Draft Law on the budget of the National Health Insurance Fund (NHIF) for 2019.

Mr. Valery Simeonov
DEPUTY MINISTER-PRESIDENT
ON ECONOMIC AND DEMOGRAPHIC POLICY
CHAIRMAN OF NSTS

CONCERNING: Draft Law on the Budget of the National Health Insurance Fund (NHIF) for 2019.
 

DEAR MR SIMEONOV,

On behalf of the Confederation of Employers and Industrialists in Bulgaria, we would like to present to your attention an opinion, agreed with the members of KRIB, regarding the draft Law on the budget of the National Health Insurance Fund for 2019.

We would like to express our support for all the efforts of the Ministry of Health, aimed at lasting and qualitative reform of the health sector, including the changes laid down in the ZBNZOK. We are extremely positive about the provision of an additional BGN 490 million for expenses and transfers compared to 2018.

However, we would like to call for a different approach when undertaking significant legislative changes, so that stakeholders, including business – a strategic partner of the Executive – have the opportunity to join the public debate and give their input.

Insofar as the subject of the main provisions of the National Health Insurance Fund for 2019 is limited only to the adoption of the budget of the National Health Insurance Fund for 1 specific calendar year, the implementation of significant changes, in principle within the scope of other legal acts, is contrary to the principle of transparency in the law-making process process, namely a public discussion in order to ensure wider support in the implementation of the policy of the Ministry of Health.

The law on the budget of the health insurance fund presumptively ensures the rights of citizens for medical assistance and treatment for the relevant calendar year and should not change the rights of citizens and the arrangement of health insurance legal relations in substance and for an indefinite period of time, in view of the budget's provisions for a specific calendar year.

In view of the nature, scope and specific content of the proposed changes, as well as the duties and responsibilities of medical professionals, the proposed changes should be subject to a preliminary impact assessment and public consultations with citizens and legal entities and be proposed through Laws amending and supplementing the relevant acts - the Health Act, the Health Insurance Act, the Medical Institutions Act, the Medicinal Products in Human Medicine Act.

With respect,

Eugene Ivanov
CEO