The rules look highly watered down. It doesn’t show the government to be in charge but rather like a collaborator with the private medical establishments.
- There is no mention of what happens if these Rules are not implemented or would that come in the main Act and Amendments? There is still only a draft version available on the GoK website.
- The initial Amendments said that the government would notify charges. Here it doesn’t say that the government has any control on regulating charges. It only says that “As far as possible, the committee shall use as reference the standard costing template formulated by the National Council constituted as under the Clinical establishment”
- There is no mention of charitable hospitals in any of these consultations. Bringing in NABH standards would adversely affect charitable hospitals in remote areas and could cause many of them to shut down giving a free unlimited playing field to the for profit sector.
- It doesn’t seem to be a good idea for registration and grievance redressal to be the same authority. (Section 7B – Composition of registration and grievance redressal authority)
- Technically all non official members of the grievance redressal committee could come from IMA and PHANA. The first member is from the IMA. The second could come from PHANA (Private Hospitals and Nursing Homes Association) and the third (woman nominee) could again come from either of these bodies. The initial clause that not more than 1/3 representation will be from the Private sector seems to have disappeared?
- For standards of infrastructure and staffing, there is one representative from PHANA, one from IMA and one from a tertiary (read corporate) private establishment. Why is there no public health, civil society or charitable hospital representation? One representative for NABH standards is again a corporate agenda.
- Why should PHFI be a representative on the Expert committee for classification, infrastructure and staffing and also to decide uniform package rates? When there are many concerns about PHFI, how can this organisation be mentioned as part of state rules?
- The executive director of SAST (state insurance scheme) is usually controlled by decision of board of SAST which predominantly comprises private players. Having the SAST director to decide uniform package rages may tilt costs in favour of the private sector rather than patients. Why have one representative from IIMB for deciding package rates? That would be another corporate pushing agenda. Technically 6 out of the 11 representatives would come with a corporate agenda when deciding the package
- The Uniform package rates are ONLY for healthcare assurance schemes for participating establishments. Is this for only BPL or APL as well? For APL only 30% costs will be borne by the government. Is the other 70% completely left to the whims of the private establishment? Will this also have to be displayed? There is no strong clarity on this.
- There is absolutely no mention of charitable hospitals or civil society organisations or patients groups to decide costs or for any form of decision making. All representation on the committees can technically be only the corporates
- Co-opting one specialist from public health institution and one from private for standard protocols of treatment, procedures and prescription audits will not be a good balance. It means that the government is not the primary regulator. There should be public health experts who are able to also look at costs beyond just procedures and from a larger context.
- Not sure if there should be a section on who should NOT be on these committees – eg. Pharma companies, nutraceuticals, large corporates, multinationals, tax evasion companies etc.
- There is no mention of the Rules for the Grievance redressal committee.
- The details of the members of these committees should be displayed on the department of health websites and also whether they have conflict of interest or not.
Dr. Sylvia Karpagam, Public health doctor and researcher, Karnataka
KPME-yake? 
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