and in Bulawayo, another still. Specialists set their own fees. Surgeons set their own theatre rates. There is no published schedule that a patient — or a funder — can consult to know what a fair price looks like. This is not a minor detail. It is the structural root of the tariff dispute that ZiMA blames entirely on medical aid societies.
Funders pay what they can — constrained by the premiums they collect and their obligation to make those funds last across their entire membership. Providers charge what they want — individually, without coordination, without a common benchmark, and without transparency to the patients who ultimately bear the cost. When the gap between the two produces a shortfall, ZiMA points the finger exclusively at the funder.
But on what basis should AHFoZ accept a tariff when the providers themselves cannot agree on one? If three orthopaedic surgeons in Harare charge three different rates for the same procedure, which rate is the “correct” one? If GPs in the same suburb charge different consultation fees, how is a medical aid society supposed to determine the fair reimbursement rate — by picking the highest? The average? The lowest?
The absence of a standardised, transparent, and collectively negotiated provider tariff schedule is, first and foremost, a failure of the medical profession itself. ZiMA, as the professional body representing doctors, is arguably the organisation best positioned to lead the development of such a schedule. It has not done so. Instead, it has asked Parliament to dismantle the infrastructure of medical aid societies — which, whatever their faults, at least offer their members predictable pricing.
The irony is exquisite: ZiMA’s paper accuses medical aid societies of creating a “closed ecosystem where member money recirculates internally.” But what is the alternative it implicitly proposes? An open ecosystem in which member money flows to independent providers who charge whatever they wish, with no common tariff, no price transparency, and no accountability for the gap between what they charge and what funds can sustain.
If ZiMA is serious about tariff reform — and it should be — the starting point is not the forced divestiture of medical aid-owned facilities. It is the development of a credible, transparent, and standardised tariff framework within the profession. Until doctors can tell patients and funders what healthcare costs — consistently, collectively, and transparently — they are in no position to accuse funders of paying too little.
The patients ZiMA does not speak for
The most vulnerable patients in Zimbabwe’s medical aid system are civil servants on PSMAS — the largest medical aid society in the country. These are teachers, nurses, police officers, and clerks earning modest salaries. For many, the medical aid-owned facility is the only place where they can access care without crippling out-of-pocket costs. The co-payment gap between a medical aid-owned facility and an independent provider is not a minor inconvenience — it can be the difference between seeking treatment and going without.
ZiMA’s paper characterises this as “trapping” the civil servant. But from the civil servant’s perspective, the medical aid-owned clinic is not a trap — it is a lifeline. Forcing its closure does not liberate the patient. It abandons them to a market where the doctors who lobbied for the closure now set the prices.
What would actually help patients
None of this is to say that vertical integration in Zimbabwe’s medical aid sector is without problems. Every sector has its own challenges. But, in this case, as is in other sectors, the answer is not a blanket prohibition that destroys infrastructure, eliminates jobs, and raises costs for the most vulnerable members. The answer is regulation — transparent, independent, and enforceable regulation. Specifically:
- An independent medical aid regulatory authority with the power to investigate complaints, audit clinical outcomes, and enforce standards — a measure that even AHFoZ has publicly supported.
- Transparent tariff-setting through an independent body, not unilateral determination by either funders or providers.
- Mandatory disclosure of conflicts of interest where medical aid societies own facilities, including ring-fenced financial reporting and independent clinical governance. This is where IPEC, recently confirmed as a regulator of medical aid societies, comes in.
- Patient choice protections that ensure members can access any accredited provider without punitive co-payments.
These reforms address every harm ZiMA alleges — without the collateral damage of forced divestiture.
A profession’s credibility is at stake
ZiMA ought to be a respected institution. Its members are on the front lines of a healthcare system under extraordinary strain.
But a submission that presents self-interested advocacy as constitutional obligation, hypothetical harms as documented evidence, and selective international comparisons as settled consensus does not serve the profession’s credibility. It does not serve patients. And it does not serve the Parliamentary Committee that must weigh these arguments.
Parliamentarians should read ZiMA’s paper — and then ask the questions it does not answer. How many patients could lose affordable access to care? How many jobs could be lost? Where is the evidence that clinical outcomes at medical aid-owned facilities are worse than at independent practices? What regulatory alternatives were considered and rejected, and on what basis?
