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Competition in the Irish Private Health Insurance Market

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Figure 7: Key features of Related <strong>Health</strong> <strong>Insurance</strong> Products<br />

Product Type<br />

<strong>Health</strong> Cash Plans<br />

Serious/Critical<br />

Illness <strong>in</strong>surance<br />

Income<br />

Protection<br />

<strong>Insurance</strong>/<br />

Permanent <strong>Health</strong><br />

<strong>Insurance</strong><br />

Key features<br />

Daily cash payments for <strong>in</strong>patient<br />

hospital stays and<br />

perhaps payments towards<br />

primary care medical costs.<br />

Lump-sum cash payment if<br />

subscriber is diagnosed with a<br />

specific illness or disability<br />

covered by <strong>the</strong> policy (e.g.<br />

cancer or stroke) for which <strong>the</strong><br />

long-term <strong>in</strong>capacitat<strong>in</strong>g effects<br />

are not normally covered by PHI.<br />

Provides a regular <strong>in</strong>come if a<br />

subscriber becomes unable to<br />

work as a result of physical or<br />

mental ill-health.<br />

Proportion of<br />

PHI holders<br />

with this<br />

product 32<br />

21%<br />

33%<br />

31%<br />

Are Policies Offered by Restricted Membership Undertak<strong>in</strong>gs<br />

Substitutes for PHI?<br />

3.12 In addition to <strong>the</strong> three ma<strong>in</strong> open enrolment PHI providers, PHI is also<br />

provided by ‘restricted’ membership undertak<strong>in</strong>gs, so-called because<br />

<strong>the</strong>ir membership is restricted to employees of particular organisations<br />

and <strong>the</strong>ir family members. The ma<strong>in</strong> restricted schemes are <strong>the</strong> ESB<br />

Staff Medical Provident Fund, <strong>the</strong> Prison Officers Medical Aid Society,<br />

and St Paul’s Garda Medical Aid Society.<br />

3.13 The PHI plans offered by restricted undertak<strong>in</strong>gs are only available to<br />

very specific groups of people (e.g. ESB staff, prison officers or<br />

members of <strong>the</strong> Gardai respectively and <strong>the</strong>ir family members). They<br />

are not available to <strong>the</strong> general public. The policies offered through <strong>the</strong><br />

largest restricted schemes are similar to <strong>the</strong> most popular policies<br />

offered by <strong>the</strong> open enrolment providers. It is highly likely that a large<br />

majority of <strong>the</strong> members of <strong>the</strong>se schemes would subscribe to an<br />

open-enrolment health <strong>in</strong>surer if <strong>the</strong>ir particular restricted scheme was<br />

not available to <strong>the</strong>m. Therefore, <strong>the</strong>re is asymmetric substitutability. 33<br />

Never<strong>the</strong>less, <strong>the</strong>se schemes do not exert any competitive discipl<strong>in</strong>e on<br />

<strong>the</strong> three ma<strong>in</strong> <strong>in</strong>surers as <strong>the</strong>y are not available to <strong>the</strong> general public.<br />

For this reason, <strong>the</strong> restricted membership schemes are not considered<br />

to be <strong>in</strong> direct competition with open enrolment PHI plans and as such<br />

are excluded from <strong>the</strong> relevant product market.<br />

32 Source: The <strong>Private</strong> <strong>Health</strong> <strong>Insurance</strong> <strong>Market</strong> <strong>in</strong> Ireland – A <strong>Market</strong> Review, September 2005 (HIA)<br />

33 Those people who are eligible to take out <strong>in</strong>surance under <strong>the</strong> restricted schemes have <strong>the</strong> option of<br />

tak<strong>in</strong>g out a policy with any of <strong>the</strong> three ma<strong>in</strong> open enrolment <strong>in</strong>surers so for <strong>the</strong>se people, <strong>the</strong><br />

products would be substitutable.<br />

44

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