The Financial Sector Conduct Authority (FSCA) recently published FSCA Communication 6 of 2021 (FAIS) to provide clarity regarding the qualification requirements for Council of Medical Schemes (CMS) accreditation.
The guidance was issued in response to numerous queries and complaints to the FSCA following the CMS’s refusal to renew the accreditation of brokers who were unable to produce a Grade 12 National Certificate or equivalent qualification.
To be accredited as a healthcare broker, the applicant must fulfil the fit and proper requirements. One of the fit and proper requirements is a Grade 12 National Certificate or an equivalent qualification. According to the Regulations issued in terms of the Medical Schemes Act:
“Any person desiring to be accredited as a broker must apply in writing to the Council, and the application must be accompanied by—
(a) documentary proof of a recognised educational qualification and appropriate experience”[1]
The Regulations further state that:
“A recognised educational qualification and appropriate experience, means—
(a) Grade 12 education or equivalent educational qualification”[2]
Previously, where an applicant was unable to provide proof of a Grade 12 National Certificate, the CMS accepted an affidavit confirming that the applicant has a Grade 12 education.
However, since 2014, the CMS required that all qualifications be verified for authentication purposes. The verification is processed through Managed Integrity Evaluation (MIE) before accreditation is conferred. MIE requires a copy of the qualification certificate which is then verified. Accordingly, the CMS no longer accepts affidavits, and any accreditation or renewal application must be accompanied by evidence of having completed a Grade 12 or equivalent qualification.
The FSCA engaged the CMS and confirmed that the CMS does not accept a registered skills programme of 30/60 credits as an equivalent to a grade 12 education. However, upon application and approval thereof, individuals who have only completed a skills programme and who do not possess a Grade 12 education may be exempted for a period of 2 years to allow them to complete a formal qualification.
Such formal qualification can be a qualification on NQF level 4 or higher NQF qualification, registered on the National Qualifications Framework (NQF) and therefore does not have to be a Grade 12 National certificate.
It is important to note that the exemption is not automatic and is subject to review on merits, and approval by the CMS. Brokers or applicants that have already been granted an exemption are advised to ensure that they complete a recognised formal qualification as soon as possible and within the allowed exemption period.