NFRA’s Guiding Opinions: What They Mean for China’s Multi-Level Coverage Framework

On September 28, 2025, the National Financial Regulatory Administration (NFRA) issued the Guiding Opinions on Promoting the High-Quality Development of Health Insurance. The document aligns with the State Council’s broader agenda to strengthen supervision, mitigate systemic risks, and elevate the role of health insurance within China’s national healthcare security system by 2030.

Five key themes stand out from the policy, each carrying major implications for building a multi-level coverage framework and improving affordability for high-value innovative therapies.

1.     Breaking Regulatory Barriers to Integrate Health Insurance and Health Management

A cornerstone of high-quality health insurance is the integration of insurance design with active health management — extending beyond preventive care to proactive risk management. Insurers and health service partners use data, incentives, and coordinated care to intervene early, guide provider behaviors, and reduce claim frequency and severity.

Yet China’s commercial health insurance market remains dominated by fixed-benefit products and short-term, reimbursement-based plans that provide only post-event compensation. These designs leave little room for proactive risk management, limiting insurers’ ability to improve outcomes, control long-term costs, or sustainably cover innovative therapies.

A major barrier lies in the legacy regulatory framework, which has long treated health management services as ancillary expenses rather than a core insurance function. Spending on such services is capped at 20% of net premiums — unlike international practice, where health management is fully integrated into insurance product design.

The new Guiding Opinions address this constraint by introducing pilot programs that allow well-rated health insurers to exceed the 20% threshold for allowable health management spending. This marks a critical shift toward recognizing that “managing health” is an inseparable part of “insuring health.”

By allowing greater flexibility in cost allocation, the Guiding Opinions lay the foundation for sustainable, innovation-oriented insurance models. These pilots strengthen the long-term sustainability of commercial insurers and enhance their capacity to share the financial burden of high-value therapies within China’s evolving multi-level coverage framework.