Sama raised many concerns and queries about unclear aspects in the 2018 draft Bill, and objected to many aspects proposed to be written into law. Examples include contracting and payment mechanisms which have never been implemented in the country before, as well as missing detail on quality of care expectations. There are also concerns about the amount of power which the Bill hands to the minister of health.

Sama ran a membership survey in November 2019 to gauge the feelings of its membership in relation to the Bill and the NHI proposals. It received 1,000 responses in the short two-week period in which the survey was open. Members do not think that a single fund is the only answer to securing universal health coverage for the population, and the membership is generally concerned about the lack of detail in contracting mechanisms, accreditation procedures and quality of care in general. The written responses indicate a deep mistrust of the government structures in general and the ability of the Department of Health to implement their plans in realising coverage for all.

Members agreed that the proposals for payment arrangements in the Bill are premature, and untested in the South African environment. Overall the Department of Health should pursue quality and finance improvement initiatives already proposed for the public and private sector before fundamentally changing the healthcare delivery system in the country.