Break up NHIF into 3 separate entities: Cofek comments to the Senate on the National Health Insurance Fund (Amendment) Bill

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• The NHIF should be transformed into a social security fund whose mandate will be to equip, buy drugs and pay for services offered to patients across the country. Some of the roles undertaken by KEMSA should be taken up by the new NHIF

• Break up NHIF into three (3) entities: (a) ‘Health Bank’; (b) Health Services Board and (c) as NHIF Insurance.

(i) As a bank, NHIF will deal with collections and disbursements to accredited health facilities;
(ii) As a Health Services Board, NHIF should review strategy based on research and benchmark on evaluating ways and means in which many more Kenyans could access UHC, cheaper medication, re-investments etc; It will also develop standards for accreditation of hospitals and doctors under the special and defined scheme – covering all conditions and as an insurer,
(iii) NHIF will offer more options and compete with private sector but allow all special health conditions to be covered – under different terms and subsidized premiums – for the poor

• Poor policies on outpatient cover: It should be capitation-based and not claims based. Even without decapitation, not a single doctor should make referrals especially for specialized and expensive procedures. Verification by another doctor is needed. An independent counter-check should be done. All such referrals should be scanned and put up online so as to be accessed by doctors from other quarters especially those independent ones for purposes for transparency and accountability

• Create viable incentives to allow for voluntary contributions well beyond the legal ceiling

• Clear roles of the National Government and that of the County Governments should be defined on linking NHIF to health infrastructure and specialized personnel. The construction of health facilities and deployment of human resources should be left to County Governments while the standards, acquisition of specialized equipment, drugs and cost of treatment should be a responsibility of National Government through NHIF.

• UHC should only be provided by public health facilities and only limit referral cases to private and international hospitals – complete with clear checks and balances. Private hospitals should only be adopted on emergency and cost-sharing basis

• NHIF should be delineated from politics. The Management and board of directors should be competitively recruited and not politically handpicked. Agencies seconding nominees should offer at least 3 nominees and that each of the selected nominee only serves for one term of 3 years. Government representation should be limited to no more than 3. Representatives of consumers of health services in line with Article 46 of the Constitution ought to be considered. De-politicize NHIF by having it report to an inter-ministerial panel of Health, Treasury, Labour and Internal Security.

• NHIF staff should all be on renewable contracts

• NHIF should be responsible for registering Ambulances across the country with minimum standards of equipment on board and qualifications of personnel depending on the illness of the patient

• NHIF should cater for other pillars of UHC i.e. preventive and promotive health care. Support medical screening e.g. Prostate – Specific Antigen (PSA) for all males above 40, Pap smears , breast exam for women above 40

• Prompt reimbursement by NHIF to service providers, set to no more than 2 weeks, will reduce opportunities for corruption. Further, all the Health Information System be developed and ensure that all NHIF departments are automated

• In remote or nomadic areas , fully equipped mobile clinics should be registered for provision of UHC

• UHC should also cover emergency evacuation for fire victims, on our roads and lakes. Strategically along our roads we should have evacuation ambulances for accident victims.

• Under UHC the cost of treatment for any disease should be standardized and the only difference should be care services e.g. Bed, food, room for patients. Care services costs can be capped under UHC beyond which the patient pays. This will discourage rushing of patients to high-cost private hospitals. There is absolutely no reason why a doctors fee for a Caesarean section (CS )in one hospital is 15k while in another is Sh180,000? Based on volume of scale, it can be comfortably cost less than Sh50,000

• UHC will be successful if we have public education and sensitization on cultural behavior and beliefs on witchcraft etc

• Public health facilities at the village level should be equipped to handle most of the common diseases and only refer the complicated cases to private or higher public health facilities.

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