Educational Psychology Association of South Africa
P. O. Box 924
Att: Dr Anban Pillay
The Director General of Health 21 September 2018
Pvt Bag X828
SUBMISSION TO PARLIAMENT ON THE NATIONAL HEALTH INSURANCE BILL
This submission seeks to contribute to development and implementation of the National Health Insurance scheme (NHI), as introduced in the National Assembly (proposed section 76); explanatory summary of Bill published in Government Gazette No. 41725 of 21 June 2018.
The Educational Psychology Association of South Africa (EPASSA) aims to promote, maintain and protect the honour and interests of Educational Psychology as a profession, and to facilitate the provision of quality educational psychology services to the public by members of the association. EPASSA can be contacted at email@example.com or www.epassa.net. EPASSA wishes to engage with and become active participants in the implementation of the NHI Scheme.
The Educational Psychology Association of South Africa (EPASSA) thanks the Minister of Health and the NDOH for the opportunity to comment on the NHI Bill. EPASSA endorses Parliaments aspirations to establish a society based on democratic values, social justice and fundamental human rights and the need to improve the life expectancy and the quality of life of all citizens.
EPASSA also ratifies the importance of mental healthcare as a key focus of the initial stages of the NHI implementation by realising the need for mental healthcare and the array of competencies found amongst all categories of psychologists as key providers of mental health providers.
EPASSA supports the initiative of child and family healthcare, school health services and community-based services. Educational Psychologists, as specialised mental healthcare practitioners, are particularly skilled in the following areas:
The evaluation of behaviour or mental processes or personality adjustments or adjustments of individuals or of groups of persons, through the use or interpretation of any psychological test, questionnaire, instrument, apparatus, device or similar method for the determination of intellectual abilities, aptitude, interests, personality make-up or personality functioning, and the diagnosis or measurement of personality and emotional functions, neuropsychological disorders and mental functioning deficiencies according to a recognised scientific system for the classification of mental deficiencies;
the use of any psychological method or practice aimed at aiding persons or groups of persons in the adjustment of personality, emotional or behavioural problems or the promotion of positive personality change, growth and development, and the identification and evaluation of personality dynamics and personality functioning according to scientific psychological methods;
the evaluation of emotional, behavioural and cognitive processes or adjustment of personality of individuals or groups of persons by the usage and interpretation of psychological questionnaires, tests, projections, or other techniques or any apparatus, whether of South African origin or imported, for the determination of intellectual abilities, aptitude, personality make-up, personality functioning, psycho-physiological functioning or psychopathology;
the exercising of control over prescribed psychological questionnaires or tests or prescribed techniques, apparatus or instruments for the determination of intellectual abilities, aptitude, personality make-up, personality functioning, psychophysiological functioning or psychopathology;
the development of and control over the development of psychological questionnaires, tests, techniques, apparatus or instruments for the determination of intellectual abilities, aptitude, personality make-up, personality functioning, psychophysiological functioning or psychopathology;
the use of any psychological questionnaire, test, prescribed techniques, instrument, apparatus, device or similar method for the determination of intellectual abilities, aptitude, personality make-up, personality functioning, temperament, psychophysiological functioning, psycho-pathology or personnel career selection;
the use of any psychotherapeutic method, technique or procedure to rectify, relieve or change personality, emotional, behavioural or adjustment problems or mental deficiencies of individuals or groups of people;
the use of any psychological method or psychological counselling to prevent personality, emotional, cognitive, behavioural and adjustment problems or mental illnesses of individuals or groups of people; and
Developing and managing mental healthcare preventative programmes in community-based settings.
Emphasis needs to be placed on schools being a community setting for child and family mental healthcare. EPASSA seeks to highlight the core competencies of educational psychologists, as mentioned above, as a resource in providing such mental healthcare and psycho-education in school environments. EPASSA welcomes the opportunity to engage in consultation regarding the establishment of vital core mental health services in community settings.
Whilst the National Health Insurance scheme is welcomed conceptually, the Bill lacks clarity on a number of issues including (but not limited to):
Section 10 states that the Fund must reimburse health care providers for the health service benefits rendered to the eligible users. No clarity is provided as to how this reimbursement process will be initiated. EPASSA seeks to be included in public participation and engagement with the Benefits Advisory Committee as to how this process will unfold. Affordability of healthcare reform for South Africa is quantified by comparison to various other developing, middle-income countries in the past Green- and White Papers. In one version of the White Paper it stated that “Previous attempts of health care reform worldwide that did not encompass reforms to health care financing have not always been successful in some countries whilst countries such as Mexico and Thailand are examples of countries where attempts to transform health financing have been positive.” These comparisons of South Africa with other developing, middle-income countries needs to be investigated as to whether or not, it is an appropriate comparison considering the diversity of the South African context and particularly, bearing in mind the need for mental healthcare at a community-based level.
“Health Establishment” refers to the definition of same contained in the National Health Act. This definition is remarkably broad and includes both private and public institutions, facilities buildings or places. This definition will include private medical practices, and consequently more information is required in terms of how private medical practices will integrate into the broader system and furthermore, become accredited to do so.
The definitions as set out in the act, refer to a health establishment or health agency that must be in possession of a Certificate of Need (sec 36 of the NHA). As yet, this provision and its related sections in the National Health Act have not been implemented. The regulations required for the implementation of the Certificate of Need, in terms of section 39 of the National Health Act have yet to be published for comment. In essence, the administrative infrastructure and prescribed fees and documentation to issue and deal with the Certificate of Need is yet to be established. Similarly, the definition of a “Healthcare Provider” includes the registered practitioners under the Acts referred to in the National Heath Act but does not include other healthcare professionals who provide services in the healthcare sector. The concept “health worker” referred to in the Draft Bill is also not defined as it is in the NHA.
“Primary health care services” refers to services that “include” health promotion, disease prevention etc., but does not actually define the concept. In the NHA, this concept is defined as “such health services as may be prescribed from time to time by the Minister”. No such prescriptions have been made by the Minister and therefore this concept actually remains undefined. Clarity is required as to what this concept defines and what type of health services it will encompass.
Section 54, Transitional arrangement, refers to the initiation of legislative reforms in order to enable the introduction of National Health Insurance, including changes to a variety of Acts. The Mental Healthcare Act 2002 (Act no.17 of 2002) is indicated as one of the Acts to be reformed, yet no further information is provided regarding what reformation will occur and when this will be gazetted for public comment. This provides for great confusion and uncertainty for all mental healthcare practitioners in South Africa.
Moreover, several important and vital concepts referred to in the Bill are not appropriately defined. These include concepts such as services (not) “medically necessary”, “health workers”, “medical insurance scheme”, “universal purchasing”, “active purchasing”, “executive management” of the NHIF, “non- personal health care services”, “personal health services”, “horizontal networks”, “Contracting Unit”, “national pricing regimen”, “supplier”. It is necessary for the purposes of precision and the correct interpretation of this Bill that these concepts be properly defined.
Thus, there is a strong need for further public comment and engagement by various interested stakeholders, such as EPASSA, and other representative bodies for healthcare providers in South Africa. This submission is not meant to be exhaustive or a complete/final comment on the Acts discussed. EPASSA wishes to be actively involved and consulted in the process of developing and refining the provisions of mental healthcare as outlined above.
CHAIRPERSON – EDUCATIONAL PSYCHOLOGY ASSOCIATION SOUTH AFRICA