Excerpts of an open letter to MOH by Dr.Neeraj Nagpal

To

Dr Anil Kumar CMO (AK)
Nirman Bhawan

 New Delhi

Medicos legal action group  do not think CEA should be applicable to small and medium healthcare establishments (SMHCE) with less than 10 cr paid up capital in metropolitan cities and proportionately lower in tier I & II cities. 

The standards proposed and displayed in nirman bhavan's website,if become notified will close Level I and Level II hospitals all over the country including all nursing homes,which are providing 70 % of the inpatient care in India. 

This Act will only benefit corporate hospitals who as yet have less than 2 % penetration in the healthcare market in India.

Registering all Clinical establishments is a noble idea. Forcing small and medium healthcare establishments (SMHCE) to fullfill norms like 27 licences not even required by 100 bed Govt or 100 bed Ayush hospitals gives a glimpse of what is the real reason behind this Act.i.e. Inspector Raj will prevail . 

Already we have reports of 30000 to 40000 being charged as bribes for Provisional registration in states,whereCE act is in force like Chattisgarh , whereas Provisional registration is supposed to be automatic. There is gross discrimination against small ;level one and Level two allopathic hospitals and this is more evident in speciality and superspeciality standards.

It is good to have public safety in mind but if by same token we make it mandatory for all cars to have air bags, four wheel drive and anti skid braking , the maruti 800 will no longer cost 2 lacs it does today. Similarly forcing western standards on SMHCEs will only make them either shut shop or charge more to break even. Viability and existence of SMHCEs is threatened.

Before notifying the minimum standards Kindly conduct a detailed study as to 
1) What is the proportion of OPD & IPD healthcare services which are provided by these small nursing homes and clinics (SMHCE)?. 
2) Are their services dispensable ?
3) Can the Govt infrastructure and the corporate hospitals along with Ayush hospitals full fill the healthcare needs of the nation without these small hospitals and nursing homes ?