Catholic Health Australia Submission: Consultation on PHI Rules – October 2025 Sunset
May 6, 2025Catholic Health Australia – Submission on the proposed new Financial and Prudential Standards
May 6, 2025
Submission
Background
The Department of Health and Aged Care (DoHAC) and the Australian Prudential Regulation Authority (APRA) are undertaking a review of private health insurance legislation in accordance with the Legislation Act 2003 to ensure it remains fit‑for‑purpose, is kept up to date and in force so long as it is needed.
This review applies to four Rules.
Three of these Rules are administered by DoHAC:
- Private Health Insurance (Risk Equalisation Policy) Rules 2015
- Private Health Insurance (Health Benefits Fund Policy) Rules 2015
- Private Health Insurance (Levy Administration) Rules 2015
One Rule is administered by APRA:
Private Health Insurance (Risk Equalisation Administration) Rules 2015
Each of the rules were analysed based on four key factors:
- Market conditions: This evaluates the current state of the private health insurance sector, including trends like insurer consolidation, changing demographics, and the evolving role of insurers in healthcare delivery.
- Policy intent: This assesses whether the original purpose and objectives of each rule remain relevant and effective in the current environment, ensuring the rules still align with their intended goals.
- System efficiency: This looks at how well the rules function in practice, including the administrative burden they place on insurers, the efficiency of processes, and whether there is room for improvement through technological advancements or streamlined procedures.
- Impact on affordability: This factor examines how the rules affect the cost of premiums for consumers, considering whether they help maintain affordability or inadvertently contribute to rising costs.
