On the 2^nd of February approved at the session of the Government of RA “On Approving The Concept Of Introduction Of Comprehensive Health Insurance (CHI)” the decision of the Government of RA (the Concept) contains a large amount of theoretical information, that does not completely justify most of the considered issues, despite the many topic discussions held in 2022 and conceptual suggestions presented by the business community.

The opinion of business associations about the above-mentioned document is the following:

1. Only after improvements aimed at increasing the efficiency of the HealthCare System of RA, it can be possible to invest the comprehensive health insurance effectively and provide the harmonious implementation of rights and responsibilities for each member of society.
2. Despite the policy of tax burden optimization announced by the Government of RA, in fact, the increasing tax burden on the citizens and businesses is taking place. This makes uncertainty and unpredictability rise in the circle of businessmen.
3. Essentially the investment of the new tax type also contains risks for the shadow economy increasing with all its side effects.
4. The name of the concept “Comprehensive Health Insurance” does not correspond to the context, because in the presented concept, in fact, the social safety system is described. And according to the Constitution of RA, the insurance activity is subjected to licensing, as well as relevant control by the Central Bank of RA.

1. CHI funds collecting, defining the amount of payment and spending will be implemented by one body: the Foundation, whose management Board President is the Minister of Health of RA. Therefore, in the hands of the Minister of RA will be centered the policy and the implementation of all the functions. This deepens, even more, the corruption risks taking into account the conflict of interests.
2. Even the forms of reports about Foundation activity will be defined by the same managing Board.
3. The budget of the Foundation is out of the control of the Ministry of Finance of RA because it is suggested to reflect only the main indexes (planned revenues and expenditures, projected deficit/surplus, the share of administrative costs, etc.) in the State Budget of RA.
4. The activity of the Foundation is completely out of control because performance appraisal will be implemented by the Audit Chamber of the RA, and financial audits will be implemented by a well-known international audit company. Therefore, there will be no estimation of means of expenditures efficient and purposeful use.
5. In fact, according to the concept it ignores the insured person’s right to choose the licensed medical facility, without restrictions applied to the latter.
6. Institutionally, the CMTPLI (Compulsory Motor Third-Party Liability Insurance) system is suggested to be applied, which is an established example of state-private sector productive collaboration.

Thus, we consider it necessary to highlight the following:

• It is important to exclude the monopolization of functions and services of the private sector by the state.
• A worrying tendency is noticed, when in the name of creating effective regulation/field the state changes any function from the private sector into the public sector.
• We note that the discussions with the private sector are purely formal in nature, ignoring the opinions and justifications expressed by the business community, and the Ministry of Health of RA continues its non-transparent way of working.