The draft NHI Bill again places a tremendous amount of power in the hands of the all knowing Minister as most of The Bahamas legislation does.
Here are a few of my quick thoughts.
I would be delighted to receive yours.
7. Powers of Authority
(b) to set the payment rate to establish and administer the risk adjustment mechanism for Administrators for the benefits under the Plan;
(c) to fix fee schedules, set payment rates and establish risk adjustment mechanisms for Providers for the various benefits under the Plan;
(b) and (c) are in effect Price Controls and we know the outcome of those.
(d) to cause on-site inspections in accordance with Section 36;
More Bureaucracy and time wasting.
12. Accounts and audit
(a), (b), (c) – books records, financials presented to House annually and b-annual actuarial projections.
No penalty for non-compliance
13. Borrowing Powers
Should borrowing be a provision? Taxing for it so why would this be necessary?
18. Enrolment of beneficiaries
(5) power to appoint a doctor for people that do not select one.
21. Coordination of benefits
If one has private insurance they will be primary payer? This should be a choice. After all one is being forced to pay premiums to the government.
22. Termination or suspension of benefits
Refers to section 16 but I don’t see a correlation between power to invest (16) and (22) termination of benefits?
This section also makes me say why bother to enrol?
23. Contributions
If you don’t pay you can’t get service?
32. Withdrawal
Gives Administrators and Providers an out.
34. Power to require information
(2) Minister can Amend Third Schedule? This is only names of bodies involved in delivery of health services, but how a Minister simply amend a law?
(3) fines are excessive for failure to produce and record or supply any information
35. Maintenance of records
This will become even more onerous than it is now for doctors and hospitals.
36. Routine inspection of providers
Will lead to snooping by the authorities
37. Report
No penalty for late or no filing.
38. Determination of questions and grievances
Does this give them the power to prevent a matter going to court as you can only appeal to the Supreme Court. This essentially prevents law suits.
40. Offences and Penalties
Fines are excessive.
First Schedule
1. Constitution of Board
Should it include the Shadow Minister of Health?
6. Remuneration
Minister decides remuneration and allowances. Really?
10. Confidentially
Confidentially of patient health records are important but what if the Board Member suspects malfeasance of some sort?
