Submission on A Strategic Framework for the Human Resources for Health Plan: Draft for Discussion
The AIDS Law Project (“the ALP”) and the Treatment Action Campaign (“the TAC”) welcome the release of the Strategic Framework for the Human Resources for Health Plan (“the Strategic Framework”) for public comment and discussion. We further welcome the express acknowledgement therein by the Department of Health (“the DoH”e need for appropriate human resources for health (HRH) planning and recognise the substantial work that has gone into the development of the Strategic Framework.
However, we are concerned about a number of issues, both in relation to the substance of the Strategic Framework as well as the process by which it has been developed. While this submission will focus on the key substantive concerns raised by the Strategic Framework, it is important that we also place our reservations regarding the process on record. In short, the process followed to date has been flawed in the following ways:
- Despite expecting an HRH plan to be released at the end of March 2005, as initially promised by the DoH, the Strategic Framework was only released some four months later on 3 August 2005, calling for public comments within a six week period.
- At the time the Strategic Framework was released, the draft Health Charter had been in circulation for just over three weeks, with public comments on that document being due less than two weeks later on 15 August 2005.
- Neither the ALP nor the TAC was invited to attend the briefing sessions on the Strategic Framework organized by the DoH during the week 11 – 17 August 2005, despite the DoH’s knowledge of our interest in the matter and the need for broad consultation with civil society organisations that act and/or speak on behalf of users of health care services.
These flaws needn’t be fatal. While an HRH plan should be finalised as soon as is reasonably possible, there is a need to consult more broadly and appropriately with organisations such as ours as well as other key stakeholders such as health sector trade unions, tertiary institutions, nursing colleges and appropriate statutory councils. Such consultations should take place in an open and accountable manner, possibly in the form of public hearings co-ordinated by Parliament’s Portfolio Committee on Health.
Our key concerns relating to the substance of the Strategic Framework can be summarised as follows:
- It is not a national HRH plan;
- It fails to recognise the relationship between HRH planning and health sector transformation, and to give substantive meaning to the concept of national stewardship of HRH planning;
- It fails to deal with emergency and short-term needs as integral parts of HRH planning;
- It is devoid of priority setting; and
- It fails to address other key issues such as:
- Inter-sectoral cooperation;
- The setting of health care worker (HCW)/patient ratios;
- Why many HCWs are leaving the public sector;
- The impact of HIV/AIDS on individual HCWs and the health system as a whole;
- The financing of HRH planning;
- Determining an appropriate role for the private sector; and
- Monitoring, evaluating and ensuring the proper implementation of a national HRH plan.
But before commenting in further detail on these key concerns, we believe it is important briefly to consider the context that demands appropriate HRH planning, as well as to set out the relevant constitutional and statutory framework within which the HRH plan is to be located.1 This focus considers the constitutional requirement to develop and implement a national HRH plan, the requirements regarding the substance of such a plan, and various statutory requirements as set out in the National Health Act, 61 of 2003 (“the NHA”). Once this is done, the submission considers the manner in and the extent to which the Strategic Framework fails to comply with the constitutional and statutory requirements and how it could be improved to address its shortcomings.