By Enock Musungwini, MPH; MBA
There are varying definitions and descriptions of what a medical aid is. Medical aid societies, also known as private health insurance companies, are non-profit or for-profit entities that provide health coverage by pooling member contributions to finance medical services. According to Shylet Sanyanga, the AHFoZ CEO, a medical aid is a form of insurance where members pay a monthly fee (called a contribution or premium) in return of financial cover for medical treatment or related medical expenses when the need arises. Medical aid members contribute money into a pool on a regular basis to cover health related expenses for any one of the contributing members as and when the need arises. According to the Medical Services Act Chapter 15:13, a medical aid society is an association or organization which accepts subscriptions from members or other persons wholly or mainly for the purpose of (a) paying any expenses incurred by such members or persons and additionally, or alternatively, their dependents or employees, in respect of medical or dental treatment; (b) meeting the whole or part of any expenses incurred by such members or persons and additionally, or alternatively, their employees, in respect of medical or dental treatment. Medical aid societies help protect individuals and families from catastrophic health expenditures, promote access to essential healthcare and promotes Universal Health Coverage.
Zimbabwe currently has over 30 registered medical aid societies serving both the formal and informal sectors with over 90% of these medical aid societies being members of the Association of Healthcare Funders of Zimbabwe (AHFoZ). AHFoZ is the recognized representative body for the medical aid industry in Zimbabwe with 36 medical aid societies and 4 associates (AHFoZ, 2025). Medical aid societies in Zimbabwe cover approximately 10% of the total population, with an estimated industry value of US$392 million annually (Statistica, 2025) and contributes to about 30% of the total health expenditure in Zimbabwe (Mhazo et al., 2023). This is evident that the medical aid sector plays a critical role in the financing of health services in Zimbabwe, yet questions still persist on who should regulate the industry.
Regional picture on regulation of medical aid societies
Globally, the regulation of medical aid societies or private health insurance organisations takes into account the unique nature and characteristics of health which is not an ordinary commodity. In South Africa, medical aid societies or schemes are regulated under the country’s Medical Schemes Act by the Council for Medical Schemes (CMS). The Council for Medical Schemes is a statutory body established by the Medical Schemes Act (198 of 2013) to provide regulatory oversight and supervision of private health financing through medical schemes in South Africa. The CMS reports to the Minister of Health through the board and its mission is to protect beneficiaries while aligning with national health policy. In Zambia, health insurance is jointly regulated by the Pensions and Insurance Authority (PIA) and National Health Insurance Management Authority (NHIMA), ensuring that both general insurance principles and the specific and unique needs of health insurance and financing are well covered. In Rwanda, the regulation of health insurance is under the Ministry of Social Security, emphasizing the government’s commitment to universal access and public health outcomes.
Current regulatory status of Medical aid societies in Zimbabwe
In Zimbabwe, the current status is that medical aid societies or health insurance companies are regulated under the Medical Services Act Chapter 15:13 through SI 330 of 2000 by the Minister of Health and Child Care through the Permanent Secretary. This regulatory framework has its strengths and weaknesses, with the strengths being alignment with national health policy, public health priorities, and the technical capacity of health and related professionals within the Ministry familiar with the intricate medical ecosystem. However, the weaknesses include limited oversight and enforcement capacity for such a huge and complicated industry, inadequate transparency and accountability on both parties – regulator, medical aid societies and health service providers, perceived influence of some powerful medical aid societies and occasional conflict of interest due to overlapping roles within the Ministry of Health.
Why Medical aid societies should not be regulated by IPEC
The recent and ongoing developments necessitated this opinion piece. The Insurance and Pensions Commission (IPEC) Amendment Bill, 2024, was gazetted on December 20, 2024 and proposes significant amendments to the Insurance and Pensions Commission Act [Chapter 24:21]. The amendments have far-reaching implications for medical aid societies, which will now fall under IPEC’s regulatory scope under the bill if it is signed in to law. This proposed bill drew mixed reactions from various sectors including public with varying reports in the media both in support and against the proposed bill. The different views are expressed in The Herald dated 27 December 2024, Newsday dated 7 February 2025, The Herald dated 25 February 2025, The Sunday News dated 25 March 2025, The Sunday mail dated 24 March 2025, Newsday dated 24 January 2025 and The Chronicle dated 22 March 2025. It is a contested position on whether IPEC should be the ideal regulator or there should be a specific health industry aligned body for medical aid societies considering the delicate and complexity nature of this important industry.
Healthcare as a merit and public good
It is the author’s respected view that IPEC will not be the best organisation or body to regulate the medical aid industry because of a number of reasons based on research evidence base, author’s more than decade experience in the medical aid industry and case studies of other countries. Research and international literature show that health and healthcare sector is uniquely different from other sectors and commodities hence should be treated separately and with great caution. Williams and Culver (2023) writing in the Cambridge University press argued that healthcare cannot be treated like ordinary commodities due to its unique characteristics, such as the unpredictability of the sector and the essential nature of services provided by the sector to the public. Smith (2018) cautioned against viewing healthcare as an ordinary commodity as it leads to compromising the patient-provider relationship and recommended a more holistic approach that values the human aspects of care.
Pavlakis and Roach (2021) also argued against categorising health as a privilege or commodity but recommended a more holistic approach that considers ethical, economic, and social dimensions.Romanow (2003) in his study looking at the implications of treating healthcare as a commodity, argued that this can lead to inequalities in access and quality of care, and recommended that health regulation and policies should prioritise public health objectives over business, profits and market interests. Auld (2012) of the University of Victoria in Australia highlighted the economic implications and challenges of treating healthcare as an ordinary commodity due to factors such as moral hazard, information asymmetry and externalities and recommended that governments should intervene to address these challenges in the interest of the population health.
According to Musgrove (2004) writing for World Bank argued that healthcare is a “merit good” which society believes everyone should have access to it regardless of ability or willingness to pay and also in support, the World Health Organisation (2015) documented that health is considered a public good because one individual’s consumption does not reduce availability for others. According to Frameworks Institute UK (2022), regulation of health differs from other commodities primarily because of the unique characteristics of healthcare, including its impact on life and death and this is also supported by Christiansen (2017) and Lancet (1997). Other important aspects that distinguish health from other commodities includes the involvement of multiple stakeholders with different incentives and vested interests, political economy, information asymmetry and potential for moral hazard. Government has vested interests, a role to ensure access to health under section 79 of the constitution and this distinguishes health care from other commodities that are primarily governed by market forces.
Furthermore, it is the author’s view that regulation of health and health insurance fundamentally differs from the regulation of other commodities and financial instruments and IPEC, while is an experienced and respected regulator in pensions, short-term insurance, and long-term insurance products however, it lacks the necessary technical expertise for the healthcare sector, medical tariffs, risk pooling in healthcare, and health outcomes analysis. In addition, health insurance involves nuanced issues such as medical ethics, provider payment systems, health provider relations and dynamics, patient rights, understanding disease burden trends, key medical procedures and the economics of health systems. These intricacies require oversight by professionals trained in health systems, epidemiology, clinical practice, health policy, and health financing and not just actuarial or financial oversight.
Health as a Right and the Need for Universal Health Coverage
Section 76 of the Constitution of Zimbabwe affirms that every citizen and permanent resident has the right to access basic healthcare services. This foundational right cannot be protected or realized through a purely financial or business-oriented regulatory lens that comes with IPEC. In addition, Zimbabwe, like many nations, has committed to achieving Universal Health Coverage (UHC), a goal that aims to ensure everyone has access to quality healthcare services without financial hardship and this is also reflected in the NDS 1 including initiatives to improve health coverage, with the aim of “leaving no one behind” in healthcare. Health is also deeply interlinked with most of the United Nations Sustainable Development Goals (SDGs), especially SDG 3 Good health and wellbeing. It is imperative that a regulatory for the medical aid industry must be equipped to manage this intersection between rights, ethics, and policy—not just finance and compliance.
Medical and or Health industry expertise and the role of Health professionals and experts
It is evidence that the medical aid industry requires special medical and health expertise with almost all medical aid societies and the membership body AHFoZ key operational functions such as claims adjudication, tariff setting and negotiation, managed care, risk management and fraud detection are handled by professionals with health backgrounds mainly doctors and nurses. In addition, negotiating and setting medical tariffs requires an understanding of complex and technical medical procedures and terminologies, provider incentives, health system costs, and context specific reimbursement models. Against this background, the author is contented that the regulator for the industry must reflect this same expertise to effectively engage with the unique, complicated and delicate sector and protect consumer (patients) rights. Placing this important and critical mandate under a body unfamiliar with these dynamics risks harming both service providers and beneficiaries.
The planned introduction of the National Health Insurance in Zimbabwe
Another critical aspect to consider is the advanced plan by the Government of Zimbabwe to introduce a National Health Insurance (NHI) scheme as part of broader reforms to achieve Universal Health Coverage (UHC). With this noble plan, placing the regulation of medical aid societies under IPEC, whose primary mandate is general insurance and financial oversight and not health system stewardship will create a structural misalignment for the sector and industry. It is the author’s view that regulation of medical aid societies or private health insurance companies needs to complement, not conflict with, the architecture of the NHI. It is imperative that an independent, health-focused regulatory authority or body would provide the ideal regulatory oversight and home for both private medical aid societies and the NHI, allowing for policy coherence, health stakeholder coordination, and aligned benefit structures. Having a health related regulator overseeing both the medical aid societies and the NHI, would enable it to effectively oversee risk equalisation, harmonise medical tariffs, ensure portability of benefits, and prevent fragmentation of the health financing system.
Recommendations
The author recommends that Zimbabwe should establish an independent statutory body or authority for regulating Medical aid or health insurance companies and this body should comprise skilled professionals from health, finance, law, health economics, public health and health policy fields. The body should be under and aligned with the Ministry of Health and Child Care to ensure that UHC, ethics, and the public interest are prioritised. The body should be able to balance business viability with member protection, provider fairness, fiduciary oversight and alignment with the country national health goals. The body can copy, customize and benchmarks itself against regional best practices such as Council for Medical Schemes in South Africa.
Conclusion
In wrapping up, the regulation of medical aid societies in Zimbabwe must not be reduced to a matter of finance and compliance. The regulation of the sector should reflect access to health as a fundamental basic human right provided for everyone under section 79 of the Constitution of Zimbabwe and also the critical role played by healthcare in national development. The regulation of the sector should be grounded in ethics and equity, and support Zimbabwe’s broader health, human rights and development agenda. The health sector requires a dedicated regulatory body and approach grounded in ethics, good governance, health economics, and universal access and not one modeled after business and financial products alone. A specialized, specially constituted and multidisciplinary regulatory body is essential for safeguarding the health rights of Zimbabweans while ensuring the effective oversight and sustainability of the medical aid sector.
What do you think? Should IPEC regulate medical aid societies or should Zimbabwe develop a dedicated medical aid / health insurance regulatory body? Join the conversation and share your thoughts.
Author’s profile
Enock Musungwini is an award-winning and seasoned public health and policy specialist, Health management consultant, and development practitioner with interests in health policy and financing. He is a PhD in Public Health (Health Policy and Financing) candidate with UNICAF University and holds an MSc in Public Health (MPH) with a research award from the prestigious London School of Hygiene and Tropical Medicine in the UK. He also holds a Master’s in Business Administration from Midlands State University, a BSc Hons in Psychology, a Diploma in Nursing, and several additional qualifications. Enock has received more than 6 awards for academic and professional excellence and is actively engaged in several regional and international professional networks, including as Reference Committee member - Africa Evidence Network (South Africa), Steering Committee member - International Network for Government Science Advice Africa Chapter, Global Coordinator - Healthcare Information for All (UK), Committee member - Climate Sensitive Infectious Diseases Network, and as an Alumni Ambassador for LSHTM. For further inquiries and engagements, Enock can be contacted via email at: emusungwini@yahoo.co.uk Disclaimer: While the author acknowledges and references articles from other organisations and individuals, the views expressed in this opinion piece, as well as any errors or omissions, are the sole responsibility of the author.
