By Brazil Stock Guide – Brazil’s health regulator, the Agência Nacional de Saúde Suplementar (ANS), the federal agency responsible for overseeing private healthcare and health plan operators, has taken a decisive step to reorganize one of the fastest-growing segments in the country’s healthcare system. As discount cards, prepaid services and hybrid access models expand, the agency has launched a public consultation and created an internal task force — signaling the development of a new regulatory framework.
The initiative, approved by the agency’s board on Friday (April 17), targets a segment that has become a lower-cost alternative for millions of Brazilians, but still operates in a regulatory gray area. Unlike traditional health plans offered by regulated health plan operators, these products do not provide medical coverage or assume the financial risk of treatment — a key issue at the center of the regulatory debate.
Growth Without Data
Despite rapid expansion, the sector still lacks consolidated data. To address this gap, the ANS has opened a 60-day window for companies and industry groups to submit information on ownership structures, geographic reach, service models and pricing criteria.
The goal is to build a technical foundation for future rules, with greater legal certainty and consumer protection. While consultative in nature, the process represents the first concrete step toward formally defining a segment that has so far grown largely outside the regulatory perimeter applied to health plan operators.
Participation is open to companies involved in the administration, commercialization or provision of these services, with or without proprietary networks. Submissions will be made through a dedicated form on the regulator’s website.
Jurisdiction Reinforced
The ANS’s move is backed by a recent ruling from Brazil’s Superior Tribunal de Justiça (STJ), the country’s highest court for non-constitutional matters, which confirmed the agency’s authority to regulate and supervise these activities. The decision reduces legal uncertainty and enables a more assertive regulatory approach.
According to the ANS, the absence of clear rules has allowed practices that may confuse consumers. In many cases, companies use branding, language and marketing strategies that resemble regulated health plans without offering equivalent protections — such as defined coverage, regulated waiting periods or structured provider networks.
Business Model Under Scrutiny
At the core of the discussion is a fundamental difference in economic structure. In Brazil, regulated health plan operators function under a mutual risk-sharing system, where lower-cost users help subsidize those who require more care, based on actuarial principles.
Discount cards, by contrast, transfer risk entirely to the consumer. These products facilitate access by offering reduced prices, but they do not cover procedures or pool risk. In cases of more complex or high-cost treatments, patients must either rely on Brazil’s public healthcare system or pay out of pocket.
This distinction — often not fully understood by consumers — is seen by regulators as one of the main areas requiring clarification.
Who’s Who in the Market
The market remains fragmented but already includes several relevant players operating under different models.
One of the most prominent is Cartão de TODOS, focused on low-income consumers and offering discounted consultations and exams. The company is estimated to have generated more than R$5 billion in revenue last year.
The sector also includes dozens of other providers. Among them, dr. Consulta — operated by Yalo — combines a membership model with access to its own clinical network. Clínica SiM focuses on vertically integrated, low-cost outpatient care.
Traditional healthcare groups are also entering the space. Dasa +Saúde, backed by diagnostic company Dasa, leverages its own network to offer discounted services.
Despite differences in execution, all these models share a key feature: they do not assume medical risk — a defining distinction from regulated health plan operators.
Strategic Shift
To deepen its analysis, the ANS has created a multidisciplinary internal committee involving all directorates and the agency’s presidency. The group will have an initial 90-day mandate to propose regulatory pathways.
At the same time, the regulator has decided to discontinue a regulatory sandbox initiative focused on elective consultations and exams — an idea loosely associated with “low-cost health plans.” The agency’s internal assessment is that efforts should instead be concentrated on the discount card market, given its broader social impact and the need for a more integrated regulatory approach.
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