The attached regulations at long last defining the scope of dentistry.  This means that all beauticians, cosmetic establishments etc offering aesthetic dental treatment can now be be reported immediately to Registrar/CEO, HPCSA, P O Box 205, Pretoria 0001, for investigation.

SOUTH AFRICAN DENTISTS RESPOND TO STATEMENTS BY THE HEALTH PROFESSIONS COUNCIL

The press has widely reported a statement by the Registrar of the Health Professions Council of South Africa, originally issued on 26 November 2008 and recently re-released,  regarding the ”Scrapping of  ethical tariffs” and the intention of Council to use the National Reference Price List to determine maximum ethical tariffs.

There are four key issues that need to be understood by the public.
These are “informed consent”, the “National Reference Price List” (NRPL), the “medical aid rate” and “ethical fees”.

The South African Dental Association fully supports the concept of informed consent. It is the patient’s right to be informed what the cost of any service will be and to consent to that charge before proceeding with treatment. It is the service provider’s ethical duty to give the patient a cost estimate for any procedure but the onus is also on the consumer to request a quote, ideally in writing, and, if you rely on third party funding, to submit this to your funder before proceeding with treatment so that you may ascertain what portion will be funded, enabling you to budget for the balance, if any. Patients must bear in mind that, depending on clinical circumstances, treatment options may sometimes have to be changed during the course of treatment so, unlike when one gets a quote for, say an electrical appliance, the service provider may only provide an educated cost estimate which should not be a legally enforceable quote if additional procedures become necessary.

What is the National Reference Price List? (nrpl)
There is a common misconception that the NRPL is a list of tariffs that must be charged by medical service providers, whereas it is in reality  a list of reference prices used by medical schemes to determine benefits for their members. The preamble to the NRPL states clearly that it is “not a set of tariffs that must be applied by medical schemes and/or providers. It is rather intended to serve as a baseline against which medical schemes can individually determine benefit levels and health service providers can individually determine fees charged to patients.” Although many administrators use the exact prices published in the NRPL, a significant number individually set benefits that may be higher or lower than the NRPL prices and that may even vary for different benefit options within the same medical aid scheme.
Consequently there is no such thing as the ‘medical scheme rate’, to which the Registrar refers.

The Health Professions Council of S A is rightfully charged with the responsibility of protecting the interests of the public and guiding the professions on all ethical aspects of treatment in the medical and paramedical fields, including the cost of treatment.
The South African Dental Association, however, believes that an ethical tariff bears no relationship whatsoever to the NRPL which is merely a reference price for services and nothing more. In any event, the process of price determination by the Department of Health is far from complete for many service categories, including dentistry so it is erroneous for the Council to base any ethical judgements on the NRPL at this time, if at all!  Even when the Department of Health does complete its “extensive consultation with stakeholders”, their process will reflect only the average price, for an average procedure, for the average patient, under average circumstances and according to average practice costs.

The decision of the HPCSA to make ethical determinations, based on the NHRPL, is therefore without foundation. It is the right of a practitioner to charge a tariff that is commensurate with his or her level of expertise and experience, the complexity of a procedure, the use of sophisticated technology and the circumstances in which it is provided irrespective of the patient’s medical insurance status.

Dr S Erasmus
President
SOUTH AFRICAN DENTAL ASSOCIATION