Roshan Bhana RETHINKING MEDICAL SCHEME RESERVING Why do schemes need to hold reserves? • Reserves buffer against adverse experience – Absorb unexpected claims volatility – Used to fund unexpected claims – Catastrophic events • Reserves should reflect the level of risk faced by the scheme – Not all schemes are equally risky – Consider all sources of risk • • • • Claims Credit Operational Investment What events do schemes need protection against? • High cost claims – Single events with low frequency but significant cost • Variability of claims • High volume, low cost claims • Failure of scheme service providers – If service providers could not continue doing business, would the scheme be able to continue to operate? • Asset risks – Risk of investments losing value Current reserving requirements • Regulation 29 to the Medical Schemes Act 131 of 1998 – Accumulated funds may not be less than 25% of gross contributions for the accounting period under review • Shortcomings of current requirements – Fixed 25% is not reflective of the risks faced by each scheme • 25% will be too much for some schemes, but too little for others – Penalises growth which improves the stability of the scheme – Members ultimately bear the cost through additional contribution increases – Requires reserves to be held for MSA • 2013 reserves held: R 43.194 billion Possible measures of solvency • Status quo: 25% • ITAP formula: LR2 OR 2 AR2 – LR: Liability Risk, dependent on scheme size and pricing strategy – OR: Operational Risk, dependent on impairment losses and level of NHE – AR: Asset Risk, dependent on investment strategy • Stochastic modelling approach – Risk of Ruin: – Each scheme should hold reserves sufficient to prevent failure with reasonable levels of certainty • Liability measures – not considered for this presentation 25% Solvency • Industry reserves required (2013): R 32.382 billion • 9 schemes underfunded – R 3.851 billion underfunded • 77 schemes overfunded – R 14.662 billion overfunded • Industry overfunded by R 10.812 billion ITAP Formula: • Industry Reserves required (2013): R 15.797 billion • Top 9 Open and 10 Restricted Schemes: – 3 schemes underfunded – 16 schemes overfunded • Industry overfunded by R 27.397 billion ITAP Reserving Requirements 70% Reserve Requirement (% of GCI) 60% 50% 40% Required Solvency Actual Solvency 30% 20% 10% 0% Regulatory Solvency Stochastic Modelling Approach: • Stochastically simulate one year’s claims for each scheme • Calculate the probability of failure in the next year Probability of failure of 0.5% - risk of failure once in the next 200 years • Reserves calculation: – Worst-case claims in the next year minus 85% of risk contributions – High level of conservatism built into calculation – Prevent a 1 in 200 year event - 99.5% chance of continued sustainability Stochastic Modelling Approach: • Claims reserves required (2014): R 31.151 billion • 17 schemes underfunded – R 6.896 billion underfunded • 69 schemes overfunded – R 18.939 billion overfunded • Industry overfunded by R 12.043 billion Stochastically Simulated Reserve Requirements 80% 70% Reserve Requirement (% of GCI) 60% 50% Required Solvency 40% Actual Solvency Regulatory Solvency 30% 20% 10% 0% Implications of an alternative statutory solvency requirement • Distribute excess reserves to members – Unlikely given that members cannot be called upon in cases of under-capitalisation – Won’t be allowed by Regulator in current environment • Potential for lower future contribution increases – Certain schemes would have an extreme advantage in the short-term, especially larger schemes – Need to consider regulation to prevent advantage – Schemes may be able to adopt alternate pricing philosophies – Current practice for some schemes above the 25% statutory solvency requirement – Regulation may be required to remove artificial advantages Implications of an alternative statutory solvency requirement • Transfer of assets from over-funded schemes to under-funded – Form of reserve equalisation – Alterative to risk equalisation • Increase medical aid access (LCBOs) – Schemes with reserves in excess of RBC measures or alternate measures may actively pursue extended coverage for current uncovered members – May be easier to implement for sector or industry funds • Transferred to industry fund – Would still be used as a buffer for extreme events – May be met with high level of resistance – Likely to be extremely unpopular Implications of an alternative statutory solvency requirement • Removal of barriers to entry and exit – Current potential new entrants may be discouraged from entering environment due to onerous solvency requirements – Current schemes over the 25% statutory requirement may be lulled into a false sense of security when considering the current requirements in the absence of a purely risk based measure • Schemes could pursue a more aggressive Investment Strategy – the very basis of the source of this discussion. Acknowledgements • • • • Alison Counihan Stefan Bekker Cecilia Augustine Roshan Bhana THANK YOU