The Straits Times Forum printed my letter on the issue of the Singapore Medical Association (SMA) Guideline On Fees (GOF).
I have blogged on this matter in 2007 (here).
Recently the topic is on the radar screen again - I think because it was resurrected by Prof. Lee Wei Ling. If you do not already know, she is the daughter of MM Lee Kuan Yew.
Dr. Huang Shoou Chyuan
NB: (11.2.09) The CCS has replied and I attach it below.
The CCS mentioned that SMA paid $5000 as an application fees in Feb 5 (2009) and is insinuating that my figures are inflated. It is a matter of public record that the President, SMA quoted in a national newspaper the figure of $200,000 in 2007! So who is right? Anyway, bureaucrats will always get their last word in!
The forum letter:
FEES FOR MEDICAL PROCEDURES
Reinstate guidelines for docs
Feb 7, 2009
I REFER to the report 'Fee guidelines for docs: Yes or no?'.
I feel that the Competition Commission of Singapore (CCS) has itself been poorly advised as its stand had led the Singapore Medical Association (SMA) to scrap its Guidelines On Fees (GOF) for fear of being branded anti-competitive.
The 47th SMA Council dropped the bombshell announcement at its annual general meeting on April 1, 2007, and it became clear later that it had no choice as it would cost the SMA at least $200,000 - that is, $20,000 for guidance from CCS to file paperwork; $30,000 for a decision; $150,000 for legal fees - to get a formal decision from the commission on the guidelines.
All most of us wanted was to ensure that Singapore's reputation as a centre of medical excellence - which was painstakingly built by previous generations of doctors - would not be ruined by the black sheep in our profession, who think nothing of charging many times what another doctor would for the exact same procedure.
For example, how would any patient know that procedure X is charged $2,000 by most doctors rather than the $20,000 quoted?
The GOF was mooted in the early 1980s when the Ministry of Health, the SMA and the Association of Private Medical Practitioners of Singapore felt a need to publish a fee schedule to provide greater transparency for patients. Much work was put in collaboratively by general practitioners as well as by doctors of different sub-specialities, and by the time it was scrapped, there were already four editions.
Contrary to the commission's fears, the medical community is not a cartel and the GOF was never a tool for price-fixing.
In fact, the editor of the fourth edition wrote: 'Practitioners who wish to charge outside this guideline should inform their patients accordingly...' and 'practitioners are encouraged to continue their practice of reducing or waiving fees for patients who cannot afford to pay the usual fees'.
The doctor-patient relationship is a very unequal one. The doctor holds all the cards as he has knowledge that the patient requires. The patient often does not have the time and resource to seek many medical opinions before deciding on treatment. This is especially true for foreign patients.
If we leave the patients without any guidance, patients may be 'fleeced' and Singapore's reputation in the medical field would be short-lived.
The Competition Commission should admit its mistake and advise the SMA to reinstate the guidelines immediately. It should not take six months to 'look at how the medical sector is structured and its practices here and in other countries'.
Dr Huang Shoou Chyuan
CCS's reply in the ST Forum (11.2.09)
I REFER to last Saturday's letter, 'Reinstate guidelines for docs'. Competition issues are often complex and have significant economic impact on many segments of the public. It is, therefore, necessary that the Competition Commission of Singapore (CCS) undertakes a thorough analysis before it concludes whether any practice is anti-competitive. It is not appropriate for CCS to provide specific advice on any competition case without doing so.
Price transparency to consumers should be encouraged. In this regard, CCS supports the practice of service providers clearly publishing and explaining their respective pricing information to consumers. A price recommendation by an association of service providers, on the other hand, entails the association recommending what the industry as a whole should charge. CCS notes that price recommendations are generally held by many competition authorities worldwide not to be in the public interest.
CCS has initiated a detailed study of the issue of fee guidelines in the medical services sector, in view of recent public interest in this subject. The study will examine the local market for medical services to see if there are special circumstances that justify any form of fee guidelines. We will also consider any alternative measures that may improve price information to the consumer. In conducting the study, CCS welcomes all input and views from the medical community and the public.
The writer may wish to note that on Feb 5, the Singapore Medical Association (SMA) submitted a formal application to CCS for a decision on whether its Guidelines on Fees are excluded from the Competition Act's prohibition against anti-competitive agreements. This is the first time that SMA has applied to CCS for a decision. To correct any misperception that the writer may have about the fees to be paid, SMA paid $5,000 to CCS for this application. CCS will respond to the application after completing its evaluation.
Chin Yen Yen (Ms)
Corporate Communications Competition Commission of Singapore