Submission to Health Insurance Authority on Minimum Benefit Regulations

The Society has responded to a consultation paper from the Health Insurance Authority on “Minimum Benefit Regulations in the Irish Private Health Insurance Market”.

We proposed that the services covered by the Minimum Benefit Regulations should be all services arising from medically necessary treatment carried out in a hospital setting (including associated drug costs, whether administered in hospital or in a primary care setting).  Insurers should be allowed to encourage primary care treatment where this substitutes for treatment in a hospital setting, and will be incentivised to do so if primary care treatment comes at a lower cost. However, the Regulations should not require them to do so (except in respect of associated drug costs, as indicated above), because this would bring benefits currently not covered by most health insurance policies into all policies. This would have inflationary consequences for insurance premiums, potentially leading to affordability issues, cancellation of policies (particularly by healthy people, creating further inflationary pressure) and difficulty in attracting young people into the insurance pool.

Minimum payment levels should be set equal to the “lowest market cost” for the relevant treatments. Insurers would determine “lowest market cost” for a hospital treatment based on the participating hospitals and consultants relevant to the insurer. Provision should be made for the Authority, or another appropriate body, to adjudicate in the event of dispute as to whether an insurer’s provider network facilitates access to the full spectrum of treatments within reasonable geographic reach of insured persons.

Read the Authority’s paper 

Read the Society’s submission