Many Zimbabweans currently access healthcare through clinics, laboratories and other facilities owned by their medical aid societies. These facilities provide convenient access to chronic medication, primary healthcare services and a range of healthcare services at predictable costs, helping members and non-members avoid significant out-of-pocket expenses. Under the proposed amendments to the Medical Aid Societies Regulations, however, medical aid societies would be required to dispose of these facilities, regardless of whether they are operating effectively or serving an important role in expanding access to care.
The Board of Healthcare Funders (BHF), representing healthcare funders across Southern Africa, supports effective regulation that promotes transparency, accountability and fair competition. However, any reform of this magnitude must be carefully assessed against a simple question - will it improve access to affordable, quality healthcare for the people who depend on these services?
Medical aid societies in Zimbabwe did not enter healthcare service provision by accident. In many cases, they responded to practical challenges affecting their members' ability to access care. Zimbabwe's history of currency instability has repeatedly eroded the value of financial assets and reserves. In this environment, investment in healthcare infrastructure has provided a means of preserving value while simultaneously expanding access to care.
The results have been positive. Facilities established by medical aid societies have, in some cases, expanded services into underserved areas, providing care not only to members but also to surrounding communities. In these circumstances, vertical integration has helped address service gaps, improve access and create greater certainty around healthcare delivery.
The proposed amendments may have several unintended consequences.
First, members could face higher healthcare costs if scheme-owned facilities are replaced by external providers operating under different pricing structures. This may place upward pressure on contributions, reduce benefits and/or increase out-of-pocket expenditure.
Keep Reading
- Mavhunga puts DeMbare into Chibuku quarterfinals
- Bulls to charge into Zimbabwe gold stocks
- Ndiraya concerned as goals dry up
- Letters: How solar power is transforming African farms
Second, compulsory divestiture within a 36 month fixed timeframe could weaken the financial position of medical aid societies. Assets accumulated over many years through member contributions may need to be sold under challenging market conditions, potentially reducing their value and affecting long-term sustainability.
International evidence demonstrates that competition alone does not necessarily guarantee better healthcare outcomes, nor does it support the view that insurer-provider integration is inherently harmful. Healthcare markets differ fundamentally from conventional consumer markets. Patients often require care urgently, have limited information on quality and pricing, and are not in a position to compare providers in the way economic theory sometimes assumes.
For this reason, healthcare systems around the world increasingly seek to balance competition, regulation and strategic purchasing rather than relying on structural separation between funders and providers. Many jurisdictions permit forms of vertical integration subject to appropriate safeguards. The Health Maintenance Organisation model in the United States is one example. South Africa's Medical Schemes Act similarly allows schemes to provide healthcare services to their members under specified conditions. The World Health Organization's work on strategic purchasing also focuses on governance, accountability and contracting arrangements rather than blanket structural separation.
Importantly, utilisation data from affected Zimbabwean schemes suggests that society-owned facilities represent only one component of broader provider networks. Most healthcare services continue to be accessed through external providers, indicating that concerns around market foreclosure may warrant closer examination before far-reaching structural changes are introduced.
The BHF recognises that concerns around conflicts of interest, governance and competition deserve appropriate regulatory attention. The question is not whether oversight is required, but how it can be achieved without disrupting healthcare access or undermining infrastructure that members have helped finance.
A proportionate regulatory framework could address these concerns through stronger governance and transparency measures rather than outright prohibition. This could include ring-fenced governance structures with independent oversight and full disclosure of related-party transactions, alongside open-network protections that preserve members' freedom to access external providers. Transparent transfer-pricing arrangements, supported by appropriate regulatory review and audit requirements, would help ensure accountability, while competition authorities could retain oversight of acquisitions and expansions in circumstances where market concentration concerns arise.
These measures would address legitimate regulatory concerns while preserving healthcare capacity, protecting member interests and supporting affordable access to care.
The proposed amendments also raise important legal and policy questions that merit careful consideration. Section 76 of Zimbabwe's Constitution protects the right to access healthcare services. Policymakers will therefore need to assess whether the proposed restrictions could unintentionally reduce healthcare access or affordability for scheme members.
Questions have also been raised regarding the scope of the Minister's regulatory authority under the Medical Services Act and whether restrictions relating to ownership structures may intersect with competition policy frameworks administered elsewhere in government.
In addition, medical aid society assets have generally been accumulated through member contributions over extended periods. Any regulatory intervention affecting those assets should be accompanied by meaningful consultation with members and a transparent assessment of potential consequences.
According to Afrobarometer data cited in stakeholder submissions, 87% of citizens surveyed did not have medical aid coverage, with affordability identified as the most common reason. Against this backdrop, any policy intervention that increases healthcare costs or reduces service capacity risks moving the country further away from Universal Health Coverage rather than closer to it.
The BHF therefore encourages policymakers to pause, undertake a comprehensive regulatory impact assessment, and engage meaningfully with members, employers, providers, civil society and financial regulators before proceeding.
The objective shared by all stakeholders should be clear: ensuring that Zimbabweans can access quality healthcare when they need it, at a cost they can afford.
Effective regulation should strengthen access, improve accountability and support sustainable healthcare delivery. In the end, the most important measure of any reform is not whether it changes ownership structures, but whether it improves outcomes for patients.
*Dr Katlego Mothudi is Managing Director of the Board of Healthcare Funders (BHF). The BHF is a non-profit company that works in the best interest of an effective and sustainable healthcare for all. It represents members in seven countries across Africa.