AHFoZ escalates fight against SI 330 Amendments

The proposed reforms are understood to be aimed at addressing concerns over potential conflicts of interest arising from insurer-provider integration.

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A FIERCE battle over the future of Zimbabwe’s healthcare financing system is now unfolding in Parliament after the Association of Health Funders of Zimbabwe (AHFoZ) last week submitted a position paper urging legislators to block proposed SI 330 amendments that would fundamentally reshape the medical aid sector.

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The Portfolio Committee on Health and Child Care remains seized with the matter. AHFoZ has also petitioned Parliament over the same issue, although the petition is yet to be read before the August House.

At the centre of the dispute are proposed amendments to Statutory Instrument 330 of 2000, which would prohibit medical aid societies from owning, managing or operating healthcare facilities and compel them to dispose of existing interests in hospitals, clinics and specialist units within a prescribed period.

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The proposed reforms are understood to be aimed at addressing concerns over potential conflicts of interest arising from insurer-provider integration.

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However, in its submission, AHFoZ argues that the amendments could trigger unintended consequences that ultimately disadvantage patients, weaken healthcare financing mechanisms and reduce the country’s healthcare capacity.

“We respectfully propose a more proportionate, evidence-based regulatory approach that addresses legitimate conflict-of-interest and competition concerns without undermining Universal Health Coverage, affordability and system resilience,” the position paper states.

Representing major medical aid societies including First Mutual Health, CIMAS, PSMAS, VIVAT and Parksmed, the association argues that vertically integrated healthcare models evolved as a practical response to Zimbabwe’s healthcare realities, including tariff disputes, affordability barriers, medicine shortages and capacity constraints.

According to the submission, medical aid societies invested in healthcare facilities to guarantee members more predictable access to treatment, reduce shortfalls and contain costs at a time when private healthcare pricing remained fragmented and often unpredictable.

“The proposed amendment seeks to reverse decades of functional evolution without evidence of harm or failure,” the submission states.

AHFoZ warns that compulsory divestiture could trigger distressed asset sales, weaken the solvency of medical aid societies and reduce service capacity in a healthcare system already under pressure. It argues that members could ultimately bear the burden through higher contributions, reduced benefits and increased out-of-pocket expenses.

The association also raises constitutional concerns, arguing that the proposed amendments could infringe property rights, freedom of association and the constitutional right to access healthcare if they cannot be shown to be reasonable, necessary and proportionate. It further questions whether such sweeping structural reforms should be introduced through delegated legislation rather than through an Act of Parliament.

The submission maintains that there is no evidence that medical aid-owned facilities have monopolised healthcare delivery or harmed consumers. It notes that most healthcare services utilised by members continue to be sourced from independent providers rather than society-owned facilities, challenging assertions that funders dominate the market.

Instead of a blanket prohibition, AHFoZ is proposing targeted reforms, including ring-fenced governance structures, independent audits, transparent related-party transactions, tariff oversight, open-network access and enhanced competition regulation.

It has also called for a comprehensive regulatory impact assessment and wider stakeholder consultations involving patients, healthcare providers, employers, labour representatives and civil society before any final decision is made.

The Portfolio Committee is expected to consider the submissions before making its recommendations on the proposed amendments, setting the stage for what could become one of the most consequential healthcare policy debates in recent years.

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