10 things you need to know about doing business in Qatar
Qatar has recently signalled its intention to revamp its mandatory health insurance scheme, by issuing a new law due to take effect in May 2022. The new compulsory health insurance scheme will apply to all expatriates and visitors to Qatar. The new scheme will replace an earlier scheme (SEHA) which was disbanded in 2015. In this article, we consider how the new scheme will operate, what this means for employers and the insurance market in Qatar, and the implications for non-registered foreign health insurers operating in the region.
The Law and impending Implementing Regulations are expected to develop the health sector in Qatar to alleviate the pressure imposed on it by its largely expatriate population.
The introduction of the Law comes at a time when Qatar is preparing to host the 2022 World Cup and will see a huge influx of visitors. National insurance companies in Qatar are positioned well to capitalise on the momentum.
Full details of how the scheme will work and be implemented are still awaited.
The Ministry of Public Health (‘MOPH’) announced that the new mandatory health insurance system will be implemented for all non-Qatari nationals living in and visitors to Qatar. The new system was promulgated under Law No. 22 of 2021 regulating the health services in Qatar (the 'Law'). The Law was published in Qatar's official Gazette on 4 November 2021 and repeals all former laws governing health services. The Law will take effect on 4 May 2022, six months from the date of the publication in the official Gazette.
The announcement of the Law introduces a number of significant changes to the current health insurance system in Qatar:
The SEHA scheme introduced into Qatar in 2013 contemplated a single, state-owned insurance company (National Health Insurance Company – NHIC) providing the basic cover to expatriates and Qatar nationals. The scheme was administered by an outsourced TPA.
The SEHA scheme was scrapped at the end of 2015 and NHIC was duly liquidated. Health insurance reverted to an ad hoc private medical scheme, with the Qatar government absorbing the costs of all other residents and citizens’ healthcare costs.
The new scheme appears to envisage private insurers that are approved by the MOPH being authorised to offer prescribed minimum levels of cover as set out by the scheme. The MOPH is likely to play an additional role as a regulator of the health insurance services. It is unclear what licensing or authorisations will be needed by brokers and TPAs.
However, if the scheme follows those that have been implemented in Saudi Arabia, Abu Dhabi and Dubai, one can expect to see the MOPH requiring all participants in the insurance market chain to be required to be authorised to offer health insurance related services in the scheme.
This does mean that foreign insurers, brokers or TPAs, who presently have no presence in Qatar, will be precluded from participating in the scheme, unless they set up and obtain the requisite authorisation from the MOPH. It is not yet clear whether the registration requirements will also extend to top up healthcare services, which could then impact on the ability of non-registered insurers to provide this form of cover.
We will need to await the details of the Implementing Regulations before understanding how the scheme will operate.
The scheme is intended to come into force in May 2022. Insurance policies issued before this date will remain in effect until expiry. There is a question mark as to whether this transition phase will apply to policies issued by non-registered insurers. It is also not yet clear whether there will be universal application of the scheme, or whether it will be rolled out in phases.
The scheme does not presently contemplate mandatory insurance requirements for Qatari Nationals. In Saudi Arabia, Nationals are required to have private medical insurance, whereas in Dubai and Abu Dhabi it is not mandated, and the government operates various self-funded schemes to cover costs of the UAE National population’s healthcare.
It is not only the insurance market that will need to prepare itself for the rollout of the new scheme. Employers and sponsors will need to acquaint themselves with the requirements. Details of the various plans to be required and offered, together with costings, are still awaited. Healthcare providers will also be interested to see the prescribed level of benefits that are mandated under the new scheme.
Disclaimer: Please note the English translation of the Law is an unofficial translation into English of the original Arabic text, and the government officials in Qatar may interpret the text of the legislation differently. For the purposes of drafting this article Clyde & Co has used its own translation of the Law. At the time of drafting this article, no official translation of the Law has been published.