1ST December 2025
Honourable Chair and Members of the Committee,
Thank you for the opportunity to present concerns regarding the transition of the Teachers Service Commission (TSC) Medical Scheme from AON-Minet administration to the Social Health Authority (SHA). This transition has exposed significant systemic gaps that are now directly harming patients and constraining health service providers.
1. Background: Source of Truth on Facility Levels
Under the SHA Act, the Kenya Medical Practitioners and Dentists Council (KMPDC) is the statutory source of truth for the classification of health facility levels. Historically, several facilities—particularly inpatient nursing homes and rehabilitation centres—were correctly categorized as Level 3B by KMPDC, and this classification functioned seamlessly under NHIF.
In line with this structure, SHA contracted these facilities as Level 3B, as reflected in their valid KMPDC licences renewed in October 2024.
2. Sudden Recategorization and Resulting Contract Mismatch
In January 2025, KMPDC unilaterally recategorized several 3B facilities to Level 3A within its digital portal.
● This recategorization was not communicated to the affected facilities.
● It also contradicted the existing, valid KMPDC licences already issued.
● The Gazette Notice of 2021 clearly permitted Level 3B facilities to offer both outpatient and inpatient services—services they have legitimately been providing.
SHA subsequently flagged a “mismatch” between:
● The contracted level (3B), and
● The updated KMPDC portal level (3A).
SHA indicates that an addendum to correct the contract is required. However:
● No addendum has been issued.
● SHA now states it may only be available on 6th December 2025, long after the transition has already begun.
3. Impact on the Transition of Teachers to SHA
As of 1st December 2025, teachers were transitioned from AON-Minet/MAKL to SHA. SHA instructed facilities to discharge all TSC patients from the old system and readmit them under the SHA system. However, the SHA portal rejects these admissions with the message: “FACILITY OUT OF PANEL FOR MWALIMU MEDICAL COVER.” This rejection is due to the unresolved level mismatch.
When providers escalate the issue:
● The DHA team insists that KMPDC must correct the levels.
● Providers are told that SHA simply “consumes data” from the regulator.
● Meanwhile, no solution is offered for patients already under care.
SHA has even suggested that affected providers transfer their teacher-patients elsewhere, despite:
● Patients being in the middle of essential treatment, including for alcohol and substance use rehabilitation.
● Providers having already offered care under SHA—without payment to date.
This approach undermines continuity of care, disrupts clinical outcomes, and punishes facilities for an error not caused by them.
4. Consequences
1. Patients are stranded, unable to be admitted in the SHA system.
2. Continuity of care is broken, especially for vulnerable rehabilitation clients.
3. Providers face financial strain, having provided services yet not been paid by SHA.
4. Mental stress among providers is escalating, as they bear the consequences of regulatory misalignment.
5. The transition process appears poorly planned, poorly communicated, and operationally disruptive.
This situation is unfair, unjust, and preventable.
5. Request to the Parliamentary Committee on Health
We respectfully urge the Committee to intervene and ensure that SHA, KMPDC, and DHA resolve this mismatch without penalizing patients or providers. These issues represent systemic weaknesses in transition planning, regulatory coordination, and contractual integrity. Moreover, despite being level 3 facilities they are treating inpatients. Unfortunately SHA has chosen to classify them as “Primary Healthcare” and hence have not received payments of services already rendered. This urgent anomaly must be rectified.
6. Suggested Way Forward
1. Immediate issuance of the SHA contract addendum to all affected facilities to legally align their contracted level with their KMPDC licence.
2. Immediate reopening of the Mwalimu Medical Cover portal for these facilities to allow admission and continuation of care.
3. Development of a structured, well-planned transition framework for future scheme handovers to prevent recurrence of such disruptions.
4. Settlement of all outstanding payments owed to providers by SHA to sustain service delivery and maintain provider confidence.
5. Pay the level 3 inpatient health providers.
Honourable Members, the health facilities are committed to serving teachers and all Kenyans. What they ask for is fairness, regulatory coherence, and systems that support—not hinder—patient care.
Thank you
Dr Simon Kigondu is an Obstetrician Gynaecologists and the President of Kenya Medical Association