Medi-Clinic currently employs more than 6 500 nurses in all categories in 46 hospitals in eight provinces and Namibia. We contributed 1(234 million in taxes and levies in the 2005 financial year.

Medi-Clinic Limited would like to take this opportunity in congratulating the Minister of Health in attending to the redrafting of this important legislation and presenting it for public comment. The nursing legislation is of great importance and impact in our industry. In general, we are of the opinion that it is a well drafted document and our comments are limited to the sections to which we would like to draw the honourable Portfolio Committee on Health's attention.

S10(1)(a) - Appointment of Council Chairperson

We are of the opinion that it is good administrative practice for the Chairperson of the Council to be appointed by the members of the Council rather than by the Minister of Health. This will, we believe, ensure the independence of the Chairperson and the Council as a whole.

s40(1) - Community Service

Although Medi-Clinic does not oppose the concept of community service, we are of the opinion that the implementation thereof needs to be carefully considered.

By way of background, Medi-Clinic started training Nursing Assistants at Sandton Medi-Clinic in 1985. The target group was Domestic Workers who had a matric qualification. Some of them are Registered Nurses today.

All training is based on the current and future manpower needs of the various hospitals in the group. For this reason training is funded by the company and students are required to enter into a contract to work back time. All successful students are offered a position in the company on completion of their training and have an opportunity to achieve further qualifications.

Since the expansion of our training in 1997, a total of 1 776 nursing staff members have received new qualifications. Currently we have 1 037 students in training.

Courses currently offered by Medi-Clinic's six registered nursing schools and in collaboration with tertiary institutions, include:

The Course Leading to Enrollment as a Nurse Auxiliary (P2176)

The Course Leading to Enrollment as a Nurse (P2175)

The Bridging Course for Enrolled Nurses Leading to Registration as a General Nurse (P683)

The Certificate in Anaesthetic and Recovery Room Nursing

The Certificate in the Nursing Science of Diagnostic and Therapeutic Cardiac Interventions

The Certificate in Cardio-Thoracic Critical Care

The Certificate in Emergency Nursing

The Certificate in General Critical Care

The Certificate in Oncology /Haemotology Nursing

The Certificate in Operating Theatre Nursing

The Diploma in Medical and Surgical Nursing: Critical Care

The Diploma in Emergency Nursing

The Diploma in Midwifery

The Certificate /Diploma in Neonatal Nursing Science

The Diploma in Medical and Surgical Nursing: Operating Theatre Nursing Science

The Medi-Clinic Advanced Pain Management Certificate

The Medi- Clinic Certificate for Anaesthetic and Recovery Nursing for Enrolled Nursing Categories

The Medi-Clinic Central Sterilization and Supply Course

The Medi-Clinic Endoscopic Certificate

The Medi-Clinic Maternity Nursing Fundamentals

With reference to the aforementioned training, the private healthcare sector contributes approximately R50 million to the Health and Welfare SETA per annum. In the circumstances, the role that the private sector plays in the training of nurses cannot be underestimated or ignored.

Turning to s40(1), we are concerned, firstly about the effect that community service would have on the training offered by the private sector. With respect to training that is funded and undertaken by the private sector, we do not believe that it is equitable for trained staff and Medi-Clinic to sacrifice the newly qualified professional to the public sector for community service. The nett result would be to discourage training in the private sector - it is submitted that this would be a situation that the health sector can ill afford.

Secondly, it is our interpretation of the Bill that community service would need to be rendered each time a person registers in a new category ie should a student follow a bridging course from auxiliary nurse to staff nurse to professional nurse, at least a 3 year period of community service would be required, which we do not believe is appropriate.

In addition, it must be borne in mind that many of the students bridging to become professional nurses are older and established in their personal lives. We strongly submit that any proposed community service for this type of student will serve to discourage the student from undertaking the course. Logistical issues of community service issues such as family care, accommodation, transport etc will make the bridging course unattractive to mature students.

BACKGROUND TO THE MEDI-CLINIC GROUP OF PRIVATE HOSPITALS

The core purpose of the Medi-Clinic Group is to enhance the quality of life of patients by providing comprehensive, high quality hospital services and to be a respected and trusted provider of hospital services by patients, doctors and funders of healthcare.

Medi-Clinic believes in providing cost-effective quality healthcare on a sustainable basis. The Group continually strives to be a responsible corporate citizen by inter alia supporting broad-based economic transformation, managing the environmental impact of operations and contributing to the general well being of the community. The Group is committed to ethical business practices and efficient risk management.

In addition, Medi-Clinic has an entrenched service culture that follow best international practice, which is ensured through training programs and recruiting processes that select and recruit those individuals who share the Group's values. Competent and quality service delivery in all functions of the business is of major importance to the Group. Medi-Clinic's network of professional training and development consultants, clinical assessors and mentors focus on the continuous professional development of all nursing staff. A total of 25 structured learning activities are in place to ensure competent and safe practice. This structured approach has encouraged learning and has resulted in career enhancement opportunities for participants.

COMMITMENT TO QUALITY

1. Quality Healthcare

Each of the 47 hospitals in the Medi-Clinic Group is committed to quality care, from the skills of the doctor to the care of the patient, from the empathy of our nursing staff to the high standards of our facilities, from the meticulous maintenance of our world-class technology to upholding the fairest possible tariff. By focusing on a patient centred approach to care, we have established a culture of quality that permeates every aspect of our business and have ensured that our employees and the doctors continuously strive to improve patient care and patient safety. Our dedication to excellence in healthcare is evidenced by the quality of our facilities.

Providing quality care requires a team approach. By involving the employees and doctors at decision-making levels, Medi-Clinic has entrenched an integrated multidisciplinary team approach to patient care in all our hospitals. This has ensured that our patients receive the best possible care in a safe clinical environment.

The Medi-Clinic Quality Assurance Team (MQAT) is tasked to ensure continuous training, adherence to quality protocols and accreditation criteria and ensuring compliance with key operational risk management procedures. In addition, the hospitals participate in the accreditation programme of the Council for Health Service Accreditation of South Africa (COHSASA) which, in turn, is internationally accredited by the International Society for Quality in Healthcare (lSQua), ensuring that our hospitals attain international accreditation status. The accreditation process involves regular external audits of more than 350 standards and 3 500 criteria and a pass rate of 90% and higher is required to achieve accreditation.

Medi-Clinic is also committed to ensuring that its environmental management systems and practices are accredited and aligned with international best practice, such as the SOl 4001 standard. In this regard several of the hospitals have already received the ISO 14001 certification of the National Quality Assurance (NQA) in London. Furthermore, policies aimed at sound management of water consumption, energy conservation, waste management and recycling are followed at the hospitals.

2. Technology

The Group's technical mission is to provide the best healthcare facilities and technology available in the developed world with budgets generated in a developing country. In doing this, Medi-Clinic has to design, build or improve facilities to meet the needs of clients and to maintain its commitment to quality care. The life of the Group's buildings, plant and equipment has to be maximised through reliable technical support in order to ensure a safe and user-friendly environment for staff and clients. Planned maintenance programmes are based on ISO 9000 standards. The Group's hospitals are subjected to a comprehensive in-depth maintenance audit on an annual basis that covers all categories of plant and equipment.

ECONOMIC STANDING

1. Proudly South African

Medi-Clinic is a member of Proudly South African, confirming our commitment to the provision of quality service, maintaining fair labour conditions and a healthy environment. Medi-Clinic supports the Proudly South African campaign that recognises and rewards South African products and services of high quality and believes that this will result in more employment opportunities, greater prosperity and a better life for all in South Africa.

2. Broad Based Black Economic Empowerment ("BBBE")

The Board of Medi-Clinic views the company as an integral part of the South African political, social and economic community. The Board endorses the process of democratisation and strives to support this process through a policy of business practices that enhances BBBEE, which is regarded as a strategic opportunity to strengthen the economic base of our country. A key success factor is the rapid capital accumulation at all levels of society involving human, social, intellectual and physical capital. Medi-Clinic believes that the structure of a BBBEE transaction should be such that this is not simply a transaction between two organisations, one of which happens to be black. It must be an agreement that incorporates all the objectives of black economic empowerment including meaningful ownership, knowledge sharing and involvement at decision-making level. This has been the case in all BBBEE transactions of Medi-Clinic.

Medi-Clinic introduced a black economic empowerment consortium as a partner into private healthcare through the Medi-Clinic Group at the time of the acquisition of the Curamed Group on 1 December 2002.

Medi-Clinic facilitated the Curamed transaction and provided the consortium with interim finance of about R49 million to enable them to finance their part of the transaction. The consortium currently consists of Nozala Investments (Pty) Ltd and Phodiso Clinics (Pty) Ltd (who successfully acquired the interests held by Mvelaphanda and Utlwanang).

In addition to the aforementioned, Phodiclinics (Pty) Ltd, a joint venture company owned 51% by Medi-Clinic and 49% by Phod iso Clinics, made an offer to acquire the four hospitals of the Protector group (in liquidation), the offer was accepted by the liquidator subject to certain conditions.

Medi-Clinic's commitment to sustainable growth and prosperity in a democratic South Africa and the location of its hospitals across the country implies that BBBEE strategies can be supported and encouraged across a broad spectrum of opportunities.

In addition, Medi-Clinic recognises the value of an all-inclusive Healthcare Charter and is actively participating with the Private Healthcare Forum and the Hospital

Association of South Africa to establish such a charter.

3. Preferential Procurement

In addition to the above-mentioned BBBEE initiatives, Medi-Clinic is committed to the government's BEE Preferred Procurement Strategy. To this end a committee monitors the support of and purchases from BEE suppliers, which provides benefits not only for previously disadvantaged persons and businesses, but also for the development of sustainable growth and prosperity in South Africa.