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Circular 28 of 2024: Extension of Phase 2 submission – Demarcation Exemption Renewal Framework

The Council for Medical Schemes (CMS) would like to inform the industry of an extension to the deadline for the submission of information on insurers conducting the business of a medical scheme. Originally scheduled for 30 June 2024, the new deadline for Phase 2 is now set for 30 August 2024.

On 28 March, CMS issued Circular 16 of 2024, explaining the Exemption Renewal application process in two phases, with the Phase 1 submission due on 30 April 2024. Insurers submitted relevant information in Phase 1, but due to challenges in the healthcare utilisation IT system, CMS was unable to commence with Phase 2.

In light of this, insurers are required to submit their demarcation information manually as an interim measure. The submission period will run from 1 August 2024 up until 30 August 2024, and insurers are required to populate and submit the information within this timeframe.

It is important to note that this measure aims to give insurers additional time to compile and submit accurate information in accordance with regulatory requirements. The CMS acknowledges the complexities involved in gathering and verifying data pertinent to insurers and seeks to ensure that all stakeholders can effectively meet their obligations.

Phase 2 Submission Process

  1. Medical schemes are to access the demarcation specification document here.
  2. The specification document consists of 19 spreadsheets for insurers to upload information, called DM1 – DM 19.
    • The first sheet (colour-coded in red) DM (Number) with the last word SPEC, contains information that insurers can refer to for assistance and serves as a guideline .
    • The rest of the sheets, named “DM with the last number 2024,” contain information that the insurers should populate for us .

Any queries can be directed to demarcationrenewals@medicalschemes.co.za.


Exemptions are granted by Council in terms of section 8 (h) of the Medical Schemes Act 131 of 1998 (“MSA”). The Exemption Framework serves as a guide to facilitate the exemption application process for insurers who were providing primary health care products when the Demarcation Regulations came into effect in 2017, intended to protect the interest of the existing policyholders as at 31 March 2017, as a transitional measure. The Exemption Framework is therefore neither intended to amend, substitute nor to supplement section 8 (h) of the MSA. The Exemption Framework is also not intended to in anyway restrict or take away the right of any medical scheme or any person from applying for an exemption from complying with any provision of the MSA as provided for under section 8 (h). The CMS encourages everyone who intends to conduct the business of a medical scheme to register as a medical scheme and comply with the regulatory requirements.

Download the full Circular here.