On August 28 the IRDAI's IAC Sub-Committee on Health Insurance held its third meeting of 2026 and put a familiar but consequential question on the table: what if more of the medical scrutiny that today happens after you file a claim happened before the policy is issued instead? The panel's press release frames it as stronger underwriting at the point of sale to reduce problems arising from inadequate disclosure, alongside incentives to push insurers and hospitals onto the National Health Claims Exchange, simpler policy wording, and published standard treatment guidelines and package rates. The membership matters to the signal: chaired by IRDAI Chairman Ajay Seth, with Member Deepak Sood, former NHA CEO Indu Bhushan, writer Monika Halan, and invitees including the CEOs of ICICI Lombard, Aditya Birla Health and Niva Bupa, plus World Bank and ADB experts as international advisers.
The Problem It Is Trying to Solve
The government told Parliament on August 4 that claim-related grievances accounted for 41% of all insurance complaints in FY26 - 1,23,654 complaints, of which 1,16,015 were resolved and 7,639 remained pending - and that general insurers carried the largest pendency into Q1 FY27. IRDAI's own FY26 grievance data via Bima Bharosa showed 2.97 lakh grievances, with health insurance the single largest driver. The regulator has also been publishing health insurance claim settlement data that allows apples-to-apples comparison across insurers, but settlement ratios alone can mislead: they hide absolute volumes. The panel explicitly said assessment should use settlement ratios plus absolute values. Its other notes point to the structural fix. Cashless authorisation was tightened to one hour and settlement to 30 days under the health master circular, but the upstream cause of many disputes is disclosure made in a two-minute proposal form that is later tested against a five-year medical history at claim stage. Moving diligence forward does not create a new obligation to disclose - the duty already exists - but it changes when the insurer is expected to verify it.
What Stronger Point-of-Sale Underwriting Would Actually Change
Method note: this section is BimaNiti analysis of the panel release text and current health underwriting practice, not a report of a notified regulation. No regulation requiring point-of-sale medical tests for all buyers has been issued.
In current practice, many retail health proposals up to Rs 10-20 lakh are issued on declaration without a medical test, with the insurer relying on the proposal form and, if needed, a tele-medical interview. Scrutiny of pre-existing disease, prior hospitalisation or chronic medication is deferred. The point-of-sale model would bring forward that scrutiny: a short health declaration linked to Aadhaar-based identity and, where the declared history or age triggers it, a medical examination or a targeted health record check before the risk is accepted, so that exclusions and loadings are set at inception rather than discovered at claim. Two consequences follow. First, issuance would take longer for a subset of buyers, particularly those over 45 or with a material history, and a proportion of proposals would be loaded, subject to a disease-specific waiting period that is disclosed upfront, or declined - an outcome some buyers experience today only after a claim is repudiated. Second, it reduces the stock of 'accepted then disputed' policies that generate the largest volume of grievance. The trade-off is therefore upfront friction for downstream certainty, which is the correct way to think about it.
The NHCX Incentive Idea and Why It Has Been Slow
The National Health Claims Exchange, built under the National Health Authority, is the common pipe that lets a hospital, TPA and insurer exchange a claim packet digitally rather than by paper and email. The panel considered incentives tied to onboarding itself, to payment processing, and to faster settlement, to pull hospitals and insurers who have not yet joined. Adoption has been uneven because a large share of private hospitals already run insurer-specific portals and see limited marginal gain from a new platform, while insurers have sunk cost in proprietary TPA integrations. An incentive linked to payment speed rather than mere onboarding would be the more credible design: a hospital that files a complete digital packet on NHCX and is paid faster than on an offline channel has a reason to stay. IRDAI did not specify the size, funding source or timeline for any incentive, so this remains deliberation, not a notified scheme. The parallel suggestion - that insurers publish standard treatment guidelines and package rates - points in the same direction: a common data and price language makes the exchange useful once the pipe is built.
What to Do When You Buy or Renew in FY27
Act as if point-of-sale underwriting were already the norm, because for you it already is the protective norm. At proposal stage, treat the medical history questions as the most valuable part of the form. List every hospitalisation, diagnosis and regular medication for diabetes, hypertension, thyroid, asthma, heart disease and mental health for the last five years, even if the condition feels controlled, and keep the discharge summary, prescription or test report that supports what you declared. If the proposal offers a tele-medical interview, do not rush it; a three-minute call that records your history is what the panel wants to make routine, and it protects you more than it slows you. If the Customer Information Sheet lists a disease-specific waiting period, read it as the insurer's view of your risk at inception - a transparent waiting period today is cheaper than a contested exclusion tomorrow. For claims, ask the hospital whether it is onboarded on NHCX and whether a cashless packet can be filed digitally; a hospital that is not onboarded can still do cashless, but the settlement trail is cleaner on the exchange. None of this requires waiting for a regulation. It is the practical way to convert a panel discussion about future underwriting into a claim that is not disputed for the most common reason claims are disputed today - inadequate disclosure at the point of sale.
Method and sources: Analysis based on IRDAI press release on the IAC Sub-Committee on Health Insurance third meeting dated August 28, 2026; The Insurance Reporter summary of that release dated August 29, 2026; Government's Parliament reply dated August 4, 2026 on complaint and grievance data for FY26 and Q1 FY27; IRDAI Master Circular on Health Insurance (2024) for cashless and settlement timelines; NHCX design note under National Health Authority. Insurer-specific examples are based on publicly disclosed claim settlement data for 2025-26.