Singapore Ministry Of Health Issues Fee Benchmarks For Common Surgical Procedures.
Legal News & Analysis - Asia Pacific - Singapore - Regulatory & Compliance
23 November, 2018
On 13 November 2018, the Singapore Ministry of Health (MOH) published fee benchmarks for common surgical procedures, applicable only to the private sector (Benchmarks). In the Benchmarks, the MOH adopted the recommendations of the Fee Benchmarks Advisory Committee (Committee), which aimed to improve the transparency of medical costs in Singapore, and to empower patients to make better informed decisions. The Committee also set out recommendations as to how the various stakeholders could benefit from the Benchmarks, and moving forward, will work with the MOH to monitor and update the Benchmarks.
The Benchmarks are meant to apply only to the private sector, as public sector doctors are salaried employees and surgical procedures done in the public hospitals are not charged as separate fees. The source data upon which the Benchmarks have been developed, likewise, did not include public sector surgical procedure fees.
A summary of the key features of the Benchmarks is set out below:
- The Benchmarks are available for 222 surgical procedures in the Table of Surgical Procedures and state the lower and upper limits, which are not meant to be construed as fee caps.
- Healthcare providers who deviate from the Benchmarks are encouraged to provide justification to the patient, before the procedure is carried out, when circumstances permit.
- The Benchmarks are intended to cover routine cases typically
- encountered in the private sector, for a single procedure performed in one surgery. Unusual complexities would not be covered by the Benchmarks.
- The Benchmarks are the total ballpark figures for professional fees expected to be incurred, excluding tax and the anaesthetist's fees.
- The Benchmarks for each of the procedures were based on the 2017 source data of Singaporean patients with at least 30 cases per procedure (unless specified otherwise in the Benchmarks). Where the dataset for that particular procedure was too small, the Committee determined a reasonable range by taking into account the benchmarks of a related procedure with at least 30 Singapore Citizen cases performed in the private sector in 2017.
- The Benchmarks were devised in conjunction with inputs from multiple stakeholders, including specialists from both the public and private sectors, the Consumers Association of Singapore (CASE), the Singapore Medical Council (SMC), the Singapore Medical Association (SMA), and the Competition and Consumer Commission of Singapore (CCCS), amongst others.
The approach taken by the Committee was crucial in overcoming the criticisms levelled by the then-Competition Commission of the Singapore (CCS) against the SMA's Guideline on Fees (GOF) published in 2006. The GOF was first published by the SMA in 1987, and was in its fourth edition, when it was withdrawn in 2007 due to anti-competitive concerns.
Certain shortcomings of the GOF highlighted by the then-CCS also included the fact that the MOH, SMC and consumer groups representing the interests of patients had not been consulted when devising the GOF, and that the basis on which the GOF was formulated did not appear to be sufficiently objective, and was not based on actual price data (for more information, see the full decision on the GOF here).
Notably, before making recommendations to the MOH, the Committee engaged with multiple stakeholders, and also took the GOF into consideration as a point of reference for what was perceived as "reasonable" by the medical fraternity. The fee ranges in the GOF were adjusted for inflation and compared against the source data comprising the 2017 transacted fees. This provided some insights into the trajectory of fee increments over the past decade.
Given the history underlying the GOF, this approach is practical but considering the criticisms discussed above, it is interesting that the GOF still factored into the discussions. Nevertheless, the publication of the Benchmarks serves as a fitting conclusion to the legacy of the GOF and its intent.
For further information, please contact:
Andy Leck, Principal, Baker & McKenzie.Wong & Leow