HPCSA TARIFF GUIDELINES Perspectives of the South African Dental Association 22 August 2012

SADA and Oral Health in South Africa CONTEXTUALISATION SADA and Oral Health in South Africa SADA representative of 80% of dentists in SA R2 billion industry Private practice employs 10 000 – 15 000 people in SA 40% exit ratio from the profession High incidence of depression Oral health perceived as not life-threatening and therefore not a funding priority Exceptionally low acknowledgement (patients, statutory, funders) about high input costs in private practice Medical schemes contributions reduction – from 8.4% to 2.4% Low access and low consumer awareness Brain drain high

Scenarios for Dentistry in South Africa 10% 2% 3% 85%

WHY DOES ORAL HEALTH MATTER? Oral Health and the Burden of Disease Oral health is an essential component of general health HIV/AIDS: Oral manifestations often facilitate diagnosis and identification of individuals who may be HIV positive Non-communicable diseases: Dental caries recognised as a major non-communicable disease (FDI, WHO, UN) Growing evidence of association between periodontal disease and diabetes, heart disease, strokes and respiratory ailments. Oral cancer (affecting younger population, poor prognosis) Injury and violence: most physical injuries resulting from family violence are found on the face, head, neck and oral areas that are clearly visible to the dental team during examinations

CONCERNS WITH THE HPCSA TARIFF GUIDELINES Not within the mandate of the HPCSA to publish a tariff Ultra vires section 53 of the HPA (fees referred to in Sec 53(3)(d) are not a tariff for supply of professional services by healthcare professionals and cannot be used as a basis for determination of any tariff; Contravenes the provisions of the Competitions Act (represents a fee that should be charged in order to be accepted by medical schemes, thus facilitating convergence) Procedural concerns No meaningful engagement – limiting right to fair administrative justice as per Sec 33 of Constitution and Sec 3 of Promotion of Administrative Justice Act;

CONCERNS WITH THE HPCSA TARIFF GUIDELINES Flawed basis for preparation of the guidelines Not reflective of any reasonable cost - based on a the 2006 RPL, which related to medical scheme benefits and not to professional fees;  30-40% less than approved professional fees in 2006 Inflated by CPI (refer exchange rate fluctuations and increases in utilities); materials included in codes and therefore increasingly skew The 2006 list is 6 years old in terms of procedures and technology. Affecting dignity of the professional and patient

RECOMMENDATIONS Immediate withdrawal of the HPCSA tariff guidelines (incl website) Immediate implementation of a cost study through a process approved by all stakeholders Recognition of the specific challenges in dentistry and constructive engagement with the profession to address risks

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