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Healthcare for Whom?

Unpacking the LCBO Divide in South Africa

Blogs, Analytics April 5, 2025
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Bridging the Gap or Widening the Cracks? South Africa's Contentious Low-Cost Medical Aid Debate

The struggle for affordable, quality healthcare in South Africa is a story etched onto the faces of millions. Countless families find themselves in the precarious "missing middle" – earning too much to rely solely on strained public facilities, yet not enough to afford the ever-increasing premiums of traditional medical schemes. For years, the industry and regulators have grappled with this dilemma, searching for a viable way to extend private healthcare cover to lower-income earners. The proposed solution, known as Low-Cost Benefit Options (LCBOs), has become the focal point of intense debate, culminating recently in a significant pushback from the official regulator, the Council for Medical Schemes (CMS).


In its comprehensive October 2023 report, the CMS effectively poured cold water on the industry-led proposals for LCBOs as they currently stand. Their rationale, meticulously laid out, stems from a deep concern that the proposed cure might be worse than the disease.


The Regulator's Red Flags

From the CMS's perspective, the LCBO proposals, developed through extensive industry consultation since 2020, fall short on several fundamental principles. The watchdog argues that the suggested benefit packages, primarily focused on basic primary care while seeking exemption from Prescribed Minimum Benefits (PMBs) and excluding hospitalisation, are simply not robust enough.


Their core objections can be summarised as follows:

  • Insufficient Cover: The CMS believes the proposed packages don't adequately address South Africa's complex burden of disease, leaving beneficiaries vulnerable when serious illness strikes. Critical areas like comprehensive maternity care and mental health services are notably weak or absent in the proposals.
  • Undermining Solidarity: Medical schemes in South Africa are built on pillars of social solidarity – open enrolment (accepting all applicants) and community rating (charging the same premium regardless of health status). PMBs are a cornerstone of this, guaranteeing a baseline level of care for all members. The CMS fears that LCBOs, by carving out these protections, would create a two-tiered system within medical schemes, fundamentally eroding these principles.
  • Financial Risk: Far from protecting members, the CMS fears these limited packages could increase out-of-pocket expenses when members inevitably need care beyond the basic offering. This offers little genuine financial protection, particularly for low-income households.
  • No Guaranteed Public Sector Relief: The argument that LCBOs will ease the burden on public hospitals is questioned, especially as the proposals explicitly exclude private hospital cover, meaning members would likely still rely on state facilities for admissions.
  • NHI Conflict: With National Health Insurance (NHI) looming – aiming for universal, equitable access – the CMS sees the introduction of these limited, potentially inequitable options as running counter to the national health policy direction.
  • Legal Labyrinth: Implementing LCBOs as proposed would necessitate complex and potentially unworkable legislative amendments to the Medical Schemes Act or rely on legally dubious perpetual exemptions.

Instead of approving LCBOs, the CMS recommends a phase-out of the primary health insurance products currently operating under temporary demarcation exemptions, arguing their continued existence is legally questionable and undermines the regulated medical schemes environment.


Industry's Plea: "Something is Better Than Nothing"

However, this regulatory stance clashes sharply with the perspective of a significant portion of the healthcare funding industry, most vocally represented by the Board of Healthcare Funders (BHF). For years, the BHF and many of its members (medical schemes and administrators) have passionately advocated for LCBOs.


Their argument rests heavily on the undeniable affordability crisis. They contend that for millions, the choice isn't between a comprehensive medical scheme plan and an LCBO; it's between an LCBO and nothing beyond the public sector. The industry sees LCBOs as the only practical mechanism to:

  • Expand Access: Bring desperately needed private primary care access to employed but lower-income South Africans currently shut out of the market.
  • Stimulate Growth: Inject growth into a stagnant medical schemes market, which has seen beneficiary numbers flatline for years.
  • Offer Choice: Provide a stepping stone into private cover, potentially allowing members to upgrade as their circumstances improve.
  • Compete Fairly: Allow regulated medical schemes to compete with the exempted insurance products that already target this market, albeit with concerns about the value they offer.

"Finding a path forward requires more than just regulatory directives or industry lobbying. It demands a courageous, collaborative effort to design solutions that are both genuinely affordable and meaningfully adequate, aligning with the constitutional right to healthcare access. "


The Great Divide: What Now for SA Healthcare?

This fundamental disagreement between the regulator and major industry players creates significant uncertainty. The CMS's rejection, grounded in protecting legislative principles and benefit adequacy, clashes with the industry's push for market expansion and pragmatic affordability solutions. ​ This divergence signals several critical challenges:

  • Regulatory Stalemate: Progress towards a solution for the "missing middle" is stalled, leaving millions in limbo.
  • Market Dynamics: Medical schemes face continued pressure in a saturated top-end market, while the lower-income segment remains largely untapped by regulated entities.
  • Future of Exempted Products: The CMS wants them gone, but without an approved LCBO alternative within schemes, the political and practical path to phasing them out becomes more complex, potentially leaving current policyholders without cover.
  • NHI Integration: This conflict complicates the already intricate task of integrating the private sector into the future NHI framework. How can a fragmented private sector, potentially with multiple tiers of cover, align with a universal system?

  • Ultimately, South Africa stands at a healthcare crossroads. Does it hold firm to the comprehensive principles of the Medical Schemes Act, potentially leaving millions without affordable private cover? Or does it permit lower-cost, less comprehensive options, risking the dilution of benefits and the erosion of social solidarity?


    Finding a path forward requires more than just regulatory directives or industry lobbying. It demands a courageous, collaborative effort to design solutions that are both genuinely affordable and meaningfully adequate, aligning with the constitutional right to healthcare access and the transformative goals of NHI. Until then, the gap remains, and for many South Africans, quality healthcare feels frustratingly out of reach.