What a scheme may pay an accredited healthcare broker from 1 January 2026, what that fee buys, and how a member can switch it off in one message.
Of everything a South African brokerage earns, the healthcare fee is the strangest. It is the same amount every month, it is capped in rands rather than as a share of the contribution, and the member can stop it with a single sentence to the scheme — no clawback, no dispute, no notice period. That combination makes a medical scheme book the purest retention business in the firm, and the one most often left to run itself between one January and the next.
Regulation 28(2) of the Medical Schemes Act 131 of 1998 caps what a scheme may pay a broker for introducing a member and for servicing that member afterwards. From 1 January 2026, on contributions received by the scheme, the maximum is the lesser of R125.86 plus VAT per member per month, or 3% plus VAT of the contributions payable in respect of that member. The rand figure is adjusted annually by the Minister of Health in the Government Gazette; the 2026 amount appeared in Notice 7028 of Government Gazette 54019 on 27 January 2026, up from R121.84 the year before.
The “whichever is the lesser” wording is what most fee queries turn on. Three per cent of a contribution only reaches R125.86 at a contribution of roughly R4 195 a month, so the percentage governs the lower end of the book and the rand cap governs everything above it.
| Member’s monthly contribution | 3% of contribution | Rand cap | Maximum payable (excl. VAT) |
|---|---|---|---|
| R1 500 | R45.00 | R125.86 | R45.00 — the percentage applies |
| R2 500 | R75.00 | R125.86 | R75.00 — the percentage applies |
| R4 195 | R125.85 | R125.86 | About R125.85 — the crossover |
| R6 000 | R180.00 | R125.86 | R125.86 — the cap applies |
| R12 000 | R360.00 | R125.86 | R125.86 — the cap applies |
Two consequences follow. A family paying R12 000 a month is worth no more to you than a single member on R4 200, so the economics of a healthcare book are driven by how many principal members you retain rather than by how much they contribute. And that one fee is meant to cover both the introduction or admission of the member and, in the Council for Medical Schemes’ own words, ongoing support in respect of the benefits or services the scheme offers. Members pay nothing extra for that unless they have agreed in writing to additional services. This is a different statute and a different regulator from the commission rules on your short-term book — worth reading next to commission caps and fee agreements under the Short-term Insurance Act, because clients mix the two up inside a single conversation.
Section 65 of the Act is blunt: no person may act or offer to act as a broker unless the Council for Medical Schemes has granted accreditation and the prescribed fees are paid. In practice that is two accreditations rather than one. The brokerage is accredited as an organisation, and every adviser who deals with health service benefits is accredited as an individual. A scheme is not permitted to compensate an unaccredited broker, which is why an accreditation lapse and a fee query tend to arrive in the same week.
Accreditation sits on top of the FAIS requirements, it does not replace them. Health Service Benefits is its own product subcategory under the FAIS Act, so the adviser needs that subcategory on the licence or the representative register as well as the CMS accreditation. On the CMS side, applicants meet fit and proper requirements including a Grade 12 National Certificate or an equivalent qualification at NQF level 4 — verified through Managed Integrity Evaluation rather than by affidavit — and produce written references from medical schemes confirming two years of relevant experience. With less than two years, the CMS lists the person as an apprentice advisor until they can apply for full accreditation.
The failure point is rarely the first application. It is the renewal calendar and the internal register: accreditation is annual and fee-bearing, an adviser’s status can change without anyone in the firm noticing, and an unaccredited adviser servicing members is an income problem before it is a compliance problem.
A scheme must immediately discontinue payment to a broker in respect of a particular member once it receives notice from that member — or from the relevant employer, in the case of an employer group — that the broker’s services are no longer required. And only the member, or the employer for an employer group, may appoint or replace a broker. Nobody else can move a book on the members’ behalf.
Read that against how the rest of your income behaves. An early-duration lapse on risk business triggers a commission clawback you can see coming and sometimes argue about. Regulation 28(7) has no equivalent. The fee simply stops at the end of the month, usually without anyone telling you why, and often after a member has spent an open season talking to someone else. The only signal most firms get is the scheme’s next fee schedule — which is the worst early-warning system available, because it reports the loss once it is already complete.
Underwriting is what makes option-change advice risky rather than routine. A scheme may impose a three-month general waiting period and a twelve-month condition-specific waiting period, and late-joiner penalties apply to people who join after the age of 35 without prior continuous cover. Moving a member between options inside one scheme is usually harmless; moving a member to a different scheme can restart waiting periods and strand a condition that was previously covered. That is a suitability conversation with a written record attached, not a thumbs-up in a chat.
Because the fee is flat and monthly, the servicing has to be cheap to repeat and easy to prove. A healthcare book splits cleanly by scheme, by option, by employer group, and by the members nobody has spoken to since the last open season — and that last group is the one that leaves. In ORIS those filters build a saved segment from the customer records, and a Quick Campaign sends the same check-in to all of them from a template Meta has already approved, with opt-in re-checked at send time rather than only when the audience was built.
The replies then have to land somewhere the whole firm can see. A shared inbox means an option question asked on a Saturday reaches the adviser who is actually accredited for health service benefits instead of sitting on one consultant’s phone, and the classification of incoming messages surfaces the ones that read like a member shopping around — which is the only warning you will get before Regulation 28(7) does its work. Where an adviser wants help with the wording, ORIS suggests a draft and a person sends it; that is the only sensible arrangement when the answer could amount to advice about a waiting period.
Then the record. An option change agreed in chat still needs the reasons, the alternatives considered and the member’s decision on file — see how to build a record of advice when the sale happened on WhatsApp. Conversations sit under the client record with audit logs, and customer and campaign data export to CSV for the compliance file or a scheme’s query. If you also write risk cover for the same households, the annual check-in is the natural moment to review it: our health cover cross-sell walkthrough covers that conversation.
Only for services beyond the ordinary broker service, and only where the member has agreed to it in writing. The capped amount is already meant to pay for both the introduction and the ongoing support, so a fee for answering benefit questions or handling an option change is not an additional service. Where you do agree one, document what it buys and keep it separate from anything the scheme pays you.
The fee is paid by the scheme, not billed to the member, and members pay nothing extra for having a broker. Regulation 28 caps the amount the scheme may pay per member per month, which is why the member sees no line item and often assumes the service is free. Explaining who pays you, and for what, is a better answer than deflecting the question.
Every individual who deals with health service benefits needs individual accreditation, and the firm needs to be accredited as an organisation. An adviser who only writes short-term business does not, but the moment they answer a member’s question about scheme benefits they are in the wrong lane — which is an argument for routing healthcare conversations to named, accredited users rather than letting anyone in the inbox reply.
Immediately on the scheme receiving the member’s notice, in respect of that member. There is no notice period to run and nothing to appeal, so the recovery conversation has to happen before the member writes to the scheme, not after. In practice the fee schedule is where most firms discover the loss, weeks later.
For an employer group, the relevant employer may appoint or replace the broker and may also give the scheme notice that the services are no longer required. Outside that arrangement, the choice belongs to the individual member, and an appointment collected by anyone other than the member or the employer will not hold.
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