THE Zimbabwe Medical Association (ZiMA) has submitted what it calls “The case for prohibiting vertical integration of Medical Aid Societies” to the Parliamentary Portfolio Committee on Health and Child Care, urging the passage of a proposed section 14A to SI 330 of 2000, which would prohibit medical aid societies from owning healthcare facilities.
Dressed in constitutional language and adorned with references to the World Health Organisation and the South African Medical Schemes Act, the document reads like a dispassionate policy brief from a neutral public-interest body.
Except that it is nothing of the sort.
ZiMA's paper is a lobbying document from an organisation whose members — independent doctors — stand to gain directly and materially from the regulation it advocates.
That does not automatically make its arguments wrong. But the paper's refusal to acknowledge this interest, while presenting itself as a guardian of patients, should concern every parliamentarian who reads it.
Who benefits?
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Let us begin where ZiMA's paper does not: with the question of cui bono — who benefits?
If medical aid societies are forced to divest from their clinics and hospitals, the immediate winners are independent healthcare providers, who would inherit the patient volumes currently served by medical aid-owned facilities. Independent healthcare providers are overwhelmingly ZiMA's own membership.
ZiMA frames the entire debate as one of patients versus profit. Yet it overlooks recent reports that more than 10 000 jobs could be lost, and over US$200 million in healthcare investment wiped out.
At an AHFoZ engagement last week, a representative of the Institute of People Management of Zimbabwe cited the case of a patient who avoided a US$600-per-night shortfall at a private hospital after being transferred to a medical aid-owned facility, paying just US$30 after three days.
“That kind of cost protection is what is at stake,” she said.
ZiMA's paper does not engage with this reality. It does not ask: where will these patients go? What will they pay? Who will absorb them?
These are not minor omissions. They are the central questions of the debate.
The four harms that never happened
The heart of ZiMA's argument rests on what it describes as four “real patient impacts”: a delayed referral, a missing test, a trapped civil servant and an early discharge.
These are presented as self-evident truths — vivid, emotionally charged scenarios that any reader would find alarming.
There is just one problem: not one of these examples is supported by evidence.
There is no case study.
No patient complaint record.
No clinical audit.
No Health Professions Authority finding.
No date, hospital, or outcome.
ZiMA asks Parliament to accept these as “real” impacts based, at best, on clinical intuition and, at worst, adversarial speculation about how medical aid-owned facilities must operate.
In a submission asking Parliament to prohibit an entire category of healthcare investment, the absence of even a single documented case is not a minor gap.
It is a disqualifying one.
If these harms are as systemic as ZiMA claims, where are the complaints? Where are the negligence cases?
The silence is telling.
The constitutional stretch
ZiMA's paper leans heavily on section 76 of the Constitution, which states that every citizen and permanent resident has the right to basic healthcare services and that the State must take reasonable legislative and other measures to progressively realise that right.
From this, ZiMA extracts the remarkable proposition that prohibiting medical aid societies from owning clinics is a constitutional obligation.
This interpretation stretches the Constitution beyond recognition.
Section 76 speaks about access to healthcare and the progressive realisation of that right. It says nothing about the ownership structure of healthcare facilities. It does not prescribe the separation of funders and providers any more than it prescribes a specific model of hospital ownership.
More critically, if the amendment results in the closure of facilities that currently provide affordable care to civil servants and low-income members — as AHFoZ and several stakeholders warn — then the amendment itself risks undermining section 76 by reducing access.
ZiMA's constitutional argument could just as easily be turned against its own proposal.
The misleading international tour
ZiMA points to South Africa, the United Kingdom and the World Health Organisation to argue that Zimbabwe would merely be “aligning with standards already governing its neighbouring jurisdictions.”
This comparison is misleading.
South Africa’s healthcare economy is vastly larger, with a private hospital sector dominated by large listed companies such as Netcare, Mediclinic and Life Healthcare.
Zimbabwe’s private healthcare sector, by contrast, is fragile, underfunded and losing professionals.
Transplanting regulatory prohibitions from a fundamentally different market without importing the conditions that sustain them is not policy alignment.
It is policy imitation.
More importantly, South Africa’s Medical Schemes Act does not actually prohibit vertical integration, contrary to ZiMA’s suggestion.
The Act defines the business of a medical scheme to include “the rendering of a relevant health service, either by the medical scheme itself or by a supplier of such service in association with a scheme.”
Preferred provider networks and contractual arrangements are therefore explicitly recognised.
The United Kingdom comparison is even less persuasive. The NHS is a publicly funded, universal healthcare system. Zimbabwe does not operate a national health insurance scheme.
Invoking the NHS model in a country where the public healthcare system is in crisis, and medical aid coverage is a lifeline for those who can access it, is largely irrelevant.
As for the WHO, its guidance identifies the separation of purchasing and provision as a feature of well-performing systems — but as a principle for mature health systems, not a prescription for dismantling infrastructure in fragile ones.
On clinical independence
ZiMA argues that patient safety requires clinical independence, and that clinical independence requires separating financing from provision.
This is a neat slogan, but it collapses several distinct ideas into one chain of necessity.
Clinical independence means clinicians can make decisions based on evidence and patient need without interference from financial managers.
That independence can be protected through regulation, clinical governance, professional oversight, audit requirements and enforceable sanctions.
It does not logically require that the payer and provider must never exist within the same corporate structure.
If ZiMA believes medical aid-owned facilities systematically override doctors, discharge patients prematurely or block referrals, the appropriate response is evidence and enforcement — not structural prohibition.
Clinical audits, complaint statistics and regulator findings should guide the debate.
A blanket ban is a remedy without a record.
In a fragile system with limited private capacity, forced divestiture could shrink the provider network, raise co-payments and reduce access — which itself creates patient-safety risks.
A patient who delays care because they cannot afford it is not “safer” simply because the clinic’s ownership structure satisfies a theoretical principle.
The tariff grievance hiding in plain sight
Perhaps the most revealing section of ZiMA’s submission concerns tariffs.
ZiMA argues that low reimbursement rates, delayed payments and administrative burdens imposed by medical aid societies are destroying independent medical practice.
But the paper omits a crucial fact: Zimbabwe has no standardised provider tariff system.
Doctors do not charge common rates for consultations or procedures.
A GP consultation in Borrowdale may cost one amount, the same consultation in Avondale another, and in Bulawayo yet another. Specialists and surgeons set their own fees.
There is no transparent schedule that patients or funders can reference to determine what constitutes a fair price.
This is not a minor detail. It is the structural root of the tariff dispute that ZiMA attributes entirely to medical aid societies.
Funders pay what they can, constrained by the premiums they collect and their obligation to spread risk across members.
Providers charge what they choose — individually, without coordination or a common benchmark.
When the gap between the two produces a shortfall, ZiMA blames the funder.
But on what basis should funders accept a tariff when providers themselves cannot agree on one?
The absence of a transparent, standardised tariff schedule is first and foremost a failure of the profession itself.
If ZiMA is serious about tariff reform, the starting point should be the development of a credible national tariff framework.
Until providers themselves can agree on what healthcare should cost, it is difficult to accuse funders of paying too little.
The patients ZiMA does not speak for
The most vulnerable members of Zimbabwe’s medical aid system are civil servants on PSMAS — teachers, nurses, police officers and clerks earning modest salaries.
For many, medical aid-owned clinics are the only facilities where care can be accessed without crippling out-of-pocket costs.
ZiMA characterises this as “trapping” civil servants.
But from the patient’s perspective, those clinics are not a trap.
They are a lifeline.
Closing them does not expand patient choice.
It removes the most affordable option.
What would actually help patients?
None of this suggests Zimbabwe’s medical aid system is perfect.
But the solution is regulation, not forced divestiture.
Meaningful reform should include:
lAn independent medical aid regulatory authority with investigative powers
lTransparent tariff-setting through an independent body
lMandatory disclosure and governance rules where medical aid societies own facilities
lPatient-choice protections allowing members access to accredited providers without punitive co-payments
These reforms address the concerns ZiMA raises without destroying infrastructure or eliminating jobs.
A profession’s credibility is at stake
ZiMA should be a respected voice in Zimbabwe’s healthcare system. Its members operate on the front lines of a sector under immense strain.
But credibility matters.
A submission that presents hypothetical harms as evidence, selective international comparisons as settled consensus and professional self-interest as constitutional obligation weakens the profession’s voice.
Parliament should read ZiMA’s submission carefully — and then ask the questions it does not answer:
How many patients could lose affordable access to care?
How many jobs could disappear?
Where is the evidence that clinical outcomes at medical aid-owned facilities are worse than those at independent practices?
What regulatory alternatives were considered and rejected — and why?
Until those questions are answered, the proposed reform deserves what any questionable diagnosis demands: a second opinion.