Year 2015 - The New Challenges of Insurance Regulatory Reform 保險業新規管 帶來的新機遇

6. Coverage of hospitalization and prescribed ambulatory procedures Yes, support 7. Coverage of prescribed advanced diagnostic imaging tests and non-surgical cancer treatments Yes, support 8. Minimum benefit limits Yes, support 9. Cost- sharing (deductible and /or co-insurance) restrictions - Only applicable to VHIS Standard Plan. - No, should have free market and consumers choices outside the VHIS Standard Plan 10. Budget Certainty - Yes, support. - Should include regulation of Healthcare Service Provider on DRG & standardized codes 11. Standardized policy terms and conditions Yes, support 12. Premium transparency Yes, support C. Coverage of pre-existing conditions This requirement is only desirable in the compulsory insurance environment but unnecessary in voluntary insurance environment. i. Some really high risk conditions should be funded by the Government Public Health System instead of the private insurance pool, e.g. rare congenital diseases e.g. metabolic diseases involving experimental drug, HIV, mental disease, and Notifiable Infectious Diseases like plague, SARS. Such requirement is applicable only within the VHIS Standard Plan, because there is a High Risk Pool (“HRP”) fully funded by the Government out of the HK$4.3 billion for any policyholders with pre-existing illness beyond 200% premium loading. It will be too costly for consumers to share the premium cost to support exceptional high risks outside the VHIS Standard Plan. ii. The fundamental basic of insurance is the numbering exercise of pooling all the claim cost to be shared by the policyholders within any insuring pool. The HRP fund is only subsidizing the high risks (over 200% premium loading) within the VHIS only. Most of the middle class will not be interested to buy VHIS and will arrange their own choice of higher limit of hospital insurance. Since in future any hospital insurance above the limit of the Standard Plan will have to cover all pre-existing illness with no exclusion, (but they are not funded by the Government HRP), the consequence is that it will drive up premium cost of private insurance pools. It will be too expensive to be shared by private insurance policyholders outside the VHIS. There is a myth that the Government proposal should look after the poor and needy, while the middle class have resources to look after themselves. This does not reflect reality, because most middle class people depend on their salaries and will lose the large portion of their income after retirement or when they become sick and cannot continue working. As middle class people do not normally qualify for Comprehensive Social Security Assistance, they could, under the current proposal, be left out and have to fend for themselves with no support, no money and no health coverage when they fall into hard times. We find that this is very UNFAIR to most of the middle class who are mostly tax payers throughout their working lives. This will become an issue of UNAFFORDABILITY to most of our middle class. iii. It is expected that after the launch of VHIS, not many insurance companies will offer competitive hospital plans in the market. Insurance companies are not charitable organizations and they will not subsidize policyholders to cover all the high risks. Alternatively, some insurance companies may choose to stay away from offering compliant hospital insurances. Hence it will become other issues of UNAVAILABILITY & UNACCESSIBILITY. 23