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Home / Media OutReach / Life Insurance Association, Singapore: Industry response to Position Statement on Integrated Shield Plans (IPs) by the Singapore Medical Association (SMA): Focus needs to be on identifying the best way forward together for the benefit of Singaporeans

Life Insurance Association, Singapore: Industry response to Position Statement on Integrated Shield Plans (IPs) by the Singapore Medical Association (SMA): Focus needs to be on identifying the best way forward together for the benefit of Singaporeans

SINGAPORE – Media OutReach – 31 March
2021 – Integrated Shield Plans (IPs) impact most Singaporeans and IP
insurers have been implementing various measures to manage IP costs
appropriately and without compromising needed medical care for policyholders.
The main objective of the recommendations put forth by the Health Insurance
Task Force (HITF) in 2016[1]
was to bring down the rate of claims cost inflation so that premium increases
can be moderated and kept sustainable. All recommendations by the Task Force
have since been implemented.[2]


It is
the responsibility of all parties involved to be proactive and work
collaboratively to ensure the continued accessibility of quality healthcare in
Singapore.


Greater
transparency required from all parties


We
agree that greater transparency will provide more clarity on this matter.


On this
end, we recently concluded an update of the LIA Singapore guidelines on panel management.
This includes guidance that IP insurers should explain the criteria for
selection of panel doctors and is publicly available on the LIA Singapore
website[3].
 


Equally,
we urge SMA to respond to our repeated calls for greater transparency too. LIA
Singapore has requested for clinical quality measures and guidelines to prevent
over-treatment on numerous occasions. We ask that SMA respond promptly and
positively on this.


Clinical
quality measures will enable insurers to make better, evidence-based decisions
on admitting doctors into panels. Policyholders will ultimately benefit because
they will receive better care.


Expanding
panels to include all private specialists may result in the need for further
premium increases


IP
panels have been implemented for several years now and are not completely new
to the IP market. Panels have expanded over time, and LIA Singapore’s guidance
to IP insurers is that panels should be sufficient to offer a wide range of
medical services to policyholders. IP insurers have an interest in ensuring
that their panels are comprehensive as this increases panel usage, which helps
insurers better manage costs.

SMA is
strongly advocating for panels to be expanded to include all private
specialists in Singapore, and for all panel doctors to be compensated up to the
upper bounds of the MOH fee benchmark range. This needs to be carefully
considered as tradeoffs are involved.

The average
ratio of upper bound to lower bound for surgeon fee benchmarks is 1.8[4]. As
such, proceeding per SMA’s suggestion without calibration may lead to cost
increases and further premium increases for policyholders.


Striking
this balance is critical, and we invite SMA for a discussion on how this can be
done in a way that will not disproportionately burden policyholders with higher
premiums.




Misleading
analysis should be avoided


It is
important that organisations put out objective analyses which avoid biased
conclusions.


In this
regard, we find SMA’s analysis of insurers’ costs and claims costs to be
misleading. Claim increases are the main driver of premium increases. LIA
Singapore will fully address this in due course, along with more detailed
comments on the rest of SMA’s position statement.


Importance of collaboration to achieve our shared goal of affordable,
quality healthcare for Singaporeans




Our
collective priority must be to focus on finding the best ways to achieve a
common goal for the benefit of Singaporeans.


LIA
Singapore has always pursued an open, discussive and constructive dialogue to
receive feedback and resolve potential issues. Updating of the abovementioned
LIA guidelines on panel doctor and, previously, the standard LIA
Pre-Authorisation Form[5]
based on SMA’s inputs were also actioned on swiftly.


Accordingly,
we look forward to greater collaboration amongst all parties with the formation
of a trilateral committee, comprising LIA Singapore, SMA and the Academy of
Medicine, Singapore already set up by the Ministry of Health (MOH) to discuss
and resolve IP-related issues, and to refine the implementation of HITF
recommendations together in a constructive manner.




Appendix 1: Summary of HITF recommendations


 









Recommendations

Impact on Stakeholders

Introducing Medical
Fee Benchmarks or Guidelines

–         
To have a set of
medical fee benchmarks or guidelines to provide a range of professional fees.
Benchmarks or guidelines should be calibrated to ensure the appropriate involvement
and adoption by stakeholders

–         
To address the
issue of information asymmetry by providing stakeholders access to
information on appropriate charges

–         
To mitigate cases
of over-charging by providers

Consumers (or
Patients)

·        
Provides an
approximation of charges and allows consumers to manage their personal
healthcare financing

Healthcare
Providers

·        
Enhances the
financial counselling process conducted by healthcare providers as consumers
are aware of the possible charges

·        
Provides greater
transparency on charges to promote trust and to improve the patient-doctor
relationship

 

Payers (IP
insurers)

·        
Provides a
reference for insurers to review size of claims and develop appropriate
product features (e.g. charges are within claim limits)

·        
Addresses cases of inflated
claims

 

Clarification on
Existing Process to Surface Inappropriate Medical Treatment

–         
To clarify the
existing escalation process which allows insurers to raise cases of
inappropriate and excessive medical intervention to the relevant authorities

–         
To clarify on the
practices amongst insurers when dealing with such claims so as to minimise
the impact on policyholders whose cases are subject to investigation

–         
To increase
awareness of the existing avenue for insurers to raise cases of inappropriate
and excessive medical intervention noted in their review of claims

Consumers (or
Patients)

·        
Ensures impact on
policyholders’ claims is managed by insurers

·        
Provides assurance
of a robust and accountable process when claims are denied on the basis that
treatments were not medically necessary

 

Healthcare
Providers

·        
Emphasises the
importance of providing medically necessary treatment and discourages medical
professionals from malpractices

 

Payers (IP
insurers)

·        
Provides greater
clarity and awareness of the escalation process

·        
Allows insurers to
play a more active role in supporting medically necessary treatments

Enhancing Insurance
Procedures and Product Features

·     
Panel of Preferred Healthcare Providers

–         
To suggest that
insurers consider the use of preferred healthcare provider panels, where
appropriate, to manage medical costs through fee agreements. IP insurers
should make clear to their customers that their choice of healthcare
providers is not restricted by the existence of the panels, although the
coverage may be affected

–         
To enhance and
ensure transparency of the arrangement (e.g. disclosures on the healthcare
provider selection process)

–         
To suggest that insurers
consider, during the appointment of preferred healthcare providers, TPAs, and
intermediaries, whether their fee arrangements are in line with SMC’s
ECEG 

Consumers (or
Patients)

·        
Provides assurance
that charges by panel healthcare providers are appropriate and
correspondingly, out-of-pocket costs in the form of deductible and
co-insurance are appropriate

·        
Provides clarity on
the potential implications of using a non-panel healthcare provider in terms
of making insurance claims

 

Healthcare
Providers

·        
Emphasises the
importance of providing required standard of care to patients and discourages
medical professionals from fee arrangements that may influence the
objectivity of their clinical judgement in their management of patients

 

Payers (IP
insurers)

·        
Encourages insurers
to influence their preferred healthcare providers, TPAs, and intermediaries
to have fee arrangements with medical professionals that are in line with
SMC’s ECEG

·        
Ensures leakage of
claims costs is minimised as claims are based on agreed medical fee charges
and treatment

Enhancing Insurance
Procedures and Product Features

·     
Co-insurance & Deductibles

–         
To encourage
insurers to include co-insurance and/or deductible features in product design
to ensure consumers’ interest are aligned with managing healthcare costs

–         
To address the
risks of overconsumption due to poor product features

Consumers (or
Patients)

·        
Encourages
consumers to play a more active role in managing their medical care costs

·        
Encourages
consumers to be more responsible for their lifestyle habits

 

Healthcare
Providers

·        
Increases pressure
to provide medically effective and cost efficient treatment

·        
Encourages
communication between consumer and healthcare provider on type and cost of
medical care recommended and, improves the patient-doctor relationship


Payers (IP
insurers)

·        
Aligns product
features with consumers’ interest for long term sustainability of IP premiums

·        
Ensures better
claims cost management

 

Enhancing Insurance
Procedures and Product Features

·     
Pre-approval of Medical Treatment

–         
To encourage
insurers to approve claims for medical treatment and estimated bill size
prior to the actual procedure, which provides certainty to patients on what
can be claimed from their insurance policy

–         
To address the
risks of inappropriate treatment and high medical charges

Consumers (or
Patients)

·        
Provides a peace of
mind as policyholders know their procedure is within insurance coverage when
actual treatment is sought

·        
Protects consumers
as insurers would not endorse and providers are unlikely to recommend
procedures that are not medically necessary

 

Healthcare
Providers

·        
Decreases disputes
with payers and consumers over medical treatment and bills

·        
Encourages greater
communication between payer and provider

 

Payers (IP
insurers)

·        
Provides greater
control over cost of medical bills

 

Educating Consumers

–         
To educate the
public on the available options, such as the types of hospitals and wards,
and the corresponding costs of their medical treatments

–         
To address the issue of
information asymmetry by ensuring information on medical charges is readily
accessible and easily comprehensible by consumers

Consumers (or
Patients)

·        
Educates consumers
to assess the available information and make informed healthcare choices

 


Appendix 2: Health Insurance Task Force
composition
















Name

Designation

Ms
Mimi Ho

(Chairman)

Principal,
Regulatory Professionals Pte Ltd

Dr
Khoo Kah Siang

President,
Life Insurance Association, Singapore

Mr
Richard Wyber

Deputy
Convenor, Health Insurance Subcommittee, Life Insurance Association,
Singapore

Mr
Lim Biow Chuan

President,
Consumers Association of Singapore

Mr
Seah Seng Choon

Executive
Director, Consumers Association of Singapore

Dr
Wong Tien Hua

President,
Singapore Medical Association

Dr
Wong Chiang Yin

Council
Member, Singapore Medical Association

Mr
Chin Chee Kiat

Director
(Finance Policy), Ministry of Health, Singapore

Ms
Jasmin Lau

Deputy
Director (Finance Policy), Ministry of Health, Singapore

Ms
Lee Keng Yi

Director
& Department Head (Insurance), Monetary Authority of Singapore

Ms
Tan Siew Yen

Director
& Division Head (Insurance), Monetary Authority of Singapore


Industry
experts: 





Name

Designation

Dr
Leow Yung Khee

Head
of Group Insurance and Claims, The Great Eastern Life Assurance Company
Limited and The Overseas Assurance Corporation Limited

Mr
Martin Ho

Chief
Administrator, Singapore Medical Association


Appendix 3: HITF
Terms of reference




To
recommend measures to bring about moderation in the escalation of health
insurance premiums in Singapore, including, but not limited to:




*      Measures
that increase the transparency of health services charging;


*      Measures
conducive to the provision of appropriate care at appropriate cost by
healthcare professionals; and

*      Educational
measures to help consumers make prudent choices of health services, and to
raise the awareness of healthcare providers of measures conducive to the
provision of appropriate care at appropriate cost.


[2] Refer to
Appendices  for a summary of the HITF
recommendations and members of the Task Force, Task Force composition, and HITF
Terms of Reference. Information extracted from the Report


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