| PROPOSED PROVISION FOR AMENDMENT | PROPOSED AMENDMENT | OUR COMMENTS |
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| PART I-PRELIMINARY | ||
| Regulation 2 Interpretation | “biometric” means a unique identifier or attribute including a fingerprint, hand geometry, earlobe geometry, retina or iris pattern, voice wave, in a digital form. | Biometrics provide a highly accurate and reliable way of individual identification that’s superior to traditional modes of identification like use of identification cards, which can be stolen or forged. |
| “chronic illness” means a cardiovascular disease, cancer, diabetes, obesity, respiratory disease, mental health condition, neurological condition, hemoglobinopathies, haemophilia, bleeding disorder, epilepsy, auto immune disease, renal disease, skin condition, degenerative joint and spine condition, osteoporosis, or an oral disease or condition that requires ongoing medical attention. | The definition has been provided to apply to patients who require ongoing treatment to control symptoms, prevent complications and maintain quality of life. Secondly, this definition has been provided as patients with chronic illnesses will have an unlimited NHIF cover. We propose the addition of the words “any other” immediately before the words “medical condition”. |
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| “emergency treatment” refers to necessary immediate health care that must be administered to prevent death or worsening of a medical situation. | We propose the deletion of this definition. This definition has not been used in the National Health Insurance Fund Regulations, 2023 (“the Regulations”). |
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| “income” means the income described in regulation………. | This definition is ambiguous. We propose that a full definition of the term be provided to enhance clarity. |
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| We propose the addition of the definition of “a contracted health care provider”. | The term has been used in the Regulations without a definition being provided. |
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| Regulation 3 Objects of the Regulations | The objects of the Regulations are to: a. ensure that every person who has attained the age of eighteen years and resident in Kenya is registered as a contributor of the Fund; b. prescribe the mode of identification of beneficiaries; c. set out the criteria and procedure for empanelment and contracting of healthcare providers; d. ensure that the public can access health services from qualified and licensed healthcare providers; and e. set out the criteria for payment of claims under the Act. | Objects outline the goals or aims that the Regulations seeks to achieve. By clearly stating the objects of the Regulations, it helps in interpreting and understanding its provisions. To conclude, objects ensure that the Regulations are effectively implemented, applied consistently and aligned with their intended purposes. |
| PART II- REGISTRATION OF CONTRIBUTORS AND BENEFICIARIES | ||
| Regulation 4 Registration to the Fund | A person who meets the criteria under section 15 of the Act shall apply for registration as a contributor to the Fund. An application for registration under paragraph (1) shall be made in the form set out in the Schedule and accompanied by: a. a copy of the document bearing the national identification number of the applicant; and b. proof of income, if any. Where the application made under paragraph (2) is approved, the Board shall register a successful applicant as a contributor to the Fund and issue a registration number thereof. A successful applicant under paragraph (3) shall provide his or her biometric data to the Board at the nearest service point. Where the application does not meet the requirements by the Board, the Board shall inform the applicant to provide any missing documents or to clarify any erroneous information on the application. | This regulation is silent on the mode of communication for rejected applications. Secondly, a prescribed period for the Board to review the application to become a contributor of the National Health Insurance Fund (“NHIF”) has not been included. We propose a period of fourteen (14) business days for the Board to review the application. Addition of a prescribed period hastens the process as a successful applicant can use the NHIF cover within a reasonable period. Furthermore, absence of a prescribed period leads to applications being reviewed several months after they’re submitted. This may cause delays and further health complications on the applicant who is awaiting treatment. |
| This regulation is silent on the mode of registration. Is it physical or virtual? We propose that registration is done online through the NHIF Portal. Online registration allows applicants to register for NHIF at the comfort of their homes or workplace, at any time of the day. Secondly, online registration eliminates the need for printing and reduces the staff time required to process those forms. |
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Regulation 5 Registration of beneficiaries | A contributor may include a beneficiary to access a benefit in his or her cover. The contributor seeking to include a beneficiary under the cover shall make an application: a. in the form set out in the Schedule; b. accompanied by the following identification document of the beneficiary: i. in the case of the spouse of the contributor, the spouse’s national identification document and a copy of a certificate of marriage issued under the Marriage Act; ii. in the case of a child of a contributor, who is below six months, a birth certificate or birth notification; iii. in the case of a child of a contributor who is six months of age and above, a birth certificate; iv. in the case of an adopted child of a contributor, a copy of an adoption order; v. in the case of a child for whom the contributor stands in loco parentis, a will, deed or court order; vi. in the case of a person living with a disability and is wholly dependent on a contributor, a national identification number and disability certificate from the National Council of Persons living with Disabilities; vii. in the case of a resident foreign citizen an alien identification card; or viii. in the case of a refugee, a refugee identification card issued under the Refugees Act. | Sub-regulation (2) is silent on the entity responsible for reviewing an application to include a beneficiary under the contributor’s NHIF cover. We propose giving this power to the Board. This regulation is silent on the mode of registration. Is it done physically or online? The period for reviewing the application to include a beneficiary under the NHIF cover has not been provided. We propose a period of fifteen (15) business days. |
| Regulation 6 Access to national database | The Fund shall utilize the existing National Population Data bases linkages for purposes of mobilising registration to the Fund. | The National Population Data base will be mainly used for identity verification of NHIF members. |
| Regulation 7 Amendment of beneficiary details | A contributor may amend the details of a spouse as a beneficiary by submitting to the Fund the amendment Form set out in Second Schedule. A contributor who requests for an amendment referred to in paragraph (1) shall provide the following: a. in the case of a divorce, a divorce decree; b. in the case of death, a death certificate; c. a decree declaring the presumption of the death of a spouse; d. a decree of annulment; e. a decree of divorce or annulment obtained in a foreign country and recognized in Kenya under the Marriage Act; or f. any other documentation approved by the Board. | This regulation has not indicated the person/entity that will review the request by a contributor to amend the details of a beneficiary. We propose that the Board is given power to amend the details of a beneficiary. It’s necessary to incorporate this proposal as the Board is responsible for reviewing a contributor’s application to become a member of the scheme. For sub-regulation (1), we propose the addition of the word “the” immediately before the word “Second”. |
| The sub-heading is ambiguous as it deals with the amendment of the details of a spouse who is a beneficiary of the contributor. We propose that the sub-heading is changed to, “Amendment of the beneficiary details of a spouse.” Incorporating this change enhance will clarity. |
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| Regulation 8 Deregistration of contributor | The Fund shall deregister a person as a contributor upon the death of the person. The Fund shall reallocate contributions for a deregistered person to the surviving spouse who is a declared beneficiary. Where a deregistered person has no surviving spouse and has pre-paid contributions, the beneficiaries shall continue to access benefits until the end of the period for which the contributions have been paid. | The power to deregister a contributor has not been provided for in the NHIF Act. Therefore, the Regulations conflict with the provisions of the NHIF Act. It is well recognized that an instrument of subsidiary legislation cannot override the provisions of an Act of Parliament. This was the sentiment of the Supreme Court in Evans Odhiambo Kidero & 4 Others v Ferdinand Ndungu Waititu & 4 others [2014] eKLR. Therefore, an amendment of the NHIF Act would be necessary to incorporate the proposed change in this regulation. Lastly, we propose the addition of the word “a” immediately before the word “contributor” in the sub-heading of this regulation. |
| PART III-CONTRIBUTIONS OF THE FUND | ||
| Regulation 9 Contributors of the Fund | Pursuant to section 15 of the Act, the following persons shall be liable as contributors to the Fund: a. a person who derives an income from salaried employment; b. a self-employed person who meets the criteria set out in section 15(1) of the Act; c. the National Government on behalf of indigent and vulnerable persons as provided under section 15(1B); and d. a person who is not employed or listed as an indigent person or vulnerable person. | This regulation proposes that unemployed persons should be mandated to contribute to the NHIF scheme. An unemployed person will be unable to pay the contributions as he/she does not have a source of income. |
| Regulation10 Standard contribution | A contributor in salaried employment shall pay a standard contribution at a rate of 2.75% of the gross monthly income derived from employment in the preceding month. | The proposed 2.75% of a contributor’s gross monthly income is too high. The Regulations are silent on whether the increase in monthly contributions will lead to additional services being included in the NHIF medical cover. Secondly, increasing the monthly contributions will lead to members defaulting on monthly payments. We propose that the Regulations provide a list of the additional benefits added to the NHIF scheme. If no new services are added, it’s not prudent to increase the monthly NHIF contributions. |
| Regulation 11 Contribution by self-employed person | A contributor in self-employment shall pay a special contribution to the Fund at a rate of 2.75% of the declared or assessed gross monthly income of the contributor. A contributor shall pay three hundred shillings (KES 300) where the amount in paragraph (1) is less than three hundred shillings KES 300). In determining the income upon which a contribution is applicable, the Board may require the contributor to avail such evidence and documentation as the Board may consider necessary. | This is an increase from the current contributions made by a self-employed person. Currently, a self-employed member is required to make a monthly contribution of KES 500. Increasing this amount will lead to existing NHIF members defaulting on the monthly payments. Consequently, this will lead to an increase in the number of dormant members. For sub-regulation (2), we propose the deletion of the word “paragraph” and replacing it with the word “sub-regulation”. For the sub-heading of this regulation, we propose the addition of the word “a” immediately before the word “self-employed”. |
| Regulation 12 Contributions for indigent and vulnerable persons | The state department responsible for social protection shall submit to the Board a list of the indigent and vulnerable persons for whom the National Government is liable as a contributor. Upon receipt of the list under paragraph (1), the Board shall notify the persons listed thereto that they are eligible as beneficiaries of the Fund. The amount payable by the National Government on behalf of indigent and vulnerable persons shall be thirteen thousand and three hundred shillings (KES 13300) | The Regulations has not provided a definition for an indigent and vulnerable person. We propose that a definition be provided for in Regulation 2. |
| Sub-regulation (3) is ambiguous as it has not stated whether the KES 13,300 contribution will be paid on a monthly, quarterly or annual basis. | ||
| For sub-regulation (2). The period for the Board to notify an indigent and vulnerable person on the list of indigent and vulnerable persons has not been provided. We propose a prescribed period of fourteen (14) days. | ||
| For sub-regulation (2), we propose the deletion of the word “paragraph” and replacing it with the word “sub-regulation”. |
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| Regulation 13 Other contributors | A contributor who is not employed or listed as an indigent person or vulnerable person shall pay a monthly contribution of one thousand shillings. | This proposal will lead to NHIF members defaulting on the monthly payments. In the year ended June 2022, NHIF reported that out of 15.4 million members, 8.8 million were dormant members. This infringes on the right to affordable health care which is provided for under article 43 of the Constitution. Consequently, we propose the deletion of this regulation. |
| Regulation 14 Obligations of an employer | An employer shall deduct the contribution of a salaried employed contributor and submit it to the Fund on behalf of the employee. Where an employer terminates the employment of a contributor, the employer shall notify the Fund within thirty days thereof. The obligations of an employer in relation to a contributor whose services have been terminated shall cease immediately the Fund receives the notification referred to in paragraph (2). | For sub-regulation (3), we propose the deletion of the word “paragraph” and replacing it with the word “sub-regulation”. |
| Regulation 15 Remission of contribution | Any contribution under the Regulations shall be remitted to the Fund on or before the ninth day of the succeeding month. | A NHIF member will incur penalties if he/she fails to make payments before the prescribed date. |
| Regulation 17 Statement of account | A contributor may obtain a statement of account by submitting a written or electronic request to the Board. The Board shall promptly respond to the request and provide the statement indicating the following details: a. the status of the contributions; | Sub-regulation (2) is incomplete. The addition of the missing information will provide clarity on the contents of this regulation. |
| Secondly, the period for the Board to respond to the request for a statement of account has not been included. We propose a maximum period of seven (7) business days. A prescribed period ensures that actions are completed in a timely and efficient manner. |
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| A template requesting for a statement of account has not been provided in the Regulations. We propose that a template be added to the Regulations. A template provides a standard format that is easy to understand and use. Furthermore, the use of a template enhances uniformity. |
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| PART IV- ACCESS TO BENEFITS BY CONTRIBUTOR AND BENEFICIARIES | ||
| Regulation 18 Access to benefits | A contributor or beneficiary shall access a benefit of the Fund sixty days from the date of registration. | The sixty (60) days’ waiting period is too long. We propose a waiting period of thirty (30) days. Currently, the waiting period before accessing the NHIF cover is ninety (90) days. The Regulations propose to reduce the waiting period to sixty (60) days. During the waiting period, an applicant cannot use the NHIF cover. The Board should incorporate the use of Information & Communications Technology, which will accelerate the review process and reduce the waiting period. |
| Regulation 21 Non-withdrawal of benefits in relation to chronic illness | A beneficiary suffering from a chronic illness shall, upon exhaustion of his or her benefit limits, access treatment for the chronic illness from a public health care provider subject to the applicable benefits package. A beneficiary referred to in paragraph (1) shall access treatment for the chronic illness if there are no arrears in the contributions in favour of the beneficiary. | This is a good proposal. It will allow patients with chronic illnesses to have unlimited NHIF cover. Previously, once a patient with a chronic illness exhausted his NHIF cover, he had to resort to using his own money to fund the treatment. However, private hospitals are refusing to treat patients with NHIF covers. This is because NHIF is yet to pay outstanding claims to the private hospitals. This leads to patients using their personal money to fund their treatment even though they are NHIF members who pay the monthly contributions. In the People’s Daily newspaper dated 16th May 2023, NHIF indicated that it will deregister hospitals that turn away NHIF members due to payment defaults. |
| For sub-regulation (2), we propose the deletion of the word “paragraph” and replacing it with the word “sub-regulation”. | ||
| Regulation 22 Claims outside Kenya | A beneficiary who wishes to access a health service outside Kenya shall request for authorization from the Board to access the health service in Form NHIF 001 set out in the First Schedule of the Regulations. The request in paragraph (1) shall be accompanied by the following: a. a referral letter from the treating doctor or consultant; b. a duly filled form prescribed under the Medical Practitioners and Dentists Act; and c. a letter of no objection from the Director-General for Health. The Board shall consider the request for authorization of treatment outside Kenya to verify that the health service requested for authorization is not available within Kenya. Where the Board is satisfied that the health care service is not available for the beneficiary, the Board shall authorize treatment of beneficiary outside Kenya. | In sub-regulation (3), no period has been provided for the Board to consider the request for authorization of treatment outside Kenya. We propose a period of seven (7) business days. A prescribed period should be provided as it will mandate the Board to review the application within a certain timeframe. This allows a patient to receive treatment within a reasonable period to prevent further health complications. |
| Secondly, the Regulations have not provided a list of foreign hospitals that accept the use of NHIF. We propose that a list of foreign hospitals that accept NHIF as an insurance cover be provided in the Schedule of the Regulations and the NHIF website. Inclusion of the list prevents instances where a patient seeks treatment abroad and the hospital does not accept NHIF as a mode of payment. |
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| For sub-regulation (2), we propose the deletion of the word “paragraph” and replacing it with the word “sub-regulation”. | ||
Regulation 23 Eligibility for overseas Treatment | Overseas treatment may be accessed by a beneficiary if there are no arrears in the contributions in favour of the beneficiary. | We propose the addition of a sub-regulation that states as follows: “A patient who seeks to receive overseas treatment shall fill a referral form that’s annexed to the Schedule of the Regulations.” |
| We propose the deletion of the words “Overseas treatment may be accessed by a beneficiary” and replacing it with the words “A beneficiary may access overseas treatment”. This proposal will enhance clarity of this regulation. |
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| For the sub-heading of this regulation, we propose that the word “Treatment” starts with a small letter. |
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| PART V – EMPANELMENT | ||
| Regulation 24 Empanelment | No benefit shall be payable to a healthcare provider that is not empanelled and contracted by the Board. The Board shall empanel health care providers only three times in a year. | Regulation 24 does not contain an offence. We propose making it an offence punishable upon conviction by a fine of up to KES 1 million or to a jail term of up to six (6) months if benefits are paid to a non-empaneled healthcare provider. The inclusion of an offence will act as a deterrence on non-empaneled healthcare providers that receive benefits. |
| Regulation 25 Application for empanelment | A health care provider seeking empanelment under the Act shall make an application to the Board in Form A set out in the Schedule and accompanied by the following documents: a. a copy of the certificate of registration and a valid license issued by the relevant regulatory body referred to in section 60 of the Health Act; b. a certificate of registration of business name or certificate of incorporation, where applicable; c. a certified copy of CR 12 for facilities with certificate of incorporation or CR 13 for facilities with certificate Business registration, where applicable; d. a certificate of change of name applicable to facilities requesting for change their name, where applicable; e. a tax compliance certificate issued by Kenya Revenue Authority; and f. a certificate of compliance issued by the National Health Insurance Fund. | This regulation is silent on the mode of application for empanelment. Is it physical or online? Secondly, this regulation is silent on the mode of communication for rejected applications. |
Regulation 26 Processing of application | Upon receipt of the application for empanelment under regulation 21, the Board shall review the application and make a decision within one hundred and twenty days of receipt of the application. Where the application is approved, the Board, in consultation with the relevant regulatory bodies specified in section 60 of the Health Act, shall empanel a healthcare provider. Upon the publication of an empanelled health care provider in the gazette under section 30 of the Act, the Board may contract the health care provider within thirty days of the date of the publication. | This regulation is silent on the mode of communication for rejected applications. |
| Sub-regulation (3) does not provide for the publication of a newly empaneled healthcare provider in a newspaper of national circulation. We propose that publication of an empaneled health care provider be done in both the Kenya Gazette and a newspaper of national circulation. National newspapers have a vast readership, which means that publishing information can help reach a wider audience. |
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Regulation 27 On boarding in the system | Where a health care provider is empanelled and contracted in accordance with the Act and the Regulations, the healthcare provider shall be on boarded into the Centralised Healthcare Provider Management System (“the system”). | On boarding of healthcare providers has several benefits, including streamlined administrative processes and efficient network management. These benefits ultimately contribute to improved patient satisfaction and overall quality of health care. |
Regulation 28 Inspection | The Board shall, at least once every year, inspect every contracted healthcare provider to ensure compliance with the provisions of the Act and the Regulations. | Inspections are conducted to identify potential risks or hazards that could compromise the patients’ well-being. Inspections identify deficiencies or non-compliance issues that health care providers are yet to implement. |
Regulation 29 Revocation of empanelment | The Board shall revoke the empanelment of a healthcare provider where it is established by the Fund that the healthcare provider: a. billed for a procedure that is not required by a beneficiary; b. billed for a procedure that is not covered within the level of care of the health care provider; c. billed for a procedure that is not within the scope of professional practice of the health care provider; d. billed a patient for services and medicine not provided; e. falsified or alters any information with intent to defraud the Fund; or f. submitted separate claims to the Fund for services that are to be contained in a single claim. | We propose changing the sub-heading to, “Revocation or suspension of empanelment”. |
Secondly, we propose the addition of the words “or suspend” immediately before the words “the empanelment”. Inclusion of these proposals will streamline the Regulations to be in line with regulation 37(b). Regulation 37(b) deals with the payment of claims by the Board arising from any revoked or suspended healthcare provider. |
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| Regulation 32 Obligations of a health care provider | An empaneled and contracted health care provider shall: a. ensure that quality and safe health services are provided; b. assess and review health services; c. improve the quality and safety of the health services provided; d. establish and maintain the necessary infrastructure for purposes of linking the administration of benefits and submitting claims to the system; e. maintain accurate and orderly medical records for the beneficiaries in respect to services provided; and f. prepare a statement containing information in relation to claims for any health care services rendered. | Listing of obligations provides clarity regarding the responsibilities of a health care provider. Clear obligations leave little room for ambiguity, ensuring that individuals understand what actions are accepted or prohibited. |
| PART VI- CLAIMS AND BENEFITS | ||
Regulation 33 Benefits payable | The Board may, in respect of a health service provided under the Act, pay benefits to: a. an empaneled and contracted health care provider within or outside Kenya; and b. any health care provider who has been authorized to undertake emergency services. All benefits payable shall be for an active beneficiary of the Fund. | For sub-regulation (1)(b), the entity responsible for authorizing a health care provider to undertake emergency services has not been stated. We propose giving this power to the Board. |
Regulation 34 Lodging of claims | A contracted health care provider shall lodge a claim to the Board for the payment of any health care service rendered to a beneficiary under the Act. The claim under sub-regulation (1) shall be submitted to the Board, in the manner determined by the Board indicating the following: a. the valid patient's hospital registration number; b. the patient's name, address, date of birth and gender; c. the name and contact details of the beneficiary; d. relevant clinical details of the patient; and e. amount claimed. A health care provider shall submit to the Board a claim for payment of any medical treatment within seven (7) days from the date of discharge of the patient from the health care provider. The Board may require a health care provider who has submitted a claim under paragraph (3) to provide, in the manner determined by the Board, any further information in respect of the claim. | The prescribed period for the Board to review the claim has not been stated. We propose a prescribed period of fourteen (14) days. For sub-regulation (4), we propose the deletion of the word “paragraph” and replacing it with the word “sub-regulation”. |
| Regulation 35 | The Board shall pay for a claim arising out of health services rendered to a beneficiary if there are no arrears in the contributions in favour of the beneficiary. The Board shall pay claims for health care services through the System established pursuant to section 21A of the Act. | The sub-heading for this regulation has not been provided. We propose that the sub-heading be, “Payment of claims”. A sub-heading coveys the contents of a legislation. |
Regulation 36 Adjustment of claim | The Board may review and make an adjustment if a health care provider has received any payment from the Board with respect to a claim or claims and the health care provider subsequently requests an adjustment to be made where there is an error in respect of the amount paid. | A template requesting for adjustment of a claim has not been included in the Schedule. We propose that a template be added to the Schedule of the Regulations. Regulation 36 implies that an adjustment can only be made upon the request of a health care provider. It is very unlikely that a health care provider will request for an adjustment in the event an overpayment has been made to the health care provider’s account. |
| Regulation 38 Claims outside Kenya | A beneficiary who wishes to access a health service outside Kenya shall request for authorization from the Board to access the health service in Form NHIF 001 set out in the First Schedule to these Regulations. The request in paragraph (1) shall be accompanied by the following: a. a referral letter from the treating doctor or consultant; b. a duly filled form prescribed under the Medical Practitioners and Dentists Act; and c. a letter of no objection from the Director-General Health. The Board shall consider the request for authorization of treatment outside Kenya to verify that the health service requested for authorization is not available within Kenya. Where the Board is satisfied that the health care service is not available for the beneficiary, the Board shall authorize treatment of beneficiary outside Kenya. | Regulation 38 is a repetition of regulation 22. We propose the deletion of regulation 38 as it’s a repetition of regulation 22. Deletion of regulation 38 streamlines the Regulations and enhances clarity. |
PART VII— CENTRALIZED HEALTH CARE PROVIDER MANAGEMENT SYSTEM |
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Regulation 40 Centralized Health Care Provider Management System | The system shall be accessible to the contracted health care provider for purposes of: a. claims administration; b. recording beneficiaries’ data; c. inputting health care service delivery data; and d. maintaining health care providers’ data. The Board shall review access rights granted under sub-regulation (1) in line with the provisions of the Data Protection Act. The review referred to in sub-regulation (2) shall be with respect to: a. access and processing of data including who can access the system and at what point; b. transmission to third parties including how third parties handle the information they access and the purposes for which they can access data; c. use of data including commercial, research and advertising; and d. amendment of data. The Board shall review access rights granted under sub-regulation (1) in line with the provisions of the Data Protection Act. The review referred to in sub-regulation (2) shall be with respect to: a. access and processing of data including who can access the system and at what point; b. transmission to third parties including how third parties handle the information they access and the purposes for which they can access data; c. use of data including commercial, research and advertising; and d. amendment of data. | The system allows for the consolidation of various administrative and operational functions. By centralizing these processes, healthcare providers reduce administrative overhead and streamline operations. Furthermore, using the System allows health care providers to optimize their resources and provide high quality services. |
Regulation 41 Access by other persons | A person who wishes to access the system shall apply to the Board for rights of access in line with the provisions of the Data Protection Act. | This ensures that unauthorized people do not access the system. Unauthorized access can compromise the security of confidential information stored within the system. |
Regulation 42 User obligations | A person who has been granted access into the system by the Board shall: a. carry out such transactions as authorized; b. be responsible for the security of the transactions carried out in the system. | We propose making it an offence if a person (who has been granted access to the system) uses the system in a manner that was not intended. We propose a fine of KES 1 million or imprisonment of a term not exceeding one year, or to both. |
Regulation 43 System upgrade and update | The Board shall update and upgrade the system on a regular basis in order to: a. address the prevailing technological changes; b. maintain the system; and c. review security flaws and patches. | Updating the system regularly: a. removes bugs that affect performance or cause crashes; b. provides performance enhancements which increases the speed and performance of the System; and c. ensures you have the latest security measures in place. This reduces the risk of data breaches. |
| For sub-regulation (2), we propose the deletion of the word “paragraph” and replacing it with the word “sub-regulation”. | ||
Regulation 44 | The system shall encrypt all information during transmission to ensure data protection and safety. | The sub-heading for this regulation has not been provided. We propose that the sub-heading be, “Encryption of information.” A sub-heading coveys the contents of a legislation. |