Santo Domingo.- The president of the Dominican Medical College, Waldo Ariel Suero, announced that they, along with the Specialized Medical Societies, will appeal to the National Social Security Council (CNSS) for reconsideration of provisions in the Regulations on Infractions and Sanctions approved on February 15, 2024, through resolution 584-03.
Suero expressed suspicion regarding the regulations, pointing out that of the 37 infractions listed for the ARS/IDOPPRIL, only 6 are classified as serious, 15 as moderate, and 16 as minor. For the providers, out of the 28 listed, 9 are considered serious, 12 moderate, and only 7 mild. He suggested that this reflects a bias in favor of ARS/IDOPRIL, which operate as intermediaries in Social Security.
The regulations, developed by the Permanent Commission of Regulations of the CNSS, were prepared without representation from doctors and the CMD. Suero argued that the regulations include sanctions for Health Service Providers that directly impact the medical profession and health centers.
He criticized the lack of distinction between institutional providers (Health Centers) and Medical Professionals in the regulations, noting that they contain sanctions, including criminal ones and fines of up to 5.8 million pesos, without specifying who will receive the withheld money.
Suero argued that the regulations implicitly violate the right of Specialized Medical Societies and the Dominican Medical Association to initiate actions for collective claims for rate improvements and professional fees. The appeal contends that the regulations and the procedure for their approval violate due process, the right to collective claims, the right to participate in deliberations for administrative provisions, and the right to health recognized in the constitution’s article 61.