Dr Debbie Pearmain

The Practice Code Numbering System (PCNS), the number allotted to a supplier of a relevant health service as a practice number by an organisation or body approved by the Council for Medical Schemes (CMS) – and administered by the Board of Healthcare Funders (BHF) NOT on behalf the CMS – is clearly a “national asset” for healthcare provision but still “poorly understood”.

Speaking to delegates at the BHF Healthcare Forensic Management Unit Indaba in Rosebank yesterday, Dr Debbie Pearmain, former Department of Health (DoH) and BHF legal advisor now an independent consultant, started off by noting that the law (healthcare legislation) says little about PCNS, “only a definition”.

“This is probably one of the reasons why the PCNS is poorly understood, not only among schemes and providers, but also the Department of Health and the various regulatory bodies,” she said.

To this she added that the Health Market Inquiry (HMI) conclusion that the PCNS is only useful for billing purposes and recommends that it be shifted from the BHF to the HMI-proposed Supply Side Regulator for Healthcare (SSRH) “clearly indicates that the Competition Commission doesn’t’ understand it either”.

“It has much bigger relevance such as scope of practice in terms of the Health Professions Act. It is therefore relevant in law,” Pearmain explained, “not only when it comes to the Medical Schemes Act but also provider legislation as well.”

While not strictly a fraud, waste and abuse tool, the PCNS offers valuable support particularly in identifying perpetrators. An example cited by Pearmain was a provider using another’s practice code number thereby putting his or her scope of practice into question.

Other areas where confusion may arise over the role of the PCNS include the proposed Certificate of Need (CON) legislation first mooted in the National health Act 16 years ago: “Nothing’s happened yet but one must remember that the CON refers to the licensing of practices and not individuals.”

Another, Pearmain warned, was the Protection of Personal Information Act (POPI), also still to be enforced: “Here the BHF must act responsibly in making the PCNS compliant with POPI.

“It would be a big mistake for the PCNS to assume the role of the Certificate of Need!”

The NHI, however, would need a number linking an individual to a practice. This and related considerations would make it important for the BHF to continue administering the PCNS and working with the Office of Health Services Compliance (OHSC), position itself better to take on additional roles.

“This,“ Pearmain concluded, “would apply not only to the regulation of providers, but also to addressing fraud, waste and abuse in the system.”