Zimbabwe’s proposed amendments to Statutory Instrument 330 of 2000 present a difficult policy choice: how can the country strengthen oversight of the healthcare sector without undermining the investment, infrastructure and partnerships needed to expand access to treatment?

The question is especially important in light of recent statements by Health and Child Care Minister Dr Douglas Mombeshora, who has called simultaneously for greater innovation and private-sector participation, and for stronger discipline and accountability across the health system.

Taken together, his remarks offer a sound principle for the SI 330 debate: healthcare must remain open to investment and innovation, but no participant should be beyond scrutiny.

The proposed restrictions on medical aid societies owning, managing or operating healthcare facilities — including hospitals, clinics, pharmacies and laboratories — are rooted in concerns about conflicts of interest, market power, pricing, referral arrangements and accountability.

Those concerns cannot be dismissed. But neither should they be used to justify a blanket prohibition without a clear assessment of its consequences.

A measure intended to protect patients could discourage investment, destabilise existing facilities, disrupt employment, reduce access to specialist services and add pressure to an already stretched public health system.

Zimbabwe needs more healthcare capacity. It must therefore be careful not to dismantle existing infrastructure before alternative capacity is secured.

Mombeshora’s message on innovation

At the recently held Cimas Healthathon 3.0 grand finale in Harare, Mombeshora placed innovation and collaboration at the centre of healthcare transformation.

In a speech read on his behalf, he said:

“Innovation is not only about technology or software. It is about doing things differently and better.”

He then offered a test that should be applied to every proposed healthcare reform:

“The measure of any innovation is simple: does it improve a patient’s experience, reduce the cost of care, help a health worker do their job better, or reach someone who has been left behind?”

That test raises important questions about SI 330.

Will the proposed restrictions improve the patient experience? Will they lower the cost of treatment? Will they expand access to specialist care? Will they help reach rural communities, low-income households, older people and persons with disabilities?

If those outcomes cannot be demonstrated, the reform requires more rigorous assessment.

Mombeshora also acknowledged that Government cannot transform healthcare alone.

“Government sets policy, provides public health leadership and regulates the sector. But Government cannot, and should not, work alone.”

He called on private players to invest, build and participate more boldly.

That appeal is consistent with Zimbabwe’s urgent healthcare needs. The country requires investment in hospitals, clinics, laboratories, pharmacies, diagnostic centres, specialist services, modern equipment and digital systems.

A regulatory framework that creates uncertainty around existing investments or discourages new projects could undermine the expansion the minister is seeking.

The case for targeted regulation

Mombeshora’s second recent intervention focused on discipline, corruption and the protection of public resources.

He warned:

“Duty before personal interest. Patient before profit. Public resources for public service.”

He added:

“Public facilities are public assets. Public equipment is public equipment. Public medicines are public resources.”

And he stressed:

“A patient who comes to a public health institution must never be treated as an opportunity for personal enrichment.”

Those principles should inform the entire healthcare sector. Patients must come before institutional self-interest, commercial gain and private enrichment.

However, accountability must be directed at actual misconduct rather than assumed from ownership.

A medical aid society’s involvement in a healthcare facility is not, by itself, proof of abuse. The relevant questions are whether related-party transactions are disclosed, procurement is transparent, referrals are clinically justified, patients have meaningful choices, tariffs are properly explained and clinical decisions remain independent of commercial pressure.

Where wrongdoing is established, it should attract meaningful penalties.

Government can strengthen oversight through independent governance requirements, audited financial reporting, disclosure of related-party interests, transparent procurement, separation of clinical and financial decision-making, independent referral and complaints mechanisms, and stronger competition and consumer protection.

The objective should be clear: regulate harmful conduct without destroying functioning healthcare capacity.

Tariffs need evidence-based resolution

The SI 330 controversy also reflects a wider problem in the healthcare sector: persistent disputes over tariffs, co-payments, delayed settlements and service costs.

These disagreements do not remain confined to medical aid societies and healthcare providers. Patients ultimately bear the consequences through higher out-of-pocket expenses, delayed treatment, restricted services and uncertainty over medical aid cover.

Mombeshora captured the necessary spirit of cooperation when he said:

“Doctors and medical aids are not adversaries. You are partners serving the very same patient.”

That principle should guide the proposed National Tariffs Liaison Committee.

The committee should provide a practical and technically credible platform for Government, medical aid societies, healthcare providers, professional bodies, actuaries, economists and patient representatives to resolve disputes.

Tariffs should be determined through transparent, evidence-based costing. They must reflect the real cost of delivering safe, quality and sustainable care, while taking account of affordability and geographic differences.

A tariff is not sustainable simply because it is imposed. It must also enable providers to maintain facilities, retain skilled personnel, replace equipment and preserve service quality.

A credible tariff mechanism could help resolve commercial disputes before they escalate into broader conflicts over contracting, ownership and access.

Parliament must demand evidence

With SI 330 now before Parliament, lawmakers should insist on a full assessment of the proposed restrictions before endorsing any blanket approach.

The assessment should examine the likely effects on existing facilities, investment, employment, specialist services, patient choice, tariffs, co-payments, rural access and the public health system’s ability to absorb displaced demand.

It should also determine whether targeted safeguards could address identified risks more effectively than prohibition.

If structural changes are necessary, they should be phased and accompanied by clear transitional arrangements. No functioning healthcare facility should be dismantled on the promise of replacement capacity that does not yet exist.

President Emmerson Mnangagwa’s recent call for barriers to the establishment of specialist healthcare facilities and services to be removed adds an important test of policy consistency.

If Government wants more specialist facilities and greater private investment, it must explain how a blanket restriction on existing integrated healthcare models would advance that objective.

Private healthcare must be regulated. But regulation must also be predictable, proportionate, transparent and aligned with the national goal of expanding access to quality care.

The patient must remain the measure of reform

Mombeshora’s recent statements point towards the balance Zimbabwe needs.

His call for innovation, investment and private-sector participation must be matched by his insistence on discipline, accountability and the protection of public resources.

These are not competing priorities. They are the foundations of a credible healthcare system.

The SI 330 process should protect patients from abuse, preserve existing capacity, encourage investment, regulate conflicts of interest through targeted safeguards and resolve tariff disputes through transparent, evidence-based mechanisms.

Its success should not be measured by how ownership is redistributed, but by whether patients receive better, more affordable and more accessible care.

Zimbabwe should punish abuse and demand transparency. But it should not weaken the healthcare infrastructure on which patients already depend.

The country needs reform that strengthens the health system, not a regulatory response that leaves patients paying for its unintended consequences.