Under the existing provisions of NBC, 2016, the height of hospital buildings is capped at 45 m, or about 12-15 floors. The corporate hospitals are seeking this limit be revised to 60 m, allowing them to add additional three-four floors.
Most states follow the NBC guidelines, barring Maharashtra and Gujarat where the guidelines have been tweaked to permit hospitals higher than 45 m. In Delhi, an exception was given to one government hospital—Loknayak Jaiprakash (LNJP) Hospital.
“In an environment where there is a very large urban migration, cities require these beds to cater to both urban and rural populations. Land is a scarce commodity, and we believe that vertical expansion of healthcare infrastructure will go a long way to unlock capacity that already exists,” Shah wrote.
ThePrint has seen a copy of the letter.
According to industry estimates, the number of total hospital beds in India stands around 2 million of which nearly 1.2 million are in the private sector while the rest are in public hospitals. The bed to population ratio stands around 1.3 per 1,000 persons, less than even what the National Health Policy, 2017 prescribes—2 per 1,000.
“There are many hospitals which would immediately want to expand if the height related norm in the NBC is expanded. While the government has been talking about opening new centres in tier 2 and 3 cities, it is far easier to expand the already existing infrastructure and create additional beds quickly,” NATHEALTH general secretary Sidhartha Bhattacharjee told ThePrint.
ThePrint reached out to DGHS Dr Atul Goel over phone calls for his comments on the demand by the private hospitals. This report will be updated if and when a reply is received.
The NATHEALTH letter underlines several clauses in the NBC, 2016, saying they are a source of confusion and misinterpretation for hospital building plan approvals.
The network, for instance, has pointed out that a clause in the Code considers the roof of the same floor for evacuation, rather than the floor level. “While (this) definition is fine for calculating/allowing height with respect to aviation restriction, it may not be correct to consider height of roof to evacuate people in an emergency like fire. Habitation is obviously at floor level, hence height for fire /emergency evacuation should be that of floor,” the letter says.
The NBC also mandates that all critical patients and those incapable of self-preservation and with physical impairment should be housed within 30 m height while other patients and occupancies such as consultation rooms, nursing stations, medical shops and canteens may be housed at heights beyond 30 m but not more than 45 m.
The consortium, however, has insisted that NBC should be suitably amended to define critical patients as those housed in an Intensive Care Unit (ICU) or in an operating room, adding that few states like Maharashtra allow hospital buildings up to 60-70 m.
In Delhi, says the letter, the LNJP Hospital is 122 m tall.
“If evacuation is feasible in a building or a state, it should be possible elsewhere, too. Hence hospital building should be allowed beyond 45 m—up to 60 m at least. And if found suitable, offices and administrative areas may be allowed between 45 to 60 m while other sections can be housed below,” the private health body has said.
“With the high cost of land in urban districts across the country, it would help hospitals to optimize the cost of construction with enhanced height.”
It also expressed reservations on a provision saying that the basement cannot be used to store flammables or for pathological or other laboratories particularly those involving usage of chemicals. This generic definition, according to NATHEALTH, makes it tough to get clearance for radiation facilities like bunkers which have best radiation leakage protection with natural earth surrounds.
“Even when bunkers are allowed, support areas like mould rooms, CT simulator ( a special kind of CT scanner used in radiation oncology), and patient waiting or holding are a challenge to get cleared..NBC should be amended to clearly define the hospital uses permitted in the basements along with employee areas,” it elaborated.
But while the corporate players have argued that additional beds created through the tweaks in NBC will benefit both urban and rural patients, the public health specialists ThePrint spoke with, countered saying that India has enough beds aimed at “profiteering”.
“In India, private healthcare providers are the larger supplier of services and there is enough evidence to show that their main aim has only been profiteering, resulting in hardly any benefit in accessing quality healthcare for the poor,” said Dr Mohan Rao, former professor at the Centre for Social Medicine and Community Health, Jawaharlal Nehru University (JNU).
Public health researcher Oommen C. Kurian, too, pointed out that in the metros, the patient-hospital interface is mediated by the ability to pay.
“In the metros in particular, additional floor space index or FSI and additional beds for the private sector need not automatically lead to better healthcare access to the general population, as the patient-hospital interface is mediated by the ability to pay,” he said.
FSI is calculated by dividing the total built-up area of a building by the total area of the plot.
“Most of the private hospitals, mainly the corporates, are unaffordably expensive. Out of pocket spending needs to be brought down in parallel with any FSI exemptions, be it through participation in national and state health insurance programmes, or through bringing down hospital charges,” he said.
Kurien also said that there may be a case for FSI exemptions in urban areas, whereby hospitals are ready to make reasonable profits through a high volume, low margin, affordable model.
“But more than metros such exemptions may work in smaller cities and towns where there is an existing infrastructure gap, and treatment gap, which can be overcome by a strong government insurance system that partners quality private providers,” he said.
The health researcher, however, maintained that higher FSI alone may not lead to any favourable outcome, unless the government proactively takes steps to make sure that at least part of the additional beds are used for public good at a reasonable profits, assisted by volumes.
(Edited by Tony Rai)
