What the fuck is " " reasonable fees for services rendered operates over and above contractual and

nayr69sg

Super Moderator
Staff member
SuperMod
Joined
Apr 25, 2010
Messages
17,144
Points
113
SMC CIRCULAR NO. 1/2018
[SMC 14.20]
19 March 2018
DOCTORS HAVE AN IMPORTANT ROLE TO PLAY IN KEEPING HEALTHCARE
COSTS AFFORDABLE AND SUSTAINABLE
1. We refer to the recent media coverage on rising healthcare costs (including
medical insurance premiums) and hefty and questionable insurance claims.
2. The Singapore Medical Council (“SMC”) notes that to keep healthcare costs
affordable and sustainable for patients, all stakeholders – healthcare professionals and
providers, insurers and policyholders, employers, patients and caregivers, and the
Government – have their roles and responsibilities. While the SMC acknowledges that
there are various drivers of healthcare costs, many of which are beyond the control of
doctors, doctors have a major role in managing healthcare costs, by advising patients
on appropriate and cost-effective tests, medical procedures and treatments, and striving
to keep fees fair and reasonable. In light of the recent scrutiny of healthcare insurance
and unreasonable practices and fees, the SMC by way of reminder, wishes to bring to
bear the ethical principles against complicity by doctors outlined in the 2016 edition of
the SMC Ethical Code and Ethical Guidelines.
Guideline H1 – Fees for services
3. Where patients are covered by medical insurance that guarantee they pay little
or nothing towards their medical bills, they may be less likely to contest the fees charged
by the doctor. However, patients’ acquiescence to a doctor’s fees does not absolve the
doctor of the responsibility of charging reasonable fees; the doctor’s ethical obligation
to charge fair and reasonable fees for services rendered operates over and above
contractual and market forces and is not superseded by any agreement between the
doctor and his patients.

4. Even where the doctor does not have the ability to set fees himself, as long as
he has a material financial interest, or significant professional, governance or
management responsibility for an organisation that sets fees from which he directly
benefits, he must satisfy himself that the fees abide by SMC’s ethical standards.
Guideline H3 – Financial conflicts of interest
5. In managing patients, a doctor must always place his patient’s best interests
above his personal interests and any business or financial considerations; he must not
let business or financial considerations influence the objectivity of his clinical judgment
in his management of patients. For example, a doctor must not subject a patient to
unnecessary tests or procedures simply because the doctor stands to benefit from the
fees; this could constitute over-servicing and may be a breach of his ethical obligations
even if the patient agreed to undergo the test or procedure.
6. In the same vein, doctors should not conduct tests or provide treatment merely
upon a patient’s request unless there is a clinical basis for doing so. The SMC would
like to emphasise that declining to accede to a patient’s unjustified demand is not a
breach of a doctor’s ethical obligations – acting in a patient’s best interests does not
mean doing everything a patient wants.

7. In addition, while there is no prohibition against a day procedure being carried
out as part of a hospitalisation stay, doctors must not recommend hospitalisation where
there is no clinical justification to do so and for the primary purpose of charging higher
fees. Such conduct may constitute over-servicing and/or over-charging.
Duty of Doctors
8. Doctors have a duty to provide competent, compassionate and appropriate care
to patients, based on a balance of evidence and accepted good clinical practice; this
duty also entails not over-charging and over-servicing patients for financial benefit. As
members of the medical profession, doctors are held in the highest esteem by the public,
and much trust is reposed in them. This trust is contingent on the profession maintaining
the highest standards of professional practice and conduct. The SMC believes that the
majority of doctors continue to strive to practise ethically and to build the trust of the
public, but for the few who are found to have misconducted themselves by unethical
charging and over-servicing and bring disrepute to the profession, disciplinary action
will be taken against them.
Thank you.
PROFESSOR TAN SER KIAT
PRESIDENT
SINGAPORE MEDICAL COUNCIL
 
Medical fee guidelines anti-competitive
Country: Singapore
Partner Institute: Department of Epidemiology and Public Health, National University of Singapore
Survey no: (16)2010
Author(s): Lim Meng Kin
Health Policy Issues: Remuneration / Payment
Current Process Stages
Featured in half-yearly report: Health Policy Developments 13
1. Abstract
After an 18-month review, the Competition Commission of Singapore decided that the Singapore Medical
Association?s fees guidelines are, after all, anti-competitive.
2. Recent developments
The guidelines were introduced in 1987 by the Singapore Medical Association (SMA) to provide a guide to its
members (not all doctors are members of the SMA) on what might be considered as "reasonable" fees for a wide
range of medical services. This was partly in response to the Ministry of Health´s (MoH) calls for a guide on medical
charges as the MoH was concerned with the possibility of overcharging by doctors in the private sector. These
guidelines were non-binding and no penalties for deviation were implied.

In April 2007, however, the SMA abruptly and unilaterally scrapped its pricing guidelines after merely receiving legal
advice from its own lawyers that the guidelines could possibly be a contravention with the Competition Act. The
Competition Commission of Singapore (CCS) publicly welcomed the move, saying this would lead to greater flexibility,
as medical practitioners can set the fees according to the true business costs. The fact that the SMA had scrapped its
20 year old guidelines on its own without even exploring the possibility of applying for exemption, which was provided
for in the act, prompted criticism that its acquiescence appeared rushed and premature.
In February 2009, the SMA announced that CCS had indicated its willingness "to study any proposal SMA may wish
to make in connection with fees", whereupon it finally filed notification with the CCS to find out if its fees guidelines
actually infringed the Competition Act. CCS responded by commissioning a six-month study that would examine the
local market for medical services, to see if there were special circumstances that justified any form of fee guidelines. It
would then decide if fee guidelines should be reinstated or newly set.
In June 2010, the Commission issued a provisional statement saying the guidelines were anti-competitive, thereby
infringing Section 34 of the Competition Act.
In August 2010, the Commission finally concluded that the Guidelines on Fees set by the SMA were indeed anti-
competitive.

Idea Pilot Policy Paper Legislation Implementation Evaluation Change
- 1

The decision by CCS received mixed reviews in the online chatter, with some warnings of the danger of overcharging
by doctors, and others defending differential pricing acccording to market forces.

Actors and positions
Description of actors and their positions
Actors and influence
Description of actors and their influence
Positions and Influences at a glance
Monitoring and evaluation
According to the CCS, there was no increase in complaints of overcharging to the SMA after the guidelines were
removed in 2007. In fact, numbers had gone down from 26 in 2006/2007 to 14 in 2008/2009.

The market study that the CCS had commissioned, which was conducted from second quarter of 2009 till the first
quarter of 2010, also found that after accounting for medical inflation, professional fees charged by private doctors
Government
Ministry of Health very supportive strongly opposed
Ministry of Trade and Industry very supportive strongly opposed
Competition Commission of
Singapore
very supportive strongly opposed
Providers
Singapore Medical Association very supportive strongly opposed
Patients, Consumers
Patients, Public very supportive strongly opposed
Media
Media very supportive strongly opposed
current previous
Government
Ministry of Health very strong none
Ministry of Trade and Industry very strong none
Competition Commission of
Singapore
very strong none
Providers
Singapore Medical Association very strong none
Patients, Consumers
Patients, Public very strong none
Media
Media very strong none
current previous
- 3



3. Characteristics of this policy
4. Purpose and process analysis
Initiators of idea/main actors
Government
Providers
Patients, Consumers
Media
Stakeholder positions
This ruling brings the three-year tussle between the SMA and the CCS over the issue of whether the SMA's 20 year-
old guidelines on doctors' fees infringe Singapore's Competition Act to an end.
The CCS's decision comes as no surprise since the government had thrown out the SMA's request for its Guidelines
on Fees to be excluded from the Competition Act in June 2010.
After consulting the MoH, the Ministry of Trade and Industry (MTI) determined that the guidelines would create anti-
competitive behaviour and could not be excluded from the Competition Act.
In giving the grounds for its final decision to not have such guidelines, the Commission said that, apart from the fact
that about 80% of care is provided by public sector hospitals, where SMA's fee guidelines do not apply, the guidelines
tended to create a clustering effect. When, for example, setting a fixed fee, doctors who might be able to charge less
would have no incentive to do so. It was pointed out that in a competitive market prices are determined by demand
and supply. Minimum or maximum pricing recommendations discourage competition, so the "Commission urges all
businesses to set their prices independently and to not rely on guidelines issued by trade and professional
associations."
The SMA appears to have thrown in its towel, although it could have contested the ruling if it wanted to do so. Its
President publicly conceded that the guidelines "have outlived their usefulness."
Degree of Innovation traditional innovative
Degree of Controversy consensual highly controversial
Structural or Systemic Impact marginal fundamental
Public Visibility very low very high
Transferability strongly system-dependent system-neutral
current previous
Idea Pilot Policy Paper Legislation Implementation Evaluation Change
- 2


actually dropped by 2.6 per cent after the guidelines were removed. This, it said, showed that the guidelines, which
were not binding in the first place, had no impact on private doctors' fees.
5. Expected outcome
The government is pushing for more transparency in hospital charges. It has announced that from early 2011, all
hospitals making Medisave claims (including private hospitals) will have to submit basic billing information, and this
information will be posted on the Health Ministry's website. Hospitals and doctors are also required to provide financial
advice.
6. References
Sources of Information
Claire Huang. It's final - SMA's medical fee guidelines ruled anti-competitive 19 August 2010
http://www.channelnewsasia.com/stories/singaporelocalnews/view/1075966/1/.html
Wong CY. Could SMA Have Not Withdrawn the Guidelines on Fees
(GOF)?http://www.sma.org.sg/position/Withdrawal_SMA_Guideline_on_Fees_Presidents ForumApr07.pdf
current previous
- 4
 
So previously as guideline in reasonable fees was deemed uncompetitive and goes against market forces.

Now they want some nebulous definition of reasonable fees that goes over and above market forces. Whatever that means.
 
So if your doctor don't do what you want try complain to SMC. See what happens
 
Meanwhile a Dr is asked by insurers to explain why he charged $12k for a routine colonoscopy.

All these ivory tower hypocrites.
 
Last edited:
Bankers make money ok.
Insurance make money ok.
Highest paid politicians in the world ok.
Doctors make money .....must be REASONABLE.

LOL!!!
 
Most insured patients not need to worry. But insurance company only worried.
Why don't we just cut out the middleman and allow hospitals to collect insurance money. That way, money soent 100% on healthcare and not squandered into some stupid investment that has nothing to do with health. Insurance fees will drop by a huge margin.
 
Bankers make money ok.
Insurance make money ok.
Highest paid politicians in the world ok.
Doctors make money .....must be REASONABLE.

LOL!!!

PAP government make money...is it reasonable?
 
Back
Top