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Monday, 18 June 2012

IRDA Health Exposure Draft – Few Concerns


IRDA has released exposure draft on health insurance which most consider as landmark and revolutionary and perceived that this will help society at large. But, I don’t think so as there are few concerns and needs to be addressed before these regulations are finalised.

The major change which the draft regulation proposes is that all health insurance policies shall provide for entry age till at least up to 65 years. However mere provision of minimum age till which the health insurance should be available does not necessarily mean that all the proposals fitting into the age will be accepted by the insurers. The final decision as to whether to accept or reject the proposal is in the hands of insurers and history tells us that insurers are not willing to accept a new proposal for any person above age of 45 years. Mere providing for grounds for rejection, which the proposed regulations provide, shall be made in writing, be justifiable and fair will not serve the purpose. IRDA has to ensure that proposals are not being rejected unless there are serious issues or accepting that proposal is detrimental to the interest of other policy holders. Moreover IRDA should also provide for right to appeal in case of rejection and the procedure to be followed for that.

Draft regulations also provide that all health policies shall be renewable till death and will not have any exit age for renewal. One very welcome provision of the draft regulations is that, it also provides that   insurer shall not refuse the renewal of the health insurance policy on the ground that the insured has made a claim or claims in the previous or earlier years. What the insurance company can do in such cases is that they can load the premium if the individual claims experience, for each of the three consecutive policy years is more than 500% of the premium under the current policy. This cap linked as percentage of premium is going to be detrimental to the interest of the policy holder. Let us understand the implications of this provision with an example. For example a healthy 30 years male will get health plan for sum assured of Rs. 3 lakhs at around premium of Rs. 4,000 p.a. Policy holder will be loaded if his claim amount is more than Rs. 20,000 yearly for three consecutive years. The amount exhausted is not even 10% of the sum assured and he is liable for premium loadings as per draft. This is not justifiable and should at the most the claim amounts should be linked to percentage of the sum assured for better clarity and understanding of the provision. I would even go to the extent to saying why loadings are required as premium is charged after considering the probabilities of claims and it anyway increases with advancing of age so as to keep pace with higher probability of claim being lodged.

The draft also required the health insurance company to gives option to migrate to suitable health insurance plan at the end of the specified exit age from specific policies. This is useful in case of family floater policies where the child automatically excluded from health cover once he completes 21 years of age and the child looses all its history. More clarity on the count is required as to whether a person will get the same sum assured which was available to him in the family floater plan. Policy holder must also get all benefits carried forward without any break and exclusions.

It is a good that draft provides for taking into account cumulative bonus with the sum assured to arrive at sub limits applicable. Sub limits on room rent are the major stumbling block for the insured person to claim the full genuine expenses incurred as a few people understand the impact of the same. This means in case you stay in a room costing higher than this limit all other expenses will also be charged accordingly but you will be entitled for expenses on the basis of what you would have incurred had you stayed in a room that costs within your limit. IRDA should also provide for periodic upward revision in the sub limits as room rents are likely to go up looking at medical inflation. The room rents are not uniform throughout the country and are more expensive in metro cities and these facts are also to be looked in before finalisation of the regulations.

There are some policies available in the market in which co-payments are required to be made by policy holder up to 20% of the claim amount. Co-payment means part of the claim has compulsory to be borne by the policy holder. Co-pay is levied when you are hospitalised in non net work hospitals and are levied compulsory for claims after age 65 years. There is no provision to regulate the terms about co-payments in this draft. IRDA should also take necessary steps to regulate this practice.

The draft has provided for grace period up to 30 days which at present is 15 days. One should note that cover is not available during the break period, means if you do not renew your policy before due date than you will not be covered for the diseases except due to accident till you make the payment in the grace period. One should note that in life insurance death claim is payable even you die during grace period. IRDA should look into this as why claim should not be payable during the grace period if the claim is genuine.

Draft also provides for no payment of commission to intermediary in case of policy is ported to another insurer. I strongly believe that one requires the help and support of agent in health insurance plans and if agents are not adequately remunerated then will be least interested in helping people in portability. IRDA should regulate the commission payout on overall basis and not for some specific cases. Insurers should also be asked to launch online plans which are cheaper than normal plan just like online term plans of life insurance. 

Draft should also mandate inclusion of alternative treatments because people are worried about the side effects arising out of the allopathic medicines. Also in some cases, with the use of alternative medicines, a surgery can also be avoided. Many People are already taking alternative treatments to cure their diseases, but unable to claim the expenses. Draft should also give relief for this. 

Many time previous years original policies are also called for before settling the claims. According to me this is an absurd.  Insurance companies or their TPAs should maintain these records and policy holder should not be harassed by asking for such requirements. IRDA should mandate that every renewed policy will also mention the original start date of the policy so that there is no need to submit earlier copies afterwards.

IRDA should also not allow insurers to change premium rates before completion of at least 5 years. We have witnessed the wrong practice by one particular insurance company of offering a low cost mediclaim policy and subsequently raising the premium by 300% to 400% at the time of next renewal. The policyholders had no option but to pay the premium so as to get the benefit of medical history for coverage of pre-existing disease. The raise in premium should also be fare and justified.

Last but not least draft should also provide for payment of interest @12% p.a. for delay in claim settlements beyond 30 days. 

This article first appeared at myiris.com on 18th June'2012.