Health Council Completes Advance Review
The Bermuda Health Council has completed its consultation on a proposed Advance Review and Approval Framework for major changes to Bermuda’s healthcare system, with 91% of respondents saying they “supported or strongly supported the proposed approach.”
A spokesperson said, “The Bermuda Health Council, in support of the Ministry of Health, has completed its targeted consultation on the proposed Advance Review and Approval Framework for Material Changes in Bermuda’s Healthcare System.
“The consultation was undertaken to help inform the Ministry’s continued development of the policy, which would ultimately be subject to the appropriate Government and Cabinet approval processes.
“The consultation received 69 online responses and four detailed written submissions. Overall, 91 per cent of respondents supported or strongly supported the proposed approach. There was also strong support for Government having the ability to require safeguards, modify or delay a proposal, or prevent it from proceeding where significant harm could not otherwise be addressed.
“Respondents were equally clear that the framework should focus on changes that could genuinely affect patients or the health system, and should not create unnecessary approval requirements around routine healthcare decisions. Stakeholders called for clearer rules, practical timelines, stronger clinical input, proportionate treatment of smaller providers and better use of information Government already holds.
“At its core, Advance Review is intended to give Bermuda an opportunity to understand the likely consequences of a major healthcare change before it takes effect, rather than trying to manage the impact afterwards.
“For example, if significant health insurance premium increases are proposed, the process could provide an opportunity to examine the evidence supporting those increases before higher costs are passed on to households and employers.
“Advance Review could also look at whether CIT credits are producing the public benefit they were intended to achieve. For example, where an insurer receives CIT credits while also proposing premium increases, Government could examine how those credits are being reflected in premiums, benefits, patient services or other measurable improvements for policyholders and the health system.
“If Bermuda depends on one specialist for an important service and the provider knows that service will end or significantly reduce because the specialist is retiring, early notice of that service change could give the health system time to understand the pending gap and work with providers on a solution before patients are left without a local option. Consultation respondents specifically highlighted the importance of succession, recruitment lead times and Bermuda’s dependence on small numbers of specialists.
“Advance Review could also apply where a major ownership change may reshape how healthcare is delivered. For example, if an investment company proposed buying several dental practices, the wider effects could be considered before the transaction takes place, including what it might mean for patient choice, access, prices, clinical independence and the viability of smaller independent providers.”
A Health Council spokesperson said: “In a small health system, resilience has to be built before the disruption, not after it. We do not always have a second specialist, another supplier or another service ready to step in when something changes.
“The purpose of Advance Review is not to stop change. Change is necessary in healthcare. It is about making sure significant change happens with our eyes open and with enough time to protect patients, manage transitions and address unintended consequences. Good policy should give us the opportunity to ask, ‘What happens next?’ before patients are already living with the answer.”
A spokesperson added, “Respondents also emphasised that Bermuda’s size matters. A change may appear relatively small numerically but still have a significant effect where there is only one provider, a limited number of specialists, a sole supplier or no practical alternative for patients.
“The proposed framework is intended to become part of Bermuda’s existing health regulatory structure, not replace it. Bermuda already has established regulation covering areas including health service providers, health insurance, medicines and the Drug Formulary, health technology and professional regulation. Advance Review would add a broader whole-system assessment where a proposed change could materially affect patients or the health system.
“Where specialist input is relevant, including clinical, financial, competition or other analysis, that information would contribute to the wider health-sector assessment. The intention is to make use of expertise that already exists across Government while avoiding unnecessary duplication of processes or information requests.
“The Health Council has provided the consultation findings and recommendations to the Ministry of Health for consideration as the policy is further developed.
“Further work will include testing proposed thresholds against Bermuda data and real-world examples, as well as focused technical discussions with relevant Government bodies and groups that were less represented during the consultation, including insurers, regulators and digital-health stakeholders.
“The Bermuda Health Council will publicly release the full Consultation Feedback and Recommendations Report, which sets out the detailed findings, stakeholder feedback, written submissions and recommendations provided to the Ministry.
“The full report and a summary brief will be available at healthcouncil.bm/engage.”
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