Deputy Chairperson of IFAF Buti Sigasa
By Buti Sigasa
Deputy Chairperson of IFAF
The Independent Financial Advisors Forum (“IFAF”) is disturbed that the City of Tshwane (“CoT”) is proceeding with its irregular and unlawful tender for the appointment of a single medical aid brokerage firm, for CoT employees.
Last month, IFAF raised the alarm over the CoT’s intention to tender for these services after the City published a notice to prospective bidders.
IFAF as a registered non-profit organization, which advocates for accredited healthcare brokerages and financial service providers, has a duty to expose any entity which seeks to undermine the legislation relating to medical aid brokerage services.
IFAF participated in the compulsory tender briefing which was held on the 26th of August 2025 at the CoT’s offices, and we noted that the majority of people objected to the tender, for the avoidance of doubt.
However, the CoT’s response is that whilst they note the objections, the status quo remains.
It seems evident that the City is determined to impose this broker, and one has to wonder if the City is doing this for the benefit of the brokerage firm that is to be appointed.
These are valid questions to ask given that we are witnessing a deliberate attempt to undermine due process.
If the City proceeds with the tender, this will be in gross violation of the inherent rights of the employees of the City who are members of medical aid Schemes.
IFAF has a duty to remind the City that it has no legal right to usurp the inherent rights of members.
Members are paying for medical aid brokerage services, and the contracts are between members and their respective medical aid schemes, and not the employer, (the CoT).
The employer is not the recipient of brokerage services, and therefore the employer has no right to impose its own broker onto members.
Furthermore, the CoT admitted that it has not consulted workers or unions, even as it prepares itself to subvert their rights through this process.
In addition, Regulation 28(7) of the Medical Schemes Act 131 of 1998, which has been reinforced by the Council for Medical Schemes’, makes it clear that individual members of medical aid schemes have the right to appoint their own broker.
This right supersedes any employer-driven procurement process and must be respected.
Therefore, the CoT is acting unlawfully if it insists on going ahead with this process.
The City supposedly has a stated commitment to empowering black entrepreneurs, however the current tender process threatens to undermine that very principle.
More than eight black women-owned brokerages currently serve over 14,000 City of Tshwane employees.
The proposed tender risks consolidating this service into a single large brokerage, potentially excluding historically disadvantaged providers and therefore in violation of section 12A(3)(e) of the Competition Act 89 of 1998, which promotes broader ownership and transformation.
We call on the City of Tshwane’s leadership to urgently review this process, uphold the law, and protect the rights of members, as well as black women-owned businesses.
This is not only a legal and transformation imperative, it is a moral one.