By Enock Musungwini, MPH; MBA
The recent article published by the Association of Healthcare Funders of Zimbabwe titled “Healthcare funders push back, warn 80% of Private Healthcare funding at risk in IPEC Takeover” raises important and timely concerns about the future of medical aid regulation in Zimbabwe. The sector, valued at nearly US$400 million annually, covering approximately 10% of the population and contributing about 30% of total health expenditure, remains central to the country’s healthcare financing architecture.
The concerns raised by AHFoZ particularly regarding the risks of placing medical aid societies under a purely financial regulator such as the Insurance and Pensions Commission are valid and evidence-informed. As argued in my earlier publication, “Why medical aid societies in Zimbabwe should be regulated by a Health-focused authority or body Not IPEC” (Health Times, 22 April 2025), healthcare financing is fundamentally different from conventional insurance due to its ethical, clinical, and public health dimensions. However, while I largely agree with AHFoZ’s position opposing the transfer of regulatory oversight to IPEC, I respectfully submit that maintaining the status quo under the Ministry of Health and Child Care without structural reform is equally problematic and cannot remain unchallenged.
Where AHFoZ is Right: Health is not an ordinary commodity
AHFoZ is correct in asserting that medical aid is not merely a financial product—it is a vehicle for ensuring access to healthcare, improving patient outcomes, and sustaining service delivery systems. Global literature strongly supports this position. The Lancet 1997 paper papers explicitly asserted that “health care is not a commodity” highlighting that healthcare cannot be subjected to purely market-driven regulatory approaches and this is also supported by Plakis and Roche (2021) and Klunky (2022). Healthcare differs fundamentally due to its life-and-death implications, information asymmetry between providers and patients, the presence of moral hazard and externalities and its ethical foundation as a public and merit good.
Scholarly and policy literature consistently argues that treating healthcare as a standard market commodity risks inequities in access, compromised quality of care, and weakened patient-provider relationships (Brevis & Wiist, 2021). Health systems require regulation that balances economic sustainability with ethical obligations and population health outcomes. Furthermore, the World Health Organization emphasises that achieving Universal Health Coverage requires systems that ensure all individuals access needed services without financial hardship (WHO, 2025). This cannot be achieved through regulatory models that prioritise financial compliance over health outcomes.
Against this background, placing medical aid societies under IPEC risks reducing healthcare financing to actuarial and financial metrics, weakening clinical and public health considerations and undermining alignment with UHC and national health priorities.
Where AHFoZ falls short: The limits of the current Ministry of Health-led regulatory model
While AHFoZ advocates for retaining regulation within the Ministry of Health, this position does not sufficiently interrogate the systemic weaknesses of the current framework. The existing arrangement is characterised by limited regulatory enforcement capacity, fragmented accountability systems, overlapping institutional roles creating conflicts of interest and weak transparency and governance mechanisms. From a policy analysis perspective, these challenges reflect elements of the Regulatory capture theory, first articulated by George J. Stigler which posits that regulators may become aligned with the interests of the industries they regulate (Stigler,1971). In Zimbabwe’s health sector, the close interdependence between policymakers, health providers, and funders heightens this risk. As a result, the issue is not merely about who regulates, but how regulation is structured and governed.
Correcting the South Africa analogy: Understanding the Council for Medical Schemes model
AHFoZ references South Africa as a model where medical aid is regulated under the Ministry of Health through the Council for Medical Schemes. While technically accurate, this comparison is often misunderstood. The Council for Medical Schemes is a statutory, autonomous body established by legislation and governed by an independent board. CMS is equipped with a fully functional secretariat and specialised expertise, it is mandated with strong enforcement powers and operationally independent, though accountable to the Minister of Health. In Zimbabwe, the CMS model is institutionally comparable to Zimbabwean entities such as the Medicines Control Authority of Zimbabwe and Health Professions Authority of Zimbabwe as these are semi-autonomous regulatory bodies, not direct administrative departments within the Ministry of Health. Therefore, the South African CMS model supports not contradicts the argument for an independent regulatory authority, rather than the continuation of the current Ministry of Health-led structure.
The way forward: An independent and multidisciplinary regulatory body
The current policy debate is incorrectly framed as a binary choice between IPEC and the Ministry of Health status quo. This framing fails to address the structural governance gap. Zimbabwe requires a third, more strategic solution in form of an independent, Health-focused, Multidisciplinary regulatory authority. Such a body should be statutorily established and semi-autonomous, created through legislation, accountable to Parliament and operationally independent. Secondly, it should possess a multidisciplinary skills mix made up of public health and epidemiology experts, health economists and actuaries, legal and governance specialists, and clinical professionals. Thirdly, the body should have balanced representation with Government, medical aid societies, healthcare providers, civil society and patient advocates and independent experts.
Furthermore, the body should be able to address the regulatory capture risks with independent board composition, strict conflict-of-interest safeguards and transparent governance systems. Should have strong enforcement capacity, licensing and accreditation powers, tariff and pricing oversight, dispute resolution mechanisms, compliance enforcement with sanctions and strategic alignment with Universal Health Coverage, Government NDS 2 and other national reforms. Another perspective is that Zimbabwe’s transition toward the planned National Health Insurance (NHI) requires regulatory coherence across public and private financing systems because a fragmented regulatory approach will undermine efficiency and equity. In this context, a unified, health-focused regulatory authority would align private medical aid with the country’s UHC goals, facilitate risk pooling and cross-subsidisation, harmonise benefit structures and strengthen system-wide governance and accountability.
Conclusion: Reform is urgent, not optional
It is the author strong conviction that the concerns raised by AHFoZ regarding IPEC regulation are legitimate and evidence-based. However, maintaining the current Ministry-led regulatory framework without reform is equally untenable. Zimbabwe’s medical aid sector covering millions and financing a significant share of healthcare requires a regulatory model that is technically competent, institutionally independent, ethically grounded and aligned with national and global health priorities. To some extent, yes medical aid societies should not be regulated by IPEC but equally, the current status quo cannot be allowed to persist. The optimal path forward is the establishment of a robust, autonomous, health-focused regulatory authority capable of safeguarding both the sustainability of the sector and the health rights of Zimbabweans in line with section 79 of the Zimbabwe constitution.
About the author:
Enock Musungwini is an award-winning public health practitioner and policy specialist, health management consultant, and development practitioner with over a decade of experience in health policy, health systems strengthening and medical aid. He is a PhD candidate in Public Health (Health Policy and Financing) with UNICAF University and holds an MSc in Public Health from the London School of Hygiene and Tropical Medicine (LSHTM), UK, where he received the Amanda Jacklyn Berger prize his MSc Thesis.
He also holds an Masters in Business Administration from Midlands State University, a BSc Honours in Psychology, and a Diploma in Nursing. Enock has received multiple awards, including the Africa Evidence Leadership Award (Evidence Use Category) and the Zimbabwe Achievers Global Award (Public Health Leadership and Advocacy). He is a member and also serves on several regional and international bodies Climate Sensitive Infectious Diseases Network, the American Society of Tropical Medicine and Hygiene, the Royal Society for Public Health and the UK Faculty of Public Health. He is also a Chevening Alumni.
Disclaimer: The views expressed in this article are those of the author and do not necessarily reflect those of any affiliated institutions.
