Introduction to the Reforms
On April 17, 2025, the Diario Oficial de la Federación (DOF) published reforms to the Organization and Functioning Norms of the Interinstitutional Commission of the National Compendium of Health Inputs (CNIS). This crucial document defines which medications, equipment, and materials reach public hospitals in Mexico. The modifications, including substantial changes and formal adjustments, have raised concerns about the direction of decision-making in the healthcare sector, particularly amidst chronic shortages and a lack of transparency.
Key Changes in the Reforms
Increased Voting Members with Decreased Equity
The most significant alteration is the increase in voting members from 8 to 13 in the Commission. Previously, institutions directly serving patients—IMSS, IMSS-Bienestar, ISSSTE, SEDENA, SEMAR, PEMEX, COFEPRIS, and CCINSHAE—each held a vote, ensuring equity in decisions about Compendium insumos. Now, the Secretariat of Health holds five votes (two from the Institute of Public Health, COFEPRIS, Directorate General of Modernization, and the Economic Analysis Unit), with the addition of UNAM and IPN, academic institutions without direct experience in insumo evaluation or mass patient care.
This imbalance worries many, as six of the 13 votes belong to entities without direct patient care context, placing those serving most Mexicans—like IMSS and IMSS-Bienestar—in the minority.
Creation of a Technical Group for Exclusion
Another relevant change is the establishment of a Technical Group for Insumo Exclusion, separate from the specific technical committees evaluating inclusion. Although exclusion has always been considered, now a single group will decide on all insumos without clear rules or criteria, opening the door to discretion.
For instance, the regulation states that insumos without health registration—like nutritional supplements or milk—will be excluded, but it does not explain how objectivity will be ensured. This ambiguity may lead to arbitrary decisions, especially when the Compendium includes essential insumos for vulnerable populations.
Extended Evaluation Period and Reduced Transparency
The reforms also extend the evaluation and dictamen period for insumos from 60 to 80 business days, potentially worsening delays in an already overburdened system. Moreover, the obligation for the technical secretary to communicate results is removed, allowing any official to do so, and requirements like transparent dating of dictámenes are eliminated. Surprisingly, the very concept of “transparency” was repealed in article 3, raising suspicions in a sector plagued by opacity.
Positive Aspects of the Reforms
Among the positive changes, authorizing distributors to request Compendium updates—previously restricted to health registration holders—stands out. Simplifying the request letter requirement, now only needing the medical director’s signature, is also noted, though ambiguity persists regarding what defines “insumo necessity.” Furthermore, the definition of “innovative technologies” is introduced, and requests must detail comparative advantages over clinical guidelines, despite these often being outdated, complicating the evaluation process.
Conclusion and Expert Opinion
These reforms come at a critical time. Centralizing power in the Secretariat of Health and lacking clarity in key processes, like insumo exclusion, could complicate matters instead of strengthening supply. The risks of discretion and loss of equity in decision-making raise red flags. Mexico’s health cannot afford more missteps.
Key Questions and Answers
- What are the main concerns regarding these reforms? Concerns include decreased equity due to increased voting members from healthcare-providing institutions, the creation of a Technical Group for Exclusion without clear rules or criteria, extended evaluation periods leading to potential delays, and reduced transparency in communication of results.
- Who is Dr. César Alberto Cruz Santiago and why is his opinion relevant? Dr. César Alberto Cruz Santiago has a distinguished career in public health, actively participating in the Consejo de Salubridad General (CSG) in various roles, including technical secretary of the Commission for Rare Diseases Analysis, Evaluation, Registration, and Monitoring (CAERSER) and contributing to the modernization of CNIS processes through digitalization strategies. He is a general surgeon with specialties in general, colon, and rectal surgery and possesses postgraduate degrees from UNAM and the University of Miami. His research is recognized in high-specialty conferences and national and international journal publications.
