New mandatory health insurance system introduced in Qatar

Qatar signalled its intention to revamp its mandatory health insurance scheme, by issuing a new law which came into 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 was preparing to host the 2022 World Cup and anticipating a huge influx of visitors. National insurance companies in Qatar are positioned well to capitalise on the momentum.

Whilst full details of how the scheme will work and be implemented are still awaited, an announcement this week confirmed that visitors to Qatar from 1 February 2023 will need to obtain health insurance. The application can now be made through the Ministry of Public Health (MOPH) portal.

The Law

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 took effect on 4 May 2022, six months from the date of its publication in the official Gazette.

Key changes

The announcement of the Law introduces a number of significant changes to the current health insurance system in Qatar: 

• All non-Qatari nationals and visitors in Qatar must have private health insurance for the duration of their stay to receive basic medical services.
• Employers must enrol their non-Qatari employees and their family members onto the mandatory health insurance scheme through contracts concluded with insurance companies registered with the MOPH.
• The same obligations apply to sponsors of expatriates in Qatar, such as the recruiter, to provide basic health insurance coverage.
• Employers will need to prove their employees are covered by the mandatory health insurance scheme when issuing or renewing their residence permits. Basic health insurance will be a prerequisite for obtaining any form of permit or visa rather than the current requirement for individuals who are more than 60 years of age.
• Additional healthcare services above the basic health insurance requirement may be provided by the employer or recruiter as a matter of contract.
• Fines will be issued to employers or recruiters who fail to provide basic health insurance to their employees and eligible family members.
• Detailed implementing regulations will be published to provide further details of how the Law will operate in practice. 

What does this mean for the insurance market 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.

Rollout of the scheme

The scheme came into force in May 2022; this week’s announcement regarding insurance for visitors to Qatar is the first phase of roll out.

In relation to non-visitors, insurance policies issued before May 2022 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.

Action needed

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. 

If you would like further information on any issue raised in this article, please contact Wayne Jones, Emma Higham or Nasteho Muse.  

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.