National Health Bill – presentation to Portfolio Committee

1. National Health Bill – presentation to Portfolio Committee Dr. Saadiq Kariem for ANC national health secretariat & committee

2. GENERAL COMMENTS • ANC Health Secretariat and Committee would like to fully support the Bill; and congratulate the Ministry and DOH on a comprehensive document. • The primary objective of the Bill: to establish a unitary health system is achieved • Co-operative governance between the various sections of the SA health system is achieved.

3. Clear distinctions are presented between the national, provincial, local spheres of government • Bill clarifies the distinction between municipal health services & prov/national • Bear in mind health care principles of Alma Ata – move governance to lowest level possible

4. Bill largely silent on regulation of private sector although other legislation exists ( eg MSA + related amendments ) • NHB deals with service provision/ dispensing vs. MSA deals with licensing – needs to be borne in mind • WHO Report of 2000: SA inability to control rampant private sector

5. Support the UWC recommendations on equity in preamble: but also Need more equity in terms of health care financing between the public and private sectors • consider accepted principles of PHC: efficiency, effectiveness & WHO concepts of Goodness & Fairness

6. We note the recommendations of COSATU / NEHAWU on issues of SHI / NHI in terms of the Mafikeng & Stellenbosch resolutions of the ANC; • This is a difficult issue but perhaps needs some directive in the Bill and follow the recommendations of the DOH on this matter for a 2 stage development of SHI first then move to NHI

7. Chapter 2: Users & HC providers • Emergency treatment ( S 5 ): should this be defined? • Consent ( S 7): form should be specified ( written vs. oral ) • HC provision without consent: if Serious risk to public health – needs to be defined ito HR culture

8. User participation ( S8) : difficult issue – need enabling mechanisms to realise this right for disempowered • Discharge reports ( S 10 ): should include inpts & outpts; should include basic Dx, Rx, Follow up • Dissemination of info ( S 12 ): support this but difficult from facility point; ? Operating schedules

9. Confidentiality & Access to records: fully support • Complaints (S18): need an action plan / recourse to further action should complainant not be happy: difficult ? Timeframes • Responsibilities of users (S 19): expanded to include own responsibility for health

10. Rights of health care providers not specifically mentioned at all – include :eg Protection against abuse of health workers? • Appropriate delegations ito S 97 to heads of institutions where appropriate

11. Chapter 3: National Health • Fully support functions of the national DOH ( S 20 ) • Potential conflicts between national norms vs. provincial policies – National role vs. Schedule 4 competency • National Health Council to have more direct control over SAMHS? & thus use of military hospitals for public use • National Health Forum to meet annually ( not every 2 years )– do more than merely share information, could provide input to national policies/ implementation progress

12. Chapter 4: Provincial Health • Support the implementation role of provincial DOH ( S 27 ) • Planning of private facilities in provinces to be carefully monitored – prevent excesses • Providing health services to prisons? Will have budgetary implications fro health • PH Council is weighted towards local municipalities & local government (S 28 ) • Any financial / other assistance received by provinces from foreign govts / donors to provinces must be sanctioned by national DOH to ensure equity and equitable access to $ and £

13. Chapter 5: District Health System • Support the contiguous and continuous boundaries • Municipal health services in the Bill do not include some the preventive / elements – vs. principles of Alma Ata • Community Involvement in health – needs to be permeate all sections

14. Chapter 6: Health establishments • Classification of facilities (S 40 ): should classification be linked to service delivery? • If so: need delinking of academic institutions from traditional tertiary support base • Certificate of Need ( S41 ): STRONGLY SUPPORT this – needs to be more restrictive of private establishments • Too restrictive of public facilities eg. Increase/ decrease in beds depended many operational factors • Establish appeals process in S 43 ito fairness of who gets the C. of Need

15. Chapter 7: HR planning • (S53) AHC: as above: delinking tertiary teaching platform from tertiary service platform in line with WHO – support UWC changes to ( S53)& ( S 56 ) • Development of Finance & Personnel plans should be compulsory for all levels of health service • These should bear in mind national needs, normative standards, skills mix

16. Governance issues ito the DHS must be resolved wrt conditions of service etc ( see also UWC presentation ) • Representation of academic institutions on national / provincial bodies resolved with DOE ( see also UCT presentation ) • Support the UWC position & move further to: active redistribution plan to ensure equity ito rural-urban divide; doctor-nurse; inter-provincial equity

17. Absolute nursing crisis – need to expand the teaching units in SA; and ? • DIFFERENT PARADIGM IN SOUTH AFRICA: HR planning: • Development of a new cadre of health worker in SA – entry level health practitioners; a mid level health practitioner; nurses; doctors • Need to prevent the super-specialisation of doctors in favour of generalists who can be utilised at secondary & primary levels

18. Chapter 8: blood & related products • Regulation of prices should be responsibility of National DOH and not NPO ( S 58 ) • Bl. Transfusion service must be national entity • Some form of regulation of number of facilities that can be designated – public & epidemiological needs

19. Chapter 9 & 10 • National research structure should have some regulatory functions ito national research agenda that appropriate to SA demographics, BOD, epidemiological transitional profile • Support establishment of Office of Standards Compliance & regulatory role