South African Psychiatry - November 2018

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SASOP SOUTH AFRICAN SOCIETY OF PSYCHIATRISTS provinces, and thus may not be implementable at provincial level. While there have been multiple reports of provinces failing to implement national policy, including media reports by the South African Society of Psychiatrists, it must be acknowledged that the NDOH has not drafted a programme guideline for the implementation of the National Mental Health Policy Framework and Strategic Plan 2013-2020. Additionally, no funding has been allocated at national level for its implementation, or even for the implementation of the MHCA. With the present NDOH Annual Performance Plan, provinces are to establish District Specialist Mental Health Teams, however there is no funding allocated to these teams in the national medium-term expenditure framework. Questions have also been raised by the South African Federation of Mental Health and the NMHAP regarding the practicality of the recently gazetted NDOH Policy Guidelines for the licensing of residential and/or day care facilities for persons with mental illness and/or severe or profound intellectual disability. Hence, while there is a need for improved coordination of service delivery with provinces, there appears also to be a need for the NDOH to develop realistic and implementable policy and guidelines. The NHI Act should make provision for: 1. Full provincial involvement in the development of national health policy and plans. 2. Such policy and plans must be ratified by provinces as being relevant and implementable by provinces before being gazetted by the NDOH. 3. Feedback mechanisms for rapid adjustments to be made when necessary, i.e. when problems in implementation represent a risk to users which cannot await standard quality assurance mechanisms of change. • Health Care Providers The Bill sets out obligations of the Fund in terms of payment and accreditation of health care providers, and duties of health care providers with respect to the rights of users. The Fund has a duty to “determine prices annually after consultation with health care providers, health establishments and suppliers in the prescribed manner and in accordance with the provisions of this Act” (Section 5(1)(f)). However, there is no provision for direct health care provider representation on any of the committees. The heads of medical schools and other members of the Benefits Advisory Committee, and the statutory councils, tertiary education institution and other members of the Stakeholder Advisory Committee do not have any scope in determining working conditions or reimbursement needs of practicing health care providers. This leaves only indirect representation on the Health Benefits Pricing Committee and one labour representative on the Stakeholder Advisory Committee through which the Fund may consult with health care providers regarding the cost of services provided. It is not possible to provide quality health care without addressing the needs of health care providers. The provisions of the Bill run the risk of dissatisfied and frustrated health care providers, with consequences of increased emigration or strong unionisation. Neither of these situations bode well for South Africa. The NHI Act should: 1. Provide for health care provider consultation and negotiation in a properly structured and representative forum. 2. Specify health care provider representation on the Health Benefits Pricing Committee and the Stakeholder Advisory Committee. CONCLUSION We thank the Minister of Health and the NDOH for the opportunity to comment on the NHI Bill. Overall, we welcome the intentions of the Bill to strengthen and reorganise the South African health system but have serious concerns about the Bill’s ability to do that. Our comments are in the interests of an improved system which will serve the population of South Africa, improving the health and mental health of all. We look forward to a health care system which does not discriminate between users, regardless of race, socio-economic status, or type of illness, impairment or disability 78 * SOUTH AFRICAN PSYCHIATRY ISSUE 17 2018
10 “How beautifully leaves grow old. How full of light and colour are their last days.”
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ISSN 2409-5699 ABOUT the discipline
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Features EQUINE ASSISTED 7 PSYCHOTH
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FROM THE EDITOR Dear Reader, welcom
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ORIGINAL EQUINE ASSISTED PSYCHOTHER
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ORIGINAL and horses, and which usua
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ORIGINAL focused on the efficacy of
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ORIGINAL of Science in Rehabilitati
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Global Health Education Ltd: Global
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BOOK SHOOTING WAR Title: SHOOTING W
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Make XEPLION ® your FIRST CHOICE f
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South African Psychiatry - November 2018

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