The Chief Executive Officer
Namibia Association of Medical Aid Funds (NAMAF)
Email: ceo@namaf.org.na
Windhoek, Namibia
Dear Mr Tjiuoro,
Demand for Reimbursement of Unlawfully Collected Fees For Practice Number
I, [Your Full Name], a healthcare practitioner registered with NAMAF under practice number [ state your practice number] hereby formally demand the reimbursement of all fees unlawfully collected from me between 2016 and 2023 for the renewal of my practice number.
- Legal Justification
It has been established that NAMAF’s collection of fees for practice number renewals is ultra vires, as NAMAF does not have the statutory authority to impose such charges. In addition, I invoke the legal principle of condictio indebiti, as the payments were made under a mistaken belief that there was a legal obligation to pay these fees.
- Fees Paid and Adjusted for Inflation
I have calculated the amounts owed to me based on the fees paid to NAMAF, as follows:
Year | Amount Paid | Claimed Amount |
2016 | N$ 590.00 | N$ 590.00 |
2017 | N$ 630.00 | N$ 630.00 |
2018 | N$ 671.00 | N$ 671.00 |
2019 | N$ 720.00 | N$ 720.00 |
2020 | N$ 747.00 | N$ 747.00 |
2021 | N$ 763.00 | N$ 763.00 |
2022 | N$ 779.00 | N$ 779.00 |
2023 | N$ 832.00 | N$ 832.00 |
Total Payments | N$ 5 731.00 | N$ 5 731.00 |
NOTE FROM EBEN:
One cannot make demand based on inflation adjustments. See comment in main letter. I would in fact only write one letter. And combine the information and DEMAND. Each HCP to complete and serve same on NAMAF. The two letters appear to be a duplication. Unless the idea is that NPPF writes a separate letter …. But then in that letter the DEMAND part must be deleted. The NPPF cannot demand repayment – only the HCP who paid.
- Demand for Reimbursement
I hereby request that NAMAF:
- Reimburse me the total sum of 5 731.00 for fees unlawfully collected between 2016 and 2023, as detailed above.
- Confirm in writing within 14 days of receipt of this letter that you will process the reimbursement, or alternatively provide reasons for any refusal to do so.
Failure to address this demand may result in legal action to recover all unlawful fees paid to NAMAF for the renewal of practice numbers, with interest.
I trust that NAMAF will resolve this matter promptly and look forward to your timely response.