In furtherance of this goal, a national health insurance scheme, accessible to all citizens, residents and visitors, is in the process of being implemented in five phases (the Health Insurance Scheme). Phase 1 of the Health Insurance Scheme was launched in July 2013, followed by phase 2 in April 2014.  At the launch of phase 2 the Health Insurance Scheme was renamed 'Seha', meaning 'health' in Arabic (Seha).  Seha was enacted through issuance of Law No 7 of 2013 concerning the Social Health Insurance Scheme (the Health Insurance Law). Seha is regulated pursuant to Resolution No 22 of 2013 of the Minister of Public Health Issuing the Implementing Regulations for Law No 7 of 2013 concerning the Social Health Insurance Scheme (the Regulations).

Article 5 of the Health Insurance Law tasks the Supreme Council of Health (the SCH) with the responsibility, supervision and development of Seha.  Separately, Article 19 of the Health Insurance Law tasks the National Health Insurance Company (the NHIC) with the "actual implementation and management" of Seha. The NHIC (http://www.nhic.qa) is a fully owned government entity with a board of directors formed of representatives of the SCH, Ministry of Finance, Ministry of Labour and Social Affairs, Ministry of Interior, Central Municipality Council and two members from the private business sector. The NHIC's powers are set out in Article 20 of the Health Insurance Law and the Regulations.

The NHIC has appointed Al Khaleej Takaful as its third party administrator to handle essential administrative processes and support building its capabilities. Aetna and GlobeMed have been appointed as exclusive subcontractors of the third party administrator.

Implementation

Seha is to be rolled out in five phases up to 2015 as follows:

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The SCH has indicated that expatriates (non-national residents) will be enrolled in Seha upon renewal of their residence permits by payment of a premium which is to be covered by their employer or sponsor.

Beneficiaries of Seha will be able to obtain services from both public and private health care providers.  The Seha network currently includes 73 providers of which 4 are public facilities and the remainder private sector providers. The SCH intends for all health care facilities in Qatar to join the Seha network in due course.

The SCH has indicated that over 400,000 visits were made to doctors and hospitals by Qatari nationals under the first and second stage of Seha up to 21 September 2014.

The Regulations

The Regulations contain a number of conditions which impact the operation of Seha and its participants.

Article 16 of the Regulations provides that a health insurance provider's place of business must be inside Qatar and that it shall be licenced by the competent governmental authority in Qatar.

Further, Article 16 provides that health insurance providers "shall not manage or run, either solely or jointly, any healthcare services rendered to the beneficiaries inside the State."

Amongst other things, the Regulations include various articles concerning patient confidentiality and introduce a complaints procedure in Article 32.

Health Insurance Premiums

The value of health insurance premiums has yet to be determined, and market participants, such as private employers, are awaiting guidance on this issue.

Article 13 of the Health Insurance Law provides that the Government shall be responsible for paying health insurance premiums for Qatari nationals. It appears likely that the Government will also cover the health insurance premiums of Gulf Cooperation Council (GCC) nationals although there is no explicit article mandating such in the law.

Employers and sponsors are responsible for paying health insurance premiums for their employees (and their families) and sponsored persons, respectively. Visitors are responsible for paying their own health insurance premiums for the duration of their stay in Qatar.

Article 18 prohibits employers and sponsors from recovering any health insurance premiums from employees (and their families) or sponsored persons, respectively.

The amount of health insurance premiums shall be based on "generally accepted actuarial principles" to be paid in accordance with the ratios and measure prescribed in the Regulations pursuant to Article 12 of the Health Insurance Law. The SCH is responsible for setting the amount of health insurance premiums according to Article 14.

Article 2 of the Regulations provides that health insurance premiums shall be set without discrimination between beneficiaries in respect of age, gender, previous health status or any other risk factors.  Premiums shall be paid as a percentage of all costs of the healthcare activities, in addition to the actuarial forecasts, provided that such premiums do not include profits.

There will be a period between the launch of Phase 1 and Phase 4 whereby Seha will work concurrently with private health insurance.  The SCH has indicated that this is to enable employers to reconcile the coverage of employees between their existing health insurance plans and Seha. The SCH has instituted a moratorium (SCH Circular No 7 of 2013) on price increases for health care services offered by private health care providers until Seha is fully implemented to avoid potential price increases during the implementation phase.

Basic and Additional Healthcare Services

Article 1 of the Health Insurance Law distinguishes between "Basic Healthcare Services" and "Additional Healthcare Services". Basic Healthcare Services are defined as "A range of Healthcare services, which shall be provided to the Beneficiaries in accordance with the provisions of this Law." Additional Healthcare Services are defined as "A range of Healthcare services, which may be provided, in addition to the Basic Healthcare Services, to the Beneficiaries in accordance with the provisions of this Law."

Article 28 of the Regulations provides that the NHIC "shall be soley responsible for providing the insurance coverage for the Basic Healthcare Services".  Thus, mandatory insurance coverage for all Basic Healthcare Services will be provided by the NHIC alone.  Accredited health insurance companies will be entitled to offer insurance cover for Additional Healthcare Services only.

The services included in Basic Healthcare Services are dependent on one's nationality and residency status in Qatar as detailed in Table 1.

The services included in Additional Healthcare Services (and by definition excluded from Basic Healthcare Services) will be crucial in determining the level of participation of health insurance providers in Seha.  It is not yet clear whether the NHIC will also participate in offering insurance cover for Additional Healthcare Services.

Table 1

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