Price Setting and Price Regulation in Health Care: Lessons For Advancing Universal Health Coverage

Price setting and price
regulation in health care

Lessons for advancing Universal
Health Coverage
Sarah L Barber, Luca Lorenzoni and Paul Ong

Price setting and price regulation in health care
ii Price setting and price regulation in health care
Health Coverage
Sarah L Barber, Luca Lorenzoni and Paul Ong

Price setting and price regulation in health care:
lessons for advancing Universal Health Coverage
Sarah L Barber, Luca Lorenzoni, Paul Ong
ISBN 978-92-4-151592-4 (WHO)
WHO/WKC-OECD/K18014
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Lessons for advancing Universal Health Coverage
Foreword and Acknowledgments vii

Glossary and Abbreviations viii
Executive summary x
1. Why pricing is important 1
1.1. How does pricing fit within the commitments for

Universal Health Coverage? 2
1.2. Why intervene in pricing? 3
1.3. Relevance to low- and middle-income settings 4
2. Comparison of case studies 8
Contents 2.1. Demographics and health resources 9

2.2. Health care coverage 10
2.3. Health system characteristics 13
3. Payment methods 15
3.1. The base for payments 16

3.2. Primary care and outpatient specialists 20
3.3. Inpatient care 22
3.4. Long-term care 23
4. Process by which price is determined 28
4.1. Individual negotiations 29

4.2. Collective negotiations 30
4.3. Unilateral price setting 31
4.4. Process of price setting by base for payment 33
5. Technical process of setting the price per unit

of payment 39
5.1. Costing methods 40

5.2. Process of collecting information 43
5.3. From cost submission to price setting for
hospital services 46
5.4. Changing the cost structure 47
6. Aligning pricing with overall policy goals 49
6.1. Adjustments and add-ons to ensure payment

adequacy and fairness 50
6.2. Expenditure control mechanisms 52
6.3. Balance billing limitations and financial
protection54
6.4. Bundled payments 57
6.5. Incentives for quality 58
v
7. Infrastructure for costing and pricing 60
7.1. Institutional entities 61

7.2. Formal stakeholder consultation 64
7.3. Investments in data collection 65
7.4. Information disclosure 68
8. Best practices for low- and middle-

income settings 71
8.1. Investing in data infrastructure 72

8.2. Building institutional capacities 73
8.3. Planning sequenced implementation 74
8.4. Establishing prices that approximate the most
efficient way of delivering care 76
8.5. Using prices as instruments to promote value
for health spending 77
8.6. Strengthening the national role in setting prices 77
8.7. Establishing systems of ongoing revision,
monitoring and evaluation 78
References79
Annexes: Case studies
Australia:
Jane Hall, Maryam Naghsh Nejad, Kees Van Gool and
Michael Woods
England:
Sue Nowak and Alberto Marino
France:
Zeynep Or and Coralie Gandré
Germany:
Jonas Schreyögg and Ricarda Milstein
Japan:
Naoki Ikegami
Malaysia:
Chiu Wan Ng
Republic of Korea:
Soonman Kwon
Thailand:
Viroj Tangcharoensathien, Walaiporn Patcharanarumol,
Taweesri Greetong, Waraporn Suwanwela,
Nantawan Kesthom, Shaheda Viriyathorn,
Nattadhanai Rajatanavin, Woranan Witthayapipopsakul
nited States of America and Maryland:
U
Luca Lorenzoni
vi
Under international commitments to Universal Health Coverage,
the Member States of the World Health Organization are
obligated to strengthen their financing systems to ensure that
all people have access to health services and are protected
against financial hardship in paying for these services. While
payment methods have received a great deal of attention
among policy-makers and practitioners, less attention has been
paid to price setting and how it can also contribute to broader
system objectives. However, if prices are set too high or too
low, they can easily overshadow the incentives in payment
mechanisms.
The objectives of this study are to describe experiences in price

setting and how pricing has been used to attain better
coverage, quality, financial protection, and health outcomes. It
builds on newly commissioned case studies and lessons
learned in calculating prices, negotiating with providers, and
monitoring changes. Recognizing that no single model is
Foreword and applicable to all settings, the study aimed to generate best
Acknowledgments practices and identify areas for future research, particularly in
low- and middle-income settings.
The World Health Organization (WHO) and the Organisation for

Economic Co-operation and Development (OECD) have been
collaborating since 2014 to study health care pricing policies.
The research was guided by Sarah L. Barber, Paul Ong, and
Tomas Roubal from WHO, and Luca Lorenzoni from OECD, who
established the scope and framework for the analysis in
consultation with global and regional experts. We thank the
authors of the case studies for their research and useful
comments on the summary. These authors include Jane Hall,
Maryam Naghsh Nejad, Kees Van Gool and Michael Woods
(Australia); Sue Nowak and Alberto Marino (England); Zeynep Or
and Coralie Gandré (France); Jonas Schreyögg and Ricarda
Milstein (Germany); Naoki Ikegami (Japan); Chiu Wan Ng
(Malaysia); Soonman Kwon (Republic of Korea); and Viroj
Tangcharoensathien, Walaiporn Patcharanarumol, Taweesri
Greetong, Waraporn Suwanwela, Nantawan Kesthom, Shaheda
Viriyathorn, Nattadhanai Rajatanavin, and Woranan
Witthayapipopsakul (Thailand). Professor Naoki Ikegami assisted
with the review of the case studies. Jain Nishant, Indo-German
Social Security Programme, wrote the text box for India. The
case studies were discussed with the research teams, and the
outline for this study was developed at a meeting in Yokohama,
Japan, in January 2019. At this meeting, WHO experts provided
support and guidance, including Peter Cowley, Jon Cylus, Tamas
Evetovits, Tomas Roubal, and Liviu Vedrasco. Lluis Torres Vinals
provided useful comments; Tessa Edejer and Xu Ke provided
statistical review. This document was produced with the
financial assistance of the Kobe Group, and the Yokohama
meeting was supported by Kanagawa Prefecture, Japan.
vii
Glossary and
Abbreviations
Term Abbreviation Definition
Balance billing - When a health care provider bills a patient for a price beyond what is
reimbursable from the patient’s health insurance.
Base for payment - The base or unit of activity on which prices are set. Common base for
payments are fee-for-service, diagnosis related groups, per diem, and
capitation, for example.
Base rate - The standardized payment amount that a provider receives for covered
services. The rate could be adjusted by differences in the cost of living or
other factors.
Bundled payment - A single payment covering a bundle of distinct goods and services
required for the treatment of a given medical condition based on clinical
practice guidelines.
Capitation (also per capita CAP Prospective fixed lump-sum payment per person enrolled for care with a
payment) provider within a given period (typically one year) covering a defined set
of services, independent of whether the services are provided.
Charge - The amount that a provider sets for services before applying any
discounts. The charge can be different from the amount paid.
Coinsurance - Percentage that the insurer pays after the individual deductible is
exceeded, with the intention of joint risk sharing between the insured
individual and the insurer.
Copayment - Fixed payment paid by an individual for health care services at the point
of seeking care, which is not covered by insurance, regardless of the kind
of services provided during the visit.
Contributory health coverage - Coverage paid through employee payroll contributions with employer
cost sharing.
Cost - (For the provider), the total amount incurred in providing a service,
including procedures, therapies, and medications. The actual cost is
typically lower than the price paid.
Cost based reimbursement - Retrospective payments to health care providers based on the cost of
care provided to patients and allowable covered costs.
Cost centre - A defined entity to which direct costs are assigned and indirect costs are
allocated (i.e., organizational or management unit).
Cost object (also cost objective) - A defined entity for which cost information is sought (i.e., patient, service,
department).
Diagnosis Related Group DRG Payment paid to hospitals per admission or discharge, whereby patients
payment (also case-based are classified into groups (DRGs) based on diagnosis and procedures.
payment)
viii Price setting and price regulation in health care

Term Abbreviation Definition
Extra billing - Billing for services or drugs that are not included in the benefits package.
This differs from balance billing, where the amount billed for covered
service is higher than the regulated price.
Fee-for-service FFS Fixed payment for each unit of service without regard to outcomes. It is
typically paid retrospectively by billing for each individual service or
patient contact.
Global budget - Prospective lump-sum payment to a health care provider to cover
aggregate costs over a specific period for a set of services independent
of the actual volume provided.
Line-item budget - Fixed payment to a health care provider to cover specific input costs (i.e.,
personnel, utilities, medicines, supplies, etc.) for a specific period.
Long-term care LTC Activities undertaken to ensure that people can maintain levels of
functional ability consistent with basic rights, fundamental freedoms, and
human dignity.
Multiple payer system - A system in which multiple entities set prices to pay health care
providers.
Pay for performance (also P4P Payments to health care providers for meeting specific performance
results based financing) targets, such as process quality or efficiency measures, or penalties for
poor outcomes, such as medical errors or avoidable readmissions.
Payment for procedure or - Fixed payment for each unit of service or procedure, whereby
service adjustments to prices may reflect substantial additional work as
measured by increased intensity, time, technical difficulty of the
procedure, severity of the patient condition, or physical and mental
effort required.
Per diem - Fixed amount per day for inpatient stay, which may vary by department,
patient, clinical characteristics, or other factors.
Price (also fee, rate, tariff) - Financial amount that a purchaser (i.e., health insurer) or individual pays
to a provider to deliver a service.
Price discrimination - Occurs when an identical service is sold to different consumers at
different prices.
Price schedule (also fee - Detailed list of prices for all providers and hospitals, usually by a coding
schedule) system, i.e., Healthcare Common Procedure Coding System in the United
States of America, by diagnosis-related groups (DRGs).
Residence based coverage - Coverage based on legal residence financed with general tax revenues.
Resource based relative value RBRV A unit of measure that indicates the value of procedures conducted by
physicians, midlevel and other health care providers.
Single payer system - A system in which one entity (the single payer) set prices to pay health
care providers. The payer is typically government.
United States of America USA Abbreviation of the official World Health Organization member state
name for the United States of America.
Universal Health Coverage UHC Commitment made by United Nations Member States to extend coverage
to needed health care services for the whole population, without people
suffering from high health care payments or poverty because of getting
the health care that they need.
User fee (also user charges, - Payment made by a patient to access a service or facility.
cost-sharing)
Voluntary Health Insurance VHI Insurance plans where the decision to join and the payment of a
premium is voluntary. Coverage may be complementary or
supplementary to the basic (primary) benefit package or duplicate it.
Sources: Cashin, 2015; OECD, 2016; WHO, 2017; Le Grand and Bartlett,
1993; authors.
Price setting and price regulation in health care ix

This study was carried out to support countries in meeting
international commitments towards Universal Health Coverage.
It aims to gather experiences in price setting and regulation,
generate best practices, and identify areas for future research.
There is a special focus on the implications for middle-income
settings, which represent more than 70% of the world’s
population. The share of public spending on health in these
settings doubled between 2000 and 2016. This increase in
public spending has been accompanied by new ways of
financing, organizing, and delivering health care. A key question
is how to make use of all health resources – from both private
and public sources – to attain health-related goals.
Health care is far from being a classic market for goods and
services. Individuals are usually represented by a purchasing
agent (i.e., health insurers) instead of operating by themselves,
and do not have complete information. This makes people less
sensitive to prices. However, prices provide important signals to
Executive summary health care providers, given that they determine the level of
financial resources to deliver health care services.
Provider payment systems consist of one or more payment

methods and their supporting systems such as contracting and
reporting mechanisms, which are used to create economic
signals and incentives that influence behaviour. Any payment
method has three dimensions: the base upon which prices are
defined and set; the level of payment per unit of the chosen
base; and the administrative and economic process by which
that price level is determined. This study focuses on these key
dimensions.
Among the case studies reported, the base for payment for
primary care is primarily fee-for-service and capitation; fee-for-
service is typically used in outpatient settings; and diagnosis
related groups are commonly used in hospital settings.1
Increasingly, payment methods have been combined with
specific performance-based rewards or penalties; they have
also been combined across providers to facilitate a more
coordinated and flexible approach to care. All payment models
have strengths and weaknesses; therefore, the impact of each
depends not only on the method chosen but also the price
paid. The price not only ensures that the costs of delivering
services are covered, but also provides incentives for health
care providers. Price adjustments are typically made to ensure
coverage and access, for example, to health care providers in
rural and remote areas; those treating disproportionately high
numbers of low-income or high-cost patients to ensure
coverage and quality; and for facilities providing medical
education. Prices are also adjusted to attain broader health-
related goals.
1 In this study, we use the term “base for payment” for the unit of activity upon which
prices are set (i.e., fee-for-service, diagnosis related groups, per diem, and capitation).
This differs from the “base rate” or the standardized payment that a hospital receives for
covered services.
x Price setting and price regulation in health care

The study generates lessons learned in price setting,
particularly for low- and middle-income settings. They include:
Investing in data infrastructure. In setting the level of

payment, the ways of calculating prices are linked with the
strength of data collection systems about input costs, output
volumes, and outcomes. Low- and middle-income settings can
initiate payment reforms while also building critical capacities
in health information systems and data collection. Where data
are limited, information can be used from available sources
while also investing in data infrastructure.
Building institutional capacities. In several settings,

specialized institutions have been established to separate the
technical task of determining costs from the more political
exercise of negotiating how much to pay for services. In some
The price not only cases, such institutions commission or collect data to estimate
the cost of providing services upon which prices are then
ensures that the costs based. Whether an independent entity or designated
of delivering services institution, characteristics of successful systems include
are covered. Price political independence, formal systems of communication with
adjustments are made stakeholders, and freedom from conflicts of interest. Given
finite resources for health, price regulatory systems can be
to ensure coverage and used to promote greater efficiency and attain value for health
access, for example, to spending for resources from both public and private sources.
health care providers in Planning sequenced implementation. Particularly for settings
rural and remote areas. that employ line-item budgets, substantial long-term planning
is needed to change payment systems, estimate costs, and use
prices and payment systems to reach policy goals. For any
payment reform, the starting point is developing a classification
system of the services that are currently being delivered. Given
that the strength of health systems can affect the speed and
quality of implementation of reforms, continued investments in
broader capacities should receive greater attention including,
for example, clinical guidelines, regulatory frameworks, and
strengthening professional associations.
Establishing prices that approximate the most efficient way

of delivering care. Prices should approximate the cost of
delivering services in the most efficient way that enables
quality and health outcomes. This minimizes incentives for
inappropriate and low value care and enables accurate budget
projections. Costing exercises can be useful if they reveal
information about the underlying cost structure of service
delivery and enable the development of alternative scenarios
about models of service delivery that offer high levels of
efficiency and quality.
Using prices as instruments to promote value for health

spending. Pricing is not only about covering costs but also
providing the right incentives. Pricing, payment systems, and
their regulatory frameworks can be powerful tools to drive
broader health system goals. For example, in some settings,
balance billing is prohibited, and patients are fully reimbursed
for covered services to ensure affordability and access.
Price setting and price regulation in health care xi

Strengthening the national role in setting prices. To align
prices with policy goals, a strong national role is required.
While the methods for price setting vary, we conclude that
unilateral price setting by a regulator eliminates price
discrimination and performs better in controlling growth in
health care costs. In contrast, individual negotiations between
buyers and sellers are the weakest along these same
parameters. Both collective negotiations and unilateral
administrative price setting also have the potential to improve
quality better than individual negotiations.
Establishing systems of ongoing revision, monitoring and

evaluation. Flexibility is needed to adjust to the evolution of
pricing and payment methods, factors outside of the control of
providers and changes in market structure. Many experiments
are underway to adjust prices to achieve broader health policy
goals, such as better coverage, quality, financial protection, and
health outcomes. It is not always clear whether the price set
will result in the intended provider behaviours – or unintended
consequences will occur. Yet, few of these initiatives have been
fully evaluated for impact. This limits the lessons learned both
within and across countries. More systematic testing and
evaluation is critical to inform about the impact of such
initiatives and determine the feasibility of scale-up within a
given setting, and replicability elsewhere.
Policies about pricing and purchasing health care services are

grounded in institutional history and the level of resources for
health. As such, there is no ideal price level or payment
mechanism. Each country has implemented approaches that
help address broader system objectives within a given setting.
Ultimately, it is these objectives that guide policy choices.
Lessons from other settings should be viewed considering their
feasibility and responsiveness to unique contexts.
xii Price setting and price regulation in health care

1/
Why pricing
is important
Price setting and price regulation in health care 1

1.1
How does pricing fit within the
commitments for Universal Health
Coverage?
In 2015, United Nations member states reiterated their
commitment to universal health coverage (UHC) so that all
people have access to quality health care without exposure to
financial hardship (WHO, 2019a). Implementing UHC reflects
three dimensions of coverage: who is covered, what services
are covered, and how much will be paid. In this report, we focus
on the price of health services but omit the prices of
pharmaceuticals and health insurance. Pharmaceutical prices
are covered in detail elsewhere (OECD, 2018; WHO, 2015a).
Pricing health services is a key component in purchasing the

benefits package (the covered services) within the overall
financing system (Evetovits, 2019). Pricing and payment
methods are important instruments in purchasing that provide
incentives for health care providers to deliver quality care. A
second instrument is contracting, in which the conditions for
the payment of services are defined, and prices can be used as
signals to providers. A third is performance monitoring. Where
health care providers are rewarded based on the outcomes
they achieve, these payments also must be priced correctly to
provide the right incentives.
If the price set is too high or too low, it can easily overshadow
the incentives in payment mechanisms. Prices should reflect
actual costs and take into consideration broader health system
goals and health outcomes. If not, unintended negative
consequences could arise. In example, if prices are set too low
for capitation payments, this could result in low quality care,
provider selection of healthier patients, or referral of complex
cases that require a higher intensity of services to another
service provider. Where the FFS payment is low, providers may
try to compensate by increasing volume and providing
additional (unnecessary) services. If prices are not fair, service
quality, efficiency, and sustainability also suffer. In some
settings, low prices that do not sufficiently reward health care
providers are blamed for informal fees to patients, in which the
financial burden falls on individuals and society.
In the case of balance billing, health care providers are

permitted to bill patients at prices higher than the regulated
rates, and the difference is paid by the patient. Under balance
billing, services could be underprovided where patients are
unable to pay – even though the services are part of the
benefits package and valued by communities and societies. In
this case, the government’s commitment to deliver on UHC
would shift some of the financial burden to individuals.
2 Price setting and price regulation in health care

1.2
Why intervene in pricing?
To attain their commitments to UHC, governments are obligated
to take reasonable regulatory and other measures, within
available resources, to achieve the progressive realization of
the right to health care. This is particularly important in health
care markets, which are characterized by such failures as
information asymmetry, lack of information on prices and
quality that preclude consumer choice, adverse selection, and
moral hazard (Arrow, 1963).
For most commodities, pricing is determined based on supply

and demand. Unlike other commodities, payers and consumers
of health care usually know far less than the “seller” (i.e., the
health care provider), who advises about which treatments or
medicines are the best options – while concurrently having a
financial interest in the ultimate decision on what option to use.
For many commodities, consumers assess the price and value of
goods; in health, insurance insulates consumers from the full
price. Given that accurate comparable information about prices
and technical quality are frequently unavailable, the value of
health services is difficult to assess. At the same time, demand
for acute care and hospital services provided in times of health
need is less responsive to price. Information asymmetry is also
present in health insurance markets, since insurers do not know
what health conditions consumers have – thus leading health
insurance companies (where unregulated) to implement policies
to reduce their risks of accepting high risk patients.
Important externalities exist in health, implying that

investments have broad benefits for communities and the
public. Successfully treating someone with tuberculosis, for
example, benefits not only the patient but also the community
in which s/he lives. In this instance, price setting (among other
tools) can be used to ensure adequate funding for public
health goods, such as uncompensated hospital care that benefit
communities; thus, prices should reflect the value of services to
individuals and society. This is particularly important given that
hospitals are, in many cases, obligated to serve all patients with
medical need regardless of ability to pay.
As such, health markets differ from conventional markets in

several key ways (Clarke, 2016). Consumer purchasing power is
either centralized in a single purchasing agency or allocated to
users in the form of vouchers rather than cash. This change in
consumer purchasing power makes consumers less sensitive to
price signals. Non-profit organizations compete for public
contracts, sometimes in competition with for-profit
organizations. Consumers are represented in the market by
agents instead of operating by themselves. In addition, the
price signals that connect purchasers and providers operate in
a rather different way, as prices are not formed directly by the
interplay of demand and supply, but rather are administered,
collectively negotiated or individually negotiated.
Controlling the growth of health care spending while
maintaining or increasing access is a major policy priority of
most governments. Generally, health care spending increases at
rates higher than general inflation. This is a function of both
volumes of care and prices. In the USA, high prices alone are
estimated to account for half or more of the growth in health
care spending (Martin et al., 2014). Wide price variation can be
seen both across countries and within the same country across
regions and facilities (Cooper et al., 2018). Increases in both
prices and volumes can be attributed to the adoption of new
technologies, increases in income, insurance design and
demographics. The demand for health and social services are
expected to increase with population ageing (European
Commission, 2018). In this context, price setting serves as an
instrument to reduce or increase volumes of certain services or
treatment modalities to control costs (Anderson et al., 2003;
Many OECD countries Anderson, Hussey and Petrosen, 2019).
have established price
The progressive realization of UHC implies that all countries
schedules enabling strive to extend or ensure coverage while facing technological
them to purchase progress, ageing populations, and increasing expectations for
services from the good quality health care. Rising health care spending has
private sector. pressured policy-makers to maximize all available health
resources towards meeting these expectations. Governments
frequently draw on the private sector to promote sustainability,
optimal use of resources, and increased choice of care. In doing
so, policy-makers face the challenge of harnessing resources
and efficiency gains while addressing the market failures and
equity concerns associated with the private financing of health
care. Many OECD countries have established price schedules
enabling them to draw on private sector facilities to expand
access to care. This is used to purchase services from the
private sector, provide benchmarks for private insurers, and
negotiate with private insurers and facilities. These experiences
may be informative for low- and middle-income settings.
1.3
Relevance to low- and middle-income
settings
Low- and middle-income countries represent a diverse group of
nations. The 34 poorest countries in the world differ greatly
from high-income countries. Low-income countries focus on
extending access to basic services and, in some cases, rely on
external funding for health (WHO, 2018). Experimentation in
financing health services is also being done as a part of donor
contributions. Health systems challenges in middle-income
countries are similar to those in high-income settings. Middle-
income countries with a gross national income between
US$1006 and $12,235 per capita represent more than 70% of
the world’s population and a large share of the disease burden
(World Bank, 2019). Increases in public spending on health2 are
2 For ease of reading, we refer in this paper to spending by government and compulsory
health insurance as “public” spending on health.

Figure 1
Per capita public spending on health, 2000-16, constant US$
2016, low- and middle-income countries
250 10%
Average annual percentage increase between 2000-16

Per capita health spending. Constant US$ 2016
200 8%
150 6%
100 Annual average 4%

percentage
increase
50 2%
0 0
Low income Lower middle Upper middle
2000
2016
Source: WHO, 2018.
occurring across all countries (WHO, 2018), whereby spending

on health rises with per capita income. However, the share of
public spending on health doubled between 2000 and 2016 in
middle-income countries (Figure 1).
Within the increase in public spending on health, countries are

striving to establish well-functioning health systems towards
attaining UHC. In doing so, they are paying more attention to
value for public spending on health, and the decisions about
how to channel funding and organize services to respond to
people’s needs. This is particularly true for inpatient services
and curative outpatient care, which accounts for 70% of total
public spending on health on average globally (WHO, 2018). As
health systems mature, policies take on greater importance in
ensuring financial protection. Policy decisions about the
services covered, payments to providers, and the conditions for
these payments become the determining factors in driving
patient costs –and far overwhelm any individual care-seeking
behaviours (Getzen, 2006).
In response to these opportunities, many countries are

introducing new ways to finance, organize, and deliver health
care. Understanding the methods for price setting takes on a
higher level of importance where systems are rapidly changing
to account for increasing levels of resources and changing

patient needs. To more strongly align payment with the costs
that health care providers incur in delivery different types of
services, countries are modifying the basis for payment for
health care providers from line-item budgets to alternatives
such as FFS, per diem, and diagnosis related groups (DRGs), and
determining how to price these services. Substantial numbers
of low- and middle-income countries have already established
DRG-based payment systems to pay for acute inpatient care
(Mathauer and Wittenbecher, 2013). Such a move enables
countries to take an active strategic approach in defining what
services are purchased and paid for, and how to link payments
with quality and performance. Further this move allows
purchasers to shift from being a “price and quality taker” to a
“price and quality maker” (Figure 2).
In some low- and middle-income settings, a large share of

health care utilization is in the private health care sector, which
can range from unregulated pharmacies to specialized tertiary
care hospitals. A key question is how to make use of all health
resources – from both private and public sources – to attain
health-related goals. In middle-income settings, high prices in
the private sector can undermine UHC objectives by draining
resources from the public sector where most of the population
accesses services (Barber et al., 2018). Where prices and
premiums are unaffordable for most people, the private sector
does not contribute to improving population health
commensurate with its share of resources. Accordingly,
governments are obligated to address high prices because of
their implications for equal access to health services.
Figure 2
Moving from passive to strategic purchasing
Passive purchaser Strategic purchaser
Resource allocation Performance based

using norms contracting
No selection of providers Selective contracting
No quality monitoring Quality improvements
and rewards
Price and quality taker Price and quality maker
Source: Evetovits, 2019.

Some aspects of health systems in low- and middle-income
countries should be considered when implementing changes in
financing systems. There are higher rates of poverty; middle-
income countries are home to 73% of the world’s poor (World
Bank, 2019), which underscores the importance of protection
from catastrophic health spending and promoting equitable
access to services. These settings tend to have less robust
regulatory environments for controlling quality in health care
facilities (public and private) and medical products, and less
advanced professional associations (Clarke, 2016). In settings
with weaker professional associations, changes in the base for
payment to capitation has resulted in an under-provision of
services (Mills et al., 2000). Some level of hospital autonomy is
needed to ensure that hospitals have decision-making
authority to respond to incentives for efficiency. Moreover,
purchasing arrangements assume a level of managerial
Middle-income countries capacity, including financial management, systems of
are home to 73% of information about health, utilization, and expenditures, and the
the world’s poor. This ability to enforce contracts. Experience from high-income
underscores the countries shows that DRG-based payments are complex and
require careful monitoring of care quality as well as volumes.
importance of protection Systems are needed to monitor and adjust prices to align with
from catastrophic health system-wide objectives. These institutional factors affect the
spending and promoting speed in which changes in purchasing can be implemented.
However, the process of change is both incremental and
equitable access to dynamic – and many countries implement changes in financing
services. while also building critical capacities in health systems during
implementation (Mathauer and Wittenbecher, 2013).

2/
Comparison of
case studies

2.1
Demographics and health resources
Context and institutions are key factors in determining the
choice of payment systems. A range of middle and high-income
settings were selected for the study (Figure 3). Seven are OECD
member states. Thailand and Malaysia are both upper middle-
income countries. In three of these countries, more than one
quarter of the population is 60 years or older (Japan, Germany,
and France). In three other settings (Maryland, Thailand, and
Malaysia), the population is relatively young.
Figure 3
Characteristics of case study settings
Inputs per 1000 population
Setting Population 2015 % of population GDP per capita, Physicians Nurses and Hospital
>=60 years US$ 2016 midwives beds
Australia 23,799,556 21 54,069 3.5 12.4 3.8
England 55,670,000 23 31,200 2.8 8.4 2.6
France 64,457,201 26 36,826 3.2 10.6 6.5
Germany 81,707,789 28 42,456 4.2 13.8 8.3
Japan 127,974,958 33 38,640 2.4 11.2 13.4
Malaysia 30,723,155 10 9,508 1.5 4.1 1.9
Republic of Korea 50,593,662 20 27,785 2.3 6.9 11.5
Thailand 68,657,600 17 5,911 0.5 2.3 2.1
Maryland, USA 6,042,718 15 55,404 2.6 NA 2.5
Sources: UN, 2017, 2019; United States Census Bureau, 2019; World Bank,
2019.
Wealth is correlated with the level of inputs to the health

sector. Decisions about the allocation of resources is subject to
aggregate constraints, whereby the first step is determined by
the total resources available (Getzen, 2006). The total amount
of resources for health varies widely across these settings.
Current health expenditure as a share of GDP ranges from 17%
in the USA to less than 4% in Malaysia and Thailand (Figure 4).
The source of most spending in all settings is compulsory
(i.e., set aside by the government for certain health programs or
initiatives), except for Malaysia, where public compulsory and
private voluntary expenditures are reported as equal shares.

Figure 4
Current health expenditures as a share of Gross Domestic
Product (GDP), 2016 or most recent year
16
14
12
10
8
% of GDP
0
USA France Germany Japan United Australia Republic Thailand Malaysia
Kingdom of Korea
compulsory
voluntary
Source: WHO, 2019b. Note: Compulsory or mandatory refers to the mode

of participation, whereby coverage of the population is automatic or
universal, and participation is mandatory by law including social health
insurce or compulsory private health insurance. Voluntary refers to
coverage obtained at the discretion of individuals or firms, including
voluntary private health insurance. Spending on capital items is not
included.
2.2
Health care coverage
The nine settings included in the study each represent
variations in the main source of health care coverage. Australia,
Malaysia, England, and Thailand’s Universal Coverage Scheme
have systems of health coverage based on residence or
citizenship. The other settings have employment-based
contributory health coverage and vary by the number of payers.
In the Republic of Korea, there is a single payer system,
whereas in France and Japan, multiple payers exist with
automatic (compulsory) affiliation. In Germany and the USA,
multiple payers exist with choice of affiliation (Figure 5).

Figure 5
Main source of health care coverage for case study settings
Main source of basic Country

health care coverage
Citizen entitlement Australia, Malaysia,
Thailand (UCS, CSMBS),
England
Employment-based Single payer Republic of Korea,
converage Thailand (SHI)
Multiple payers with France, Japan
automatic affiliation
Multiple payers with Germany, USA
choice
Sources: Paris, Devaux and Wei, 2010; Jongudomsuk et al., 2015. Note:
UCS: Universal Coverage Scheme; CSMBS: Civil Servant Medical Benefits
Scheme; SHI: Social Health Insurance.
Among the settings studied here, voluntary health insurance

(VHI) plays different roles (Figure 6). VHI can generate
additional financial resources for the health care system. It
should be noted that private funding is not equal to private
provision, and private insurance can pay for covered services.
At the same time, it can contribute to cost escalation, given that
many cost-control measures used in the public sector – such as
price regulation and global budgets – are not typically
employed in the private sector.
In France, Germany, Republic of Korea and Japan, private

insurers focus on covering the gap between public
reimbursements and actual fees, as well as providing access to
additional services (complementary insurance). In Germany, a
share of the population opts out of the public social insurance
program and obtains care from private insurers. In Japan, VHI
developed as a supplement to life insurance and offers
additional income in the case of illness (The Commonwealth
Fund, 2019). In Australia, Malaysia, and Thailand, VHI also
provides coverage for additional services. In the United
Kingdom, people can purchase VHI to reimburse care in a
private facility, which may offer quicker access for elective
services (supplementary insurance).

Figure 6
Spending on private voluntary health insurance, population
and services covered, categorized by insurance role
Setting % of total % of Services covered

health population
spending covered
A. Complementary: covers user fees
France 13 95 Covers copayments for services included in the social insurance basket
based on regulated prices; varying coverage of extra billing and extra
services. Deductibles cannot be covered.
Germany 9 27 Outpatient care, per diem cash benefits for hospitalization.
Republic of 7 >70 Copayment for public insurance and payment for uninsured services.
Korea
B. Complementary: covers additional services
Germany 8.9 27 Dental and eye care, more extensive ranges of services not covered by
social health insurance; in addition to full coverage for self-employed.
United 3.4 5 Dental care, complementary and alternative medicines, more rapid and
Kingdom convenient access to care, especially for elective hospital procedures.
Japan 2 88.5 Copayments; lump-sum payments when insured persons are hospitalized
or diagnosed with cancer or another specified chronic disease, or through
payment of daily amounts during hospitalization over a defined period.
USA 50 14.6 Persons eligible for public benefits, i.e., Medicare can purchase VHI for
additional coverage including long-term care; spending figures also
include primary care for people covered through employers.
C. Supplementary: amenities, choice, faster access
United 3.4 9 Faster access, choice of private provider and of specialist acting in a
Kingdom private capacity, better amenities.
Australia 9 47 (hospital) Choice of providers (particularly in hospitals), faster access for
56 (general nonemergency services, and rebates for selected services.
treatment)
Malaysia 10 NA Private hospital access, faster access.
Thailand 7 24 Exclusion of prior conditions and older persons; private hospital and
faster access although more expensive.
Sources: Sagan and Thomas, 2016; Commonwealth Fund, 2019; case

studies (see annexes).
The extent of government regulation of private health insurance

varies. Factors contributing to stronger regulation include the
presence of private insurers, insurance policies about access,
and level of premiums. Experience suggests that price setting
for the private sector alone can create incentives for providers
to shift care to other providers that are not subject to regulation.
This can inhibit greater coverage, efficiency, and health
outcomes (Kumar et al., 2014). Experience from France shows
that the private insurance market can be effectively regulated
with financial incentives (i.e., fiscal rebates) to reduce patient
selection and price escalation.

2.3
Health system characteristics
Price setting and systems of purchasing are dependent on key
features of health systems that vary considerably across
settings. For example, the OECD countries in this study have
robust regulatory systems. This affects the degree of
competition among purchasers and providers and choice of
payment and price negotiation methods. The strength of
professional associations affects systems of education and
self-regulation. Strong professional associations enable formal
systems of representation for price negotiations. In addition,
market concentration is an important determinant of
negotiating power, as seen in the USA, which can affect prices.
Figure 7
Mechanisms to nudge values towards Universal Health Coverage
Mechanism Instrument Rationale
Command and Control Health Law Prohibition on unlicensed care
Command and Control Minimum Facility Requirements Indicator of Accreditation
Command and Control Clinical guidelines and standards Standard of care usually not complete
Command and Control Issuance of license Can be based on geographical location and
needs
Command and Control Accreditation Done by professional body and tie to health
insurance payment eligibility
Financial Incentives Funding to private general practitioners, Will need mechanism to monitor if service is
(including price control) hospitals, labs, pharmacies, etc. of good quality
Self Regulation Professional subcommittee function Professional associations provide training,
empowerment, etc.
Source: Cowley, 2019.
Figure 7 illustrates key instruments used across the WHO

Western Pacific Region, and places price regulation within the
broader context of attaining the goal of UHC. The capacity of the
health purchaser is a key determinant of the choice of payment
methods, given that complex systems require higher capacity to
collect and analyse information, and ensure standards of quality
care. In some low- and middle-income settings, health laws may
be weak or poorly enforced, which can result in technically
substandard care. Formal systems of accreditation, which are
assumed for high-income countries, may not exist or operate as
focused accreditation for specific services or categories of
facilities. The foundation for payment systems, particularly for
bundled payments, is clinical care pathways that may not be
implemented in all settings. The absence of these mechanisms
limits choices; however, these supporting policies and
instruments can be developed over time.

Weak information systems are particularly challenging in many
countries. Mills (2011) analysed the impact of weak information
systems on financing in four low- and middle-income countries
(Ghana, Zimbabwe, India, and Sri Lanka). She reported poorly
developed cost accounting systems in hospitals, limited data to
cost public services, and lack of information about private
facilities and activities. These factors represent capacities that
affect the speed of implementation of payment mechanisms.

3/
Payment methods

Price setting is central to establishing sound payment systems
for health and hospital services. Factors contributing to
determining price levels include the total amount of public
money spent on health, service delivery costs, wages for
specialists and other health workers, as well as the burden of
disease and its complexity. This paper focuses on the subset of
settings described in the nine case studies to assess how price
setting is integrated into provider payment systems.
Reinhardt (2006, 2011, 2012a) identified three main

dimensions of payment methods for health care:
__ The base or unit of activity upon which prices are defined
and set.
__ The level of the payment or price per unit of the chosen
base.
__ The administrative and economic process by which that price
level is determined.
Each of these dimensions is important in aligning payment

systems with the goals that health systems are trying to achieve
and balancing the interests and financial risk taken by patients,
health providers, payers, and communities. This section focuses
on the base for payment, or the unit of activity upon which
prices are defined and set.
3.1
The base for payments
Building on existing studies (Berenson et al., 2016, Miller,
2007), the base for payments are described by the main
category of payment and the extent to which they contribute to
(or detract from) broader health systems objectives (Figure 8).
Budget-based line item and global payments are typical in

many low- and middle-income settings, but these are gradually
being replaced by other methods (Mathauer and Wittenbecher,
2013). This is because such methods are not strongly aligned
with the costs that health care providers may incur in delivering
different types of services; as such, they may provide incentives
for under-provision of needed care. Line item budgets specify
detailed amounts for each line item (i.e., personnel, medicines,
supplies, etc.) based on the previous year’s budget allocation.
The advantages of line-item budgets are predictability and
control. At the same time, they are not linked to the type and
volume of services provided, nor do they provide any
incentives for efficiency or quality. Global budgeting has
replaced line-item budgeting in many settings that rely on
regulation to control health spending. A global budget provides
fixed funding for a specific population group and offers more
flexibility in allocating resources. Like line-item budgets, global
budgets are commonly based on prior years’ allocations,
although capitation and other methods can be used (Berensen
et al., 2016; Miller, 2007).

Figure 8
Main categories of base for payments, and whether they could
contribute to (+) or detract from (-) health system objectives
Health system outcomes
Base for payment Increasing Increasing Controlling Promoting Promoting Administrative Transparency
utilization volume expenditures efficiency quality of ease
(number of (number of care
cases) services)
Budget
Line item budget – – + – unclear + +

Global budget – – + unclear unclear + –
Activity based
Fee-for-service + + – – unclear + +
Per diem + + – – unclear + –
Diagnosis Related + – unclear + unclear – +
Groups (DRG)
Population based
Capitation – – + + unclear + –
Consolidated
Bundled episode unclear + unclear + unclear – –

Global capitation – – + unclear unclear + –
Incremental
Pay for performance + + unclear unclear unclear – +
Sources: Geissler et al., 2011; Berenson et al., 2016; authors.
Payment methods directly linked to activities include FFS, per

diem, and DRGs. These approaches require a well-defined
planned episode of care and strong evidence that such care
will achieve the desired outcomes. FFS is typically based on a
schedule that lists the prices for individual services, with the
definition of services based on established classification codes,
such as the Current Procedural Terminology.3 Fees are
developed using relative weights or relative value units. One
example is the resource-based relative value scale (RBRVS). The
RBRVS was initially developed in the 1990s for the Medicare
program in the USA and is now commonly used in other
settings. It assigns a relative value to every physician procedure
or service based on two main variables: the relative amount of
physician time, level of skill, training, and intensity in providing
a given service, and the costs of maintaining a practice
including rent, equipment, supplies, and non-physician staff
costs. The relative value is multiplied by a fixed conversion
3 The Current Procedural Terminology is a numeric coding system used primarily to identify
medical services and procedures furnished by physicians and other health care
professionals (AMA, 2019).

factor (the base rate) to determine the price. The limitations in
RBRVS include values inflated for specialist payment services
and insufficiently valuing time and effort required to manage
patients with complex conditions and multi-morbidities
(Berenson and Goodson, 2016).
The FFS method rewards activity. It tends to result in an over-

provision of services because of the incentives for volume
regardless of patient need. Per diem payments offer a fixed
amount per day of hospital or residential care regardless of
care provided or costs incurred. In many settings, per diem
payments are adjusted for case mix or estimated for each
hospital ward or specialty. They are administratively simple but
provide incentives for longer lengths of stay. In contrast, DRGs
provide strong incentives for reducing length of stay. DRG
payments group patients with similar clinical characteristics,
A growing number of use cost information to determine weights based on average
provider payment treatment costs, and apply a conversion factor to generate a
price for each DRG. In comparison with FFS, DRGs help to
mechanisms are contain costs by bundling all goods and services provided
emerging that explicitly during hospitalization into one unit (base) for payment (Annear
seek to align payment and Huntington, 2015). In many settings, DRGs have replaced
incentives with health global budgets in order to reward hospital activity (Berenson et
al., 2016). A key drawback is administrative complexity.
system objectives.
Ongoing evaluations Capitation is a population-based payment, whereby a fixed
payment is made prospectively for a defined benefits package
are essential. per person for a period, regardless of the services provided.
Capitation typically adjust for age and gender but not for health
status. Primary care capitation generally requires a system in
which a gatekeeper or a medical home provides routine care
and approves referrals to other health care providers. With a
fixed amount, the doctor has a financial incentive to reduce
unnecessary care and thus control costs. At the same time,
there is an incentive for an under-provision of care and
referring complex patients to other health care providers.
The level of aggregation of the services included in the price is

a factor in determining the level of financial risk sharing
between the payer and provider. FFS payments are the most
highly disaggregated (the least bundled) and the global budget
is the most aggregated (the most bundled). In the case of FFS
payments, health care providers can bill more individual
services to cover their costs. Therefore, risk sharing is in favor
of the providers, and the payers bear the financial risk. In the
case of global budgets and capitation payments, the price is
highly aggregated. For example, a capitation payment could be
expected to cover many kinds of services for a given person
over the course of a year. In this case, the health care providers
receive one payment regardless of the services provided.

Therefore, the payer faces limited financial risks linked to the
type and amount of services provided, because there is
certainty about the expenditure per person covered.
Figure 9
Predominant base for payment for primary care, by type of
provider
Setting Remuneration of provider setting Remuneration of

physicians
FFS P4P Global Cap Other Salary FFS

budget
A. Private practice group
Australia x x x
Japan x x x
USA x x
B. Private solo practices
France x x x x x x
Germany x x x
England x x
Republic of Korea x x x
Thailand (SHI) x x
Thailand (UHC) x x
C. Public clinics
Thailand x x
Malaysia x x
Sources: case studies (see annexes). Note: FFS: fee-for-service; P4P: pay for
performance; Cap: capitation; SHI: Social health insurance; UCS: Universal
Coverage Scheme. Primary care and outpatient specialists are not
differentiated in Japan or the Republic of Korea. In England, block contracts
are still the predominant payment mechanism for the community sector
and mental health sector. In Thailand, SHI FFS refers to subcontractors; for
UHC and public clinics, capitation is inclusive of salaries.
Integrated approaches attempt to combine payments across

sectors to facilitate a more coordinated and flexible approach
to care. Such integration can balance the objectives of
maximizing beneficial incentives and minimizing potential
unintended consequences of different methods (Cashin, 2015).
Several kinds of consolidated base for payments exist, such as
bundled episode payments and global capitation. A bundled
payment methodology involves combining, or blending, the
payments for physicians, hospitals, and other health care
provider services into a single amount. Bundled episode
payments provide a single amount for all services that cover
care provided over one episode from beginning to end.

Extending the definition of an episode beyond discharge to
follow-up care has been done to motivate health care providers
to improve care coordination, communication, reduce costs, and
ultimately improve quality of care in addition to lowering costs
and utilization. Unintended consequences may include
incentives for more cases and procedures that may not be
clinically warranted to make up for lost revenues and the
under-provision of patient care. Further, administrative costs
may be high, not all procedures can be bundled together into
one package, and risk-adjustment is needed for high-cost,
high-need patients. Evidence about bundled payments is quite
limited and the impact to date is mixed (Bertko and Effros,
2011; Delbanco, 2018).
Under global capitation, one payment is made to an integrated

health system that is responsible for delivering the primary and
referral service package to a relatively large defined population.
Payments are typically adjusted for age, sex, and health status.
The provider has an incentive for efficiency and cost control, and
the payment method promotes integrated care and coordination.
However, similar to bundled payments, the needs of high-cost,
high-need patients may not be sufficiently covered.
Traditional ways of paying health care providers – such as FFS

and capitation – do not explicitly reward providers for
delivering better quality care. A growing number of new
provider payment mechanisms are therefore emerging that
explicitly seek to align payment incentives with health system
objectives by rewarding the achievement of targeted
performance measures. Mixed impact of these incentives has
been reported, however, and ongoing evaluations are essential
(Eijkenaar et al., 2013). Studies have not consistently found
associations between the amount of the incentive payments
and behavioural change (Scott, Lui and Yong, 2018).
3.2
Primary care and outpatient specialists
The most common means of purchasing primary care services is
through capitation and FFS; and outpatient services are
commonly purchased through FFS, in which health care
providers are reimbursed for the activities that they carry out
(Figures 9 and 10). FFS schedules are used in France, Japan,
Australia, Republic of Korea, the Thai Social Health Insurance
scheme, and the USA. In Germany, physicians (especially
general practitioners) receive a capitation or lump-sum
payment per patient. In countries such as Germany and the
USA, the schedule may vary by payer or region.
To counter the disadvantages of FFS (such as lack of incentives

for quality and incentives for volume), it can be combined with
other mechanisms to promote efficiency and cost control. FFS
has been combined with pay for performance (P4P) in France
and the Republic of Korea, and capitation in Australia, France,
and England. Under Medicaid in the USA, states commonly
make incentive payments to physicians, including those
practicing at academic health centres, those participating in
primary care coordination and management, home health care;
and pay for performance initiatives.
Figure 10
Predominant base for payment for outpatient specialist care,
by type of provider
Setting Remuneration of provider setting Remuneration of

physicians
FFS P4P Global Cap Other Salary FFS

budget
A. Private practice group
Australia x x
Japan x x x
USA x x x x
B. Private solo practices
France x x x
Germany x x x
England x x
Republic of Korea x x x
Thailand (SHI) x x
C. Outpatient department of public hospitals
Australia x x
Thailand (UCS) x x x
Malaysia x x
Source: case studies (see annexes). Note: FFS: fee-for-service; P4P: pay for
performance; Cap: capitation; SHI: Social health insurance, UCH: Universal
coverage scheme. In Thailand, capitation payments are inclusive of salary.
In Japan, payment is made to the facility and not to individual physicians.
In England capitation payments are used for primary care, and

FFS is applied for outpatient specialists. It can be noted that the
general practitioner funding formula for capitation payments in
England do adjust for morbidity and mortality. In Malaysian
public facilities, global budget is used for both primary care
and outpatient specialists, whereby a prospective lump-sum
payment is made to health care providers to coverage
aggregate costs. In Thailand, the Universal Coverage Scheme
that provides care for most of the population uses capitation as
base for payment for primary and outpatient specialist care,
with the capitation payment inclusive of salary. Malaysia
remunerates physicians in the public sector through salary
payments. In France, an increasing number of general
practitioners working in primary care practice are salaried.
3.3
Inpatient care
In many settings, inpatient payment methods in public hospitals
employ DRGs as the base for payment (Figure 11). Implementing
DRGs requires classifying health care services and patient
case-mix from the most to least complex and assigning prices to
them. The financial incentives in the DRG payment have
provided strong incentives for changing hospital behaviours.
Figure 11
Predominant base for payment for acute inpatient hospital
services, by type of provider
Setting Public hospitals Private non-profit Private for profit
Australia DRG Procedure/service Procedure/service
England DRG Procedure/service Procedure/service
France DRG, bundled payments for DRG, bundled payments for public DRG, P4P
public health services, P4P health services, P4P
Germany DRG DRG DRG
Japan Case-weighted per diem Case-weighted per diem (non- Case-weighted per diem (non-
(non-acute); Diagnosis acute); Diagnosis procedure acute); Diagnosis procedure
procedure combination (acute); combination (acute); FFS combination (acute); FFS
FFS (Outpatient) (Outpatient) (Outpatient)
Malaysia Global budget FFS FFS
Republic of FFS FFS FFS

Korea
Thailand (UCS) DRG, global budget, DRG, global budget, central DRG, global budget,
central reimbursement reimbursement central reimbursement
USA (public) DRG, per diem DRG, per diem DRG, per diem
Source: case studies (see annexes). Note: DRG: Diagnosis Related Group;
FFS: fee-for-service; P4P: pay for performance.
The Republic of Korea primarily uses FFS for both public and
private hospitals, with limited use of DRGs. Malaysia also uses
FFS in private hospitals. Japan uses diagnosis procedure
combination for acute care and case-weighted per diem for
non-acute care in both public and private hospitals, which can
be combined with FFS. By bundling together hospital and
physician payments into one unit, Japan addresses the problem
of volume and substitution (Ikegami and Anderson, 2012).
Other predominant base for payments include combinations
such as DRGs, bundled payments for public health services and
P4P in France; DRGs, global budget, central reimbursement in
Thailand; and global budget in Malaysian public hospitals. In
settings that use global budgets, prices are similarly estimated
for budget allocations.

3.4
Long-term care
The demand for long-term care (LTC) services is increasing, as
well as its importance in health care and social spending (de la
Maisonneuve and Martins, 2014; WHO, 2017). This is related to
the size and growth of older population groups, many of whom
require not only medical care but also assistance with activities
in daily living, such as washing, dressing, cleaning and cooking.
LTC encompasses both kinds of support in most settings. The
base for payment method varies by setting and categories of
facility (Figure 12). For most of the settings in this study,
assessments are in place that restrict access to government
benefits and determine the financial amount for which
beneficiaries are eligible. The common thread is the adjustment
of the payment level based on level of the complexity of the
health condition, physical functioning and medical needs.
In Australia, the federal government subsidizes non-medical

care and support for older persons. The subsidies are held by
consumers (for home care) or providers (for long-term
residential care). Older persons contribute to the cost of their
care and accommodation based on means testing, and
government subsidies are available for those with low incomes
and assets. Annual and lifetime caps are in place to limit the
level of means-tested care fees that residents pay. In Australia,
the level of funding to the provider is determined by the Aged
Care Financing Instrument (ACFI), which consists of 12 sets of
questions about care needs and two diagnosis sections.
Australia established in 1997 the position of the Aged Care
Pricing Commissioner. The Commissioner is an independent
statutory office holder who reports to the Minister. The
Commissioner’s role is to increase the level of transparency in
the pricing of residential aged care services and ensure that
aged care recipients are charged appropriately through
approval of prices beyond the maximum set by the federal
government. In addition, the Aged Care Financing Authority
(ACFA) is a committee of experts who provide independent
advice to the government on funding and financing issues.

Figure 12
Payment methods for long-term care and the basis of
adjustment for health need
Setting Facility Payment method Basis of adjustment for health need

type
Australia Nursing A means tested medical care fee is applied based on the The ACFI consists of 12 sets of
home Aged Care Financing Instrument (ACFI) to determine questions and two diagnostics sections
need. Payments are covered by residents with to determine the overall care profiles
government subsidies, including a basic daily fee for and the average cost per stay per
residential services (covered by residents), person.
accomodation fees (paid by residents and government),
and fees for any additional services (paid by residents).
England Nursing All costs are covered for those with long term conditions The NHS Continuing Health Care
home determined as eligible for National Health Service (NHS) assessment measures breathing,
Continuing Health Care. A weekly contribution is made nutrition, continence, skin, mobility,
for those who don’t meet these requirements but communication, cognition, behaviour
require some nursing care (£158.16 per week). Other and other dimensions.
nursing home costs are means tested. For those on very
low incomes, the local authority pays.
France Long term All facilities (private or public) are paid for under the GMPS measures 238 condition-profiles
residential care package, including long-term care. The case-based by evaluating 50 clinical conditions
care payment is adjusted for patient need based on scores and 12 profiles of care. For each
using the iso-weighted care group (GPMS). Accomodation condition-profile, eight resource
is paid by the patients. groups are delineated. These groups
define the social care plan, based on
Home care Health care prices are fixed by the social health an assessment of the dependency
insurance fund with fees for services. Prices for social calculated using the Gerontology
care services are unregulated. Reference prices are used Autonomy and Iso-Resource Groups
to calculate subsidies (based on the level of autonomy). model, which measures activities in
daily living.
Germany Outpatient Care is covered by compulsory long-term care (LTC) Financial contributions by LTC
and home insurance. All outpatients receive a monthly lump sum insurance depends on the enrollee’s
care for short-term inpatient care, semi-inpatient services at need for nursing care. Patient needs
night, or services to support relatives. Additional are evaluated based on an assessment
monthly contributions are provided if all services are of physical, medical, cognitive and
done at home, for professional outpatient services, and psychological needs, and the person’s
for inpatient services. ability to live independently and social
interactions. Patients are graded on a
Nursing Nursing care charges are negotiated individually scale from 0 to 100 and allocated to
home between a nursing home, welfare organisations and the one of five stages.
LTC funds, whose enrollees contribute at least 5% of
the nursing home’s days. Patients in nursing homes
contribute to nursing home costs in five different ways:
fixed copayment; payment for housing, utilities, and
meals; investment costs; training levy set by the state;
and other additional services.
Japan Health Case based payments are adjusted for patient needs, Seven eligibility levels are based on
facility for and financed from compulsory LTC insurance. The functional capacity.
elders maximum cash entitlement is determined by functional
capacity, and ranges from $50 to $350 per month.
Beneficiaries must pay coinsurance ranging from 10%
to 30% based on household income. Compulsory LTC
insurance covers home helper visits and visiting nurse
services; day care; loan of wheelchairs; care provided
prior to going to health facilities; and LTC medical
facilities.

Setting Facility Payment method Basis of adjustment for health need
type
Republic Long term A per-diem case-based payment is determined by Five different functional levels.
of Korea care medical need. Public LTC insurance is provided. The
hospitals benefits package includes home and institutional care;
home-visit care; nursing; bathing; and assistive devices
such as wheelchair, walker, and bath chair, etc. for home
care services; aged care facilities; and housing for
institutional services. The benefits ceiling per month
for residential care depends on five different functional
levels determined by a health needs assessment.
USA Skilled A predetermined per diem payment is paid based on The PDPM uses five case-mix adjusted
(Medicare) nursing patient needs. The payment is expected to cover all components: physical therapy,
facilities operating and capital costs, with high-cost, low- occupational therapy, speech-language
probability ancillary services (i.e., magnetic resonance pathology, non-therapy ancillary, and
imaging and radiation therapy) paid separately. nursing. Each resident is classified into
Adjustments are made for geographic differences in one group for each component.
labour costs and case mix. In 2019, the Patient Drive
Payment Model (PDPM) will be used that classifies
residents into a separate group for each case-mix
adjusted component and each has their own case-mix
indexes and per diem rates.
Thailand Home visit Fixed fee per patient. -
Source: case studies (see annexes). Note: LTC: Long-term care; P4P: pay for
performance; NHS: National Health Service.
In England, all costs are covered for those with long-term

conditions assessed as eligible based on a Continuing Health
Care assessment, measuring basic physical and cognitive
functioning, whether at home or in long-term residential care.
A weekly contribution is made for those who don’t meet these
requirements in residential care but who require some nursing
care. All nursing home costs are means tested. Non-medical care
costs for low-income patients are covered by the local authority.
In France, nursing home facilities, whether private or public, are

funded by case-based payments. There is a three-part tariff
comprised of a care package paid by social health insurance, a
long-term care (or dependency) bundle paid by the local
authorities, and an accommodation fee paid by the patient. The
care package for each patient is calculated based on the
iso-weighted care group (GPMS) scores, which generate 238
condition-profiles corresponding with the average care needs
and dependency level of people living in the facility. The
average level of resources required for the 238 profiles was
defined by specialists and reported as points per cost item. The
dependency level is determined by the Gerontology Autonomy
and iso-resource Groups. This instrument uses ten variables
measuring physical and mental capacities and seven variables
for domestic and social activities (i.e., cooking, household tasks,
mobility). For people living at home, medical and social care
services are provided and paid for separately. Health care is
financed under regulated health insurance prices. Social care
services are provided by other public and private entities, and
prices are not regulated. However, reference prices are used by
the government to calculate the amount of the subsidies, and
these reference rates vary by local authority (département)
(from 13 EUR to 24 EUR per hour).
In Germany, LTC insurance is compulsory, and financial

contributions vary based on the need for nursing care.
Evaluations of patient need are based on physical, medical,
cognitive and psychological assessments, and the ability to live
independently. These assessments are graded on a scale from 0
to 100, which is divided into five stages of need. All people
who receive care in an outpatient setting receive a monthly
lump-sum contribution for short-term inpatient care, semi-
inpatient services at night or for services that support relatives.
In addition, they receive a monthly contribution of between
In Japan, LTC insurance EUR 316 to 901, if services are entirely provided by the family
is compulsory for and relatives at home; EUR 689 to EUR 1995 for professional
outpatient services; and EUR 700 to EUR 2005 for inpatient
everyone 40 years and services.
older. The fees have
For nursing homes, prices are calculated on a per diem basis.
been revised to align If the monthly sum of nursing care charges is higher than the
with policy goals. monthly lump-sum payment, residents pay the difference
irrespective of their level of need. Nursing care charges are
negotiated individually between a nursing home, welfare
organizations and LTC funds, whose enrollees contribute at
least 5% of the nursing home’s nursing days. During these
negotiations, nursing homes explain any increase in fees.
Nursing home cost data are benchmarked based on size, and
those with costs in the lower one-third are deemed cost-
efficient. Patients contribute to nursing care charges by paying
a fixed copayment based on the monthly average of nursing
care charges, after deducting monthly LTC contributions and
divided by the number of residents. Patients also cover costs
for housing, utilities, and meals; investment costs of nursing
homes (i.e., building, equipment and maintenance); a training
levy; and additional costs, such as wellness services, superior
housing and individual meal plans.
In Japan, LTC insurance is compulsory for everyone 40 years of

age and older. Benefits are restricted to services, and the
maximum cash equivalent is determined by seven eligibility
levels. The levels are based on functional capacity and range
from about US$50 to $350 per month. Beneficiaries must pay
coinsurance, ranging from 10% to 30% based on household
income level. The fee schedule has the same structure as that
of the health insurance. The fees and conditions of billing have
been revised to align with policy goals. For example, bonus
payments for home care agencies are given to employ more
experienced workers. The fee schedule is revised every three
years, and the base rates differ according to geographic
adjustments (with Tokyo as the highest at 11.4% above the
base rate).

The Republic of Korea introduced public insurance for LTC,
managed by the National Health Insurance Service. The benefits
package includes home and institutional care, home-visits for
activities in daily living; assistive devices; aged care facilities
and institutional services. The benefits ceiling for residential
care depends on the need assessment. The payment for
residential LTC facilities is per diem adjusted for case mix using
a health assessment of five functional levels of the beneficiary.
The fee is determined by the insurance service, with no
negotiation of fees with providers, based on an analysis of
provider activity and cost data.
Starting in 2019, the Medicare program in the USA will apply

per diem case-mix adjusted payments for nursing homes using
the Patient-Driven Payment Model (PDPM). Five case-mix
adjusted components are used: Physical Therapy (PT),
Occupational Therapy (OT), Speech-Language Pathology (SLP),
Non-Therapy Ancillary (NTA), and nursing. Each resident is
classified into one group for each of the five components,
mainly based on the primary diagnosis clinical category, and
function and cognitive levels. A resident may be assigned to
one of 16 PT groups, 16 OT groups, 12 SLP groups, 6 NTA
groups, and 25 nursing groups. Each component has their own
associated case-mix index and per diem rate. Additionally, the
PDPM applies per diem payment adjustments to three
components (PT, OT, and NTA) to account for variations in
resource use. The adjusted PT, OT, and NTA per diem rates are
then added together with the unadjusted SLP, nursing
component rates and the non-case-mix component to
determine the full per diem rate for a given resident.

4/
Process by
which price is
determined

Once the base for payment is established, there is an
administrative process or negotiation by which prices are
determined. These processes can be grouped into three main
methods:
__ Individual negotiations between providers and payers.
__ Negotiation between associations of providers and payers.
__ Unilateral administrative price setting.
In this section, we review each in turn, discuss implementation

issues, and then present practical examples.
4.1
Individual negotiations
Under individual negotiations, prices are agreed upon through
negotiations between individual health insurers or self-paying
patients and individual providers of health care services.
Transaction prices are the result of many discrete negotiations
often unknown to final consumers and to the public, and the
results may be treated as commercially sensitive (Reinhardt,
2006). In the USA, this is changing with recent pressures to
increase price transparency and promote consumer sensitivity
to prices (CMS, 2018).
There are several key features of individual negotiations. Like

the negotiation of any good, prices reflect the parties’
respective bargaining positions. Those parties with stronger
market power, for example, will have stronger bargaining power.
Under individual negotiations, a concentration of purchasers
and providers will have stronger bargaining power. In theory, if
an insurer covers a large share of the population, beneficiaries
can be guided to use “in-network” providers with which it
contracts. Under such a system, providers may agree to accept
relatively lower rates from the insurer to ensure patient volume
and capture guaranteed revenue. The use of macro-level
budgeting tools in some countries limits expenditure growth
even under individual price setting methods (Shut and
Verkevisser, 2017). However, in practice, providers with good
reputations or brands, specialized services, or those
representing the largest or sole provider in the region have
strong leverage to demand higher rates from insurers and can
control price changes over time (Berenson et al., 2015; Baker et
al., 2014).
Under individual negotiations, there will be price

discrimination, in which identical services can be purchased by
different payers at different prices. The US private health care
market commonly reports variations in prices for the same
services that bear little relation to the cost of providing
services, its quality or patient severity. Published reports across
the USA (i.e., Massachusetts, New York, Rhode Island, Vermont,
and New Hampshire) cite wide provider price variation and
conclude that high prices are correlated with a provider’s

position within the health care market, defined by size,
competitive position and/or brand (Commonwealth of
Massachusetts, 2017). For example, Massachusetts reported
differentials of 2.5 to 3.4 between the hospitals with the
highest and lowest prices for the same set of services (ibid).
In addition, administrative costs are high because of

expenditures on health insurance marketing and
administration, and on billing activities. These administrative
costs represent a loss to society, whereby large sums of money
are dedicated to administrative procedures that do not promote
health and welfare.
4.2
Collective negotiations
Under collective negotiations, associations of payers (i.e.,
health insurers) negotiate with associations of hospitals doctors
or other health providers. The outcome of these negotiations
would typically be a uniform fee schedule that would apply to
all payers and providers. In some settings, overall growth in
health care spending is constrained by using macro-economic
metrics, i.e., economic growth rates, expected payroll increases,
inflation rates, increases in health care utilization, and
population growth and ageing (Reinhardt 2012b).
There are wide differences in the objects and levels of

negotiation. Frequently negotiations take place when
determining payment levels to health care professionals, where
the objective is to ensure an optimum income. For physician
services, among countries in this study, price negotiation takes
place at central level between third party payers and insurers
(Japan, Republic of Korea, France), at local level on point value
following central level negotiations on resource based relative
value scales (Germany), or at central level for capitation
payments (England). In some settings, negotiations can take
place at local level for prices (i.e., Canada, New Zealand), or
capitation payments (Sweden) (Paris, Devaux and Wei, 2010).
There are several key features of collective negotiations. Price

discrimination present in individual negotiations is eliminated,
given that an identical service is purchased at the same price.
Collective negotiations also face much lower administrative
costs in comparison with individual negotiations, given that
substantially fewer resources must be dedicated to billing and
marketing. At the same time, the level of conflict among the
different stakeholder groups participating in the negotiation
may increase as the space and the scope of negotiations
widens.

4.3
Unilateral price setting
The third method of determining price levels is unilateral
administrative price setting by a regulator. When prices are
administered, a form of non-price yardstick competition rewards
a given firm depending on its standing vis-a-vis benchmarking
(Shleifer, 1985).4 Setting national prices based on average costs
through yardstick competition gives incentives to higher-cost
providers to improve efficiency and reduce cost.5 Providers with
below-average costs have incentives to keep prices below the
average to retain the marginal difference.
Like collective negotiations, the unilateral administrative

method eliminates price discrimination, given that a fixed price
Unilateral price setting is established. In comparison with individual negotiations,
eliminates price unilateral administrative price setting incurs lower
discrimination. Prices for administrative costs by insurers and health systems, but
additional relatively smaller regulatory expenses may apply
hospital services are (Anderson and Herring, 2014). Prices for hospital services are
often set unilaterally often set unilaterally and may include add-on payments to
and may include add-on ensure broader public health goals such as equity and access. A
payments to ensure unilateral, administrative price-setting system requires
information including cost, volume, and outcome given that
equity and access. prices are usually cost-based (average, marginal) or normative
(efficient). Adjustment factors are used by the provider or by
service to account for features that impact the cost of
production. Examples of such loadings include hospital type or
size, location, patient complexity and teaching activities.6
Where prices are regulated, providers compete on volume and

service quality rather than price to attract consumers. As such,
pressures to reduce costs could result in efficiency gains rather
than reduced quality. In Maryland, the all-payer approach
resulted in closing smaller facilities and high-cost hospitals,
resulting in efficiency gains and improvements in patient flows
(Murray and Berenson 2015).7 The Medicare and Maryland
unilateral price setting approaches have been combined with
quality incentives that promote evidence-based clinical
guidelines and provide incentives for reducing hospital
readmissions and nosocomial infections. As a result, quality
improvements were reported (Calikoglu, Murray, and Feeney
2012). Studies conducted in the USA generally conclude that
price setting by a regulator also improved hospital financial
stability (Murray and Berenson, 2015; Murray 2009).
4 This benchmark (or shadow firm) may be set by averaging the choice among other firms in
the group. Each firm is thus forced to compete with its shadow firm. If firms are identical
or if heterogeneity is accounted for correctly and completely, the equilibrium outcome is
efficient.
5 Strictly speaking, collective negotiations and agreements prices may also follow a form of
yardstick competition.
6 These loadings may also apply to collective negotiations/agreements.
7 The all-payer approach refers to a hospital payment system in which all payers (both
public and private) pay the same rates.

Fixed price systems allow transferring the treatment risk from
the insurer to the provider (Kumar et al., 2014). For instance, if
the patient requires a certain treatment that is only partially
covered by the fixed price, the provider must bear the additional
cost. Under unilateral systems, formal consultations can ensure
that health care providers are consulted in determining the
prices for which they are compensated and that the decision-
making is perceived as fair and transparent to all parties.
Figure 13
Methods of determining price levels by base for payment and
how they may contribute to health systems objectives
Method for Controlling Avoiding price Improving Expanding Increasing price Reducing
determining price levels discrimination quality choice transparency/ administrative
price levels information costs
Individual
negotiations
0 0 ? + 0 0
Collective
negotiations
+ + ? + + +
Unilateral
administrative
++ ++ ? + + +
Source: Authors. 0: little/no impact; +: positive impact; ++: strong positive

impact; ?: inconsistent evidence.
Each of these three methods can be described in terms of how

they may contribute to broad health systems goals (Figure 13).
In the late 1960s and early 1970s in the USA, at least 30 states
had implemented approaches to either review or directly
regulate hospital rates and budgets (McDonough, 1997). This
allows a comparison of the methods of price setting. Where
properly structured and evaluated, unilateral price setting by a
regulator performed better in reducing cost growth and/or
improving access in comparison with market-based systems
(Anderson, 1991, Atkinson, 2009; Sommers, White and
Ginsburg, 2012; Murray and Berenson, 2015). Robinson and
Luft (1988) estimate that, between 1982 and 1986, state rate
setting approaches by regulators reduced growth in hospital
expenditures by as much as 16.3% in Massachusetts and
15.4% in Maryland, in comparison with a control group of
hospitals in 43 states.
Using 2011 insurance claims data covering 38% of people with

employer-sponsored health insurance in the USA, Cooper et al.
(2018) compared hospital prices, negotiated rates (conducted
through individual negotiations), and Medicare reimbursements
(set unilaterally) for a series of risk-adjusted conditions. For
inpatient care on average, the negotiated price was US$
14,020; the full hospital price was 207% of the negotiated
price, and Medicare payments were 45% of the negotiated
price. Ironically, those with the least bargaining power and
ability to pay (self-payers and the uninsured) are subject to
paying the full charges (Tompkins et al., 2006; Anderson, 2007).
Similar patterns were reported for hip and knee replacements,

where the Medicare payments were 55% of the negotiated
price. Selden et al (2015) report that private insurance
payments rates in 2012 were 75% greater than Medicare
payments, and suggested that this gap has increased over time.
From an international perspective, the comparative price level

index for hospital services is lower in France where 83% of
revenues are controlled under regulated prices as compared
with the USA (Lorenzoni and Koechlin, 2017). Sizable
differences in total health spending in the USA compared with
the OECD median are attributed in part to the way in which
prices are set in the private health care sector (Anderson et al.,
2003; Anderson, Hussey and Petrosyan, 2019). In the hospital
sector, competition for quality is more likely to occur in markets
with fixed prices, although evidence is mixed (Allen, Fichera
and Sutton, 2016; Anderson, 1991; Gaynor, Moreno-Serra and
Propper, 2013; Gaynor and Town, 2011).
Based on the evidence available in comparing the three

methods, unilateral price setting eliminates price discrimination
and has performed better in controlling the growth of health
care costs. Both collective negotiations and unilateral
administrative price setting have the potential to improve
quality better than individual negotiations.
4.4
Process of price setting by base for payment
Using the base for payment as the starting point, Figure 14
illustrates the relationships between the base for payment and
the three administrative and economic processes by which the
price level is determined. Using this framework, we can identify
examples from the case studies and elsewhere to illustrate the
process of price setting.
Figure 14
Method of determining price levels by base for payment
Method of determining Base for payment

price level
FFS Per case Capitation Per diem
Individual negotiations
between providers and A B C D
payers
Collective negotiations
between associations E F G H
of providers and payers
Unilateral administrative
I J K L
price setting
Sources: Adapted from Reinhardt, 2012b. Note: FFS: fee-for-service.

Individual negotiations between providers and payers (A-D)
Private health care in the USA is theoretically a conventional

market with individual negotiations for FFS payment to
outpatient clinics and hospitals, and per diem payment for
inpatient services (Figure 15). However, both hospital and
insurer markets have become so concentrated that consumer
choice is often very limited, and physician markets are also
becoming more consolidated. Significant premium increases
and the profits of the health insurance industry in recent years
suggest that little, if any, of the benefits of insurer bargaining
power are being passed to consumers (Gaynor and Town,
2011). On average, prices in the private health care market
have been reported as approximately 50% higher than average
hospital costs; they are frequently 50% or more of Medicare
payment rates (Cooper et al., 2018; Medicare Payment Advisory
Private insurers in the Commission 2018).
USA utilize government It should be noted that private insurers in the USA utilize
(Medicare) payment government (Medicare) payment rates and relative values as a
rates as a starting point starting point for their individual price negotiations. As such
Medicare has significant influence over the prices that private
for individual insurers pay (Clemens and Gottlieb, 2016). Prices for private
negotiations. As such, hospitals in Thailand are also negotiated individually for certain
Medicare has significant services.
influence over the prices In Germany’s LTC system, agreements are made between the
that private insurers pay. state associations of LTC funds (both public and private) and
state associations of nursing home providers. The provision of
care is supervised by the respective state authority (the Ministry
of Social Affairs or Ministry of Health). Prices are negotiated
individually between nursing homes and LTC funds. Nursing
homes that wish to provide care reimbursable under these
agreements can negotiate a contract with sickness funds to
provide nursing care for their enrollees. This applies to both
social health and public health insurance funds. In return,
nursing homes must adhere to quality criteria, such as staffing
ratios. Per diem payments are made for nursing care (a lump-sum
payment from LTC funds), and patient copayments cover housing
and meals, infrastructure, training and additional services.
While the Netherlands is not included in the report, an example

of price setting is included for completeness. In the
Netherlands, health insurers can negotiate contracts with
individual hospitals for many services (the “B-segment”)
(Kroneman et al., 2016; Shut and Verkevisser, 2017). Some
insurers negotiate a lump-sum budget while others negotiate
on price and/or volume for individual treatments. Furthermore,
health insurers negotiate with multidisciplinary groups for a
single bundled payment for diabetes, chronic obstructive
pulmonary disease, and asthma. In turn, care groups negotiate
with general practitioners about the share of the total price that
will be paid for their services. For the remainder of hospital
production (the “A-segment”), including more complex cases,
prices are unilaterally set by the Dutch health authority.

Collective negotiations between associations of providers
and payers (E-H)
In the Republic of Korea, the National Health Insurance Policy

Deliberation Committee determines the scope of the benefits
package and the level of cost sharing. The National Health
Insurance Corporation and provider representatives then
negotiate the prices and payment conditions annually. All
provider associations contract with the insurance corporation,
although the terms of the contracts may differ. The RBRV, or the
value of procedures carried out by health care providers, is
established centrally, and negotiations are done on point value
for blended FFS and case-based payments in public hospitals.
In Japan, FFS payments are negotiated at central level with

medical associations and third-party payers for outpatient and
primary care. A Diagnosis Procedure Combination (DPC) per
diem payment system is used to pay for over half of beds for
acute hospital care. At the same time, FFS continues to be used
for surgical procedures, endoscopic examinations, rehabilitation
therapy, devices, and pharmaceuticals given on the day of
surgery. The per diem rate differs according to four groups,
reflecting variations in the length of stay, and weighted by
different coefficients. For example, efficiency coefficients reward
hospitals with shorter lengths of stay after adjusting for case-
mix. The complexity coefficient rewards hospitals that have
more complex patients. Hospitals have reacted to the incentives
in the DPC payment by transferring services to outpatient
departments where they could be billed using FFS or
discharging patients earlier so that they would receive higher
per diem payments. On the positive side, incentives for quality
increased leading to more extensive use of clinical treatment
guidelines.
In Germany, the cost weights for federal base prices are

negotiated centrally; the DRG base rates for states are then
negotiated between sickness funds and hospitals within a
given range to set prices. Subsequently, at local level, budget
negotiations take place between individual hospitals and larger
sickness funds. For hospital inpatients, the social health
insurance (SHI) state associations contract all hospitals that
have an agreement with the state (the majority of all hospitals).
In the public health insurance (PHI) system, patients can access
all hospitals and claim reimbursement from their PHI fund.
Hospitals are reimbursed almost exclusively based on DRGs.
Prices are mostly calculated at the federal level. States can
deviate from the overall price level within a predefined range.
The budget of a hospital is negotiated between an individual
hospital and the SHI and PHI funds.
In the outpatient sector in Germany, state associations of SHI

funds have closed collective agreements with their state’s
associations of SHI physicians (KV) and consequently contract
all physicians who are licensed by the KV. Physicians are
reimbursed by the SHI funds and must adhere to location
restrictions and quality controls by their KV. Physicians are

reimbursed by a mixture of FFS and lump sum payments. Like
the inpatient sector, prices are set at the federal level and
tailored to specificities at the state level. In contrast to the
inpatient sector, services are budgeted. SHI funds pay an
aggregate budget to their state’s KV, and the KV distributes the
budget among its SHI physicians. Services to PHI patients are
reimbursed differently, albeit by a FFS system. Patients can
receive services from all physicians who hold a medical
licensure to practice and claim reimbursement by the PHI fund
depending on their health plan. As opposed to the SHI system,
services are not budgeted. It can be noted that there is no
quality control or supervision.
In France, primary and outpatient specialist services are

currently funded on a negotiated FFS basis, although this may
change in the foreseeable future with the introduction of a
pay-for-performance scheme and bundled payments. The fees
are set through formal negotiations between the unions of
statutory health insurance funds (UNCAM), the government, and
unions of health professionals. This leads to a collective
national agreement or a contract that aims to regulate the cost
and activity of the ambulatory sector.
In England, primary care services are primarily funded through

capitation payments for four primary care contractor groups
(medical, dental, eye health and pharmacy). The capitated
funding is based on each practice’s registered list size with a
fixed, nationally agreed price per patient, and the actual
amount paid is calculated practice-by-practice. Price
negotiations are carried out between National Health Service
(NHS) England and the General Practitioners Committee of the
British Medical Association on the General Medical Services
contract. For secondary care, national tariffs are centrally
calculated based on cost information submitted by providers.
There is a statutory consultation on the methodology used to
determine the prices and any changes to the payment rules,
and scope of the tariff. Should an objection threshold be
breached, the methodology is reviewed. An informal
consultation takes place in advance on key proposals, and
adjustments made as required before the statutory
consultation. Expert clinical groups review the draft prices, and
manual adjustments can be made.
Thailand uses capitation payments for primary health care

centres and DRG payments for hospitals through collective
negotiations. Working group members for negotiations include
both public and private providers, who review and negotiate
unit costs and concur with the utilization rates. The final figures
are constrained by annual fiscal capacity, which is a political
decision based on the costs required for service provision for
Universal Coverage Scheme members in a given year. The
Universal Coverage Scheme sets the global budget for the
maximum total payment for inpatient services, while the other
two schemes (Social Health Insurance and Civil Servant Medical
Benefits Schemes) do not use global budgeting.

Figure 15
Method of determining price levels by base for payment,
by setting
Method of Base payment

determining price
level FFS Per case Capitation Per diem
Individual negotiations USA (private health The Netherlands: USA (private health
between providers and care): outpatient hospitals. B-segment care): inpatient
payers clinics, hospitals activity services
Thailand: private The Netherlands: GPs. Germany: nursing care
for-profit hospitals for (Bundled payments for
certain conditions diabetes, COPD and
asthma)
Collective negotiations Japan, Republic of Germany: hospitals for England: primary care Japan: hospitals
between associations Korea, France: local rates (after DRG (medical, dental, eye (diagnosis procedure
of providers and payers outpatient and primary weights are set health and pharmacy) combination+ fee-for-
care unilaterally) service)
Republic of Korea: England: hospitals Thailand: primary
hospitals (blended health care
fee-for-service and
case-based payments)
England: outpatient France: acute care
care hospitals
Germany: outpatient Thailand: hospitals
care (FFS+ lump sum)
Unilateral USA (Medicare, USA (Medicare): USA (Medicaid): USA (Medicare and
administrative price Medicaid): primary care hospital inpatient and managed care Medicaid): skilled
setting outpatient care, and nursing facilities
ambulatory surgical
centres
Australia: outpatient Maryland (preferred
and primary care providers): hospital
inpatient and
outpatient care
The Netherlands: Germany: hospitals
general practitioner (DRG-weights)
payments
Australia and France:
public hospitals and
private patients in
public hospitals
The Netherlands:
hospitals. A-segment
activity (more complex
cases)
Source: case studies (see annexes), authors. Note: GP: general

practitioners; OP: outpatient; COPD: chronic obstructive pulmonary
disease; FFS: fee-for-service; G-DRG: German Diagnosis Related Group.

Unilateral administrative price setting (I-L)
In the USA, where hospital market consolidation has resulted in

higher prices, unilateral price setting has been used to control
spending growth and avoid inequalities in the Medicare
program for preferred providers and in the state of Maryland.
Medicare fees are set centrally, and prices administered for the
entire country. The Medicare program establishes prices per
case (DRGs) for hospitals and pays hospitals a bundled
payment to cover the resources needed based on the
estimated costs incurred by a hospital with average efficiency
in managing that case. The Medicare and Medicaid programs
also unilaterally set the per diem fees for skilled nursing
facilities, which is adjusted for patient case mix. Since 2014,
Maryland operates an all-payer system for both inpatient and
outpatient care at hospitals, with price levels determined by a
In Australia, general commission of stakeholders.
practitioners are paid by In Australia, general practitioners are paid by FFS based on the
fee-for-service based on Medicare Benefits Schedule (MBS) determined by the
the Medicare Benefits government. When the MBS list was first introduced, the fees
were based on the Australian Medical Association’s (AMA) list of
Schedule. Patients are “most common fees” charged. At that time, the AMA fees
entitled to a rebate from reflected a market-based price based on a practice costs and
eligible providers, and patient willingness to pay. At present the MBS fees for primary
the MBS rebate acts as a care consultations have been indexed to the wage-price index
and the consumer price index. Patients are entitled to a rebate
floor price for fees. for treatment from eligible providers, and the MBS rebate acts
as a floor price for fees. If the fee charged is equal to the MBS
rebate, the patient faces no co-payment.
Funding of Australian hospitals reflects federal-state financial

relationships and public and private interests. State
governments own and operate public hospitals but are reliant
on financial transfers from the federal government for
financing. Until 2011, specific bilateral agreements for public
hospital funding were negotiated every five years. After 2011,
under the National Health Reform Agreement, the federal
government provided shares of federal funding based on the
growth in public hospital activity (measured by DRG weights)
and hospital costs based on the national efficient price. Federal
government funding was paid directly to the local hospital
network. States and territories covered the funding balance,
and thus they were designated as the system managers with
the responsibility for managing volume growth. In France,
hospital prices are set unilaterally by the Minister of Health.
In comparison, prices are set by the Dutch health care authority

based on FFS for general practitioners, whereby the maximum
price for FFS payments is established, accounting for 75-80%
of general practitioner earnings. The Dutch authority also
establishes per case price setting for hospitals for more
complex cases.

5/
Technical process
of setting the
price per unit of
payment

From a societal perspective, the price is the amount that must
be paid to elicit from providers the supply of health care
services that the society wishes to have and is willing to pay
for. In determining the tools and processes for price setting,
several common objectives can guide the process (Waters and
Hussey, 2004). These include ensuring that:
__ Prices accurately reflect the actual costs of delivering a
given service.
__ Health care providers are reimbursed fairly.
__ The pricing structure supports broader health system goals,

i.e., coverage, quality, financial protection, and health
outcomes.
When setting prices at an appropriate level, elements that

should be factored in include the unit costs of providing
services, economies of scale and scope, high entry and capital
costs, and marginal benefits of quality. To estimate unit costs,
purchasers use different costing methodologies to structure the
information collection systems and verification.
5.1
Costing methods
Price levels that are too low or too high create incentives for
over- or under-utilization. This gives an incentive for purchasers
to estimate prices that reflect the actual costs of the given
service across a set of providers. There are different kinds of
costing such as activity-based costing, average costing,
standard costing, economic methods, and others. The
methodology chosen is based on the context and information
needs. For example, cost accounting methods use accounting
principles to classify and measure all costs incurred in carrying
out an activity. For provider payment purposes, decisions
usually require total or average cost information – and thus cost
accounting methods are typically applied (Cashin, 2015).
The cost accounting approach follows a process (Cashin, 2015).

The total resources used by a cost centre are identified and
measured. The cost of resources used directly by all cost
centres are calculated and the costs are assigned to each
individual cost centre. The cost of resources used indirectly by
all cost centres is generated, and a share is allocated to each
cost centre based on the centre’s estimated use of resources.
From this information, average unit costs are generated based
on units of service (i.e., discharged patients, bed-days, or
outpatient visits).
Two kinds of cost accounting methods are used most frequently

to inform provider payment rate setting: gross costing and
micro-costing. The choice depends on the level of accuracy
needed, scope of the exercise, and cost objects (i.e., patient,
service, hospital department, or unit from which costs are
sought).

Gross costing first calculates the total costs of the service at the
organizational, provider, or departmental level, then
disaggregates the total costs to the cost centres (departments
or units to which costs are assigned), depending on the richness
of the available data and the homogeneity of the services
provided. This method is also called the average costing
approach or departmental costing, and it represents a top-down
approach resulting in average costs per category.
In micro-costing, all relevant components are defined at the

most detailed level. This approach records resource utilization
at the level of the patient or individual service, and aggregates
patient or service utilization data to identify the types of
resources used and measure their utilization to calculate the
costs of specific services. Micro-costing results in patient
specific costs. It can be either retrospective (through collection
Price levels that are too of existing data from medical records) or prospective (through
low or too high create medical record review or specific studies such as direct
observation).
incentives for over- or
under-utilization. Micro-costing exercises face methodological challenges, given
that it is not possible to develop detailed costing for each
service or patient. Aggregating cost estimates for individual
services typically leads to heavily inflated total cost estimates
that almost always exceed available resources and prove
difficult in matching funding flows with service priorities. The
top-down approach (gross costing) uses the total facility cost,
disaggregates the expenditures to cost centres (departments or
units to which costs are assigned), and divides the department
by the number of patients to generate the cost per patient visit
or discharge. Top-down exercises are retrospective given that
they rely on data from existing financial accounts documenting
aggregate resource use. Either top-down or micro-costing can
be used for different base for payments. The common thread
across both is the allocation of costs to cost centres. Accuracy
relies on the correct allocation of direct costs (medicines and
supplies) and indirect costs (administrative and support
activities) (Özaltın and Cashin, 2014).
Activity-Based Costing or Funding (ABC or ABF) is an approach

used to calculate the unit costs of health services in the USA;
subsequently it was applied in other countries (Waters and
Hussey, 2004; Özaltın and Cashin, 2014). Instead of allocating
indirect costs in proportion to the volume of units or to direct
costs, ABC assigns indirect costs based on the main activities
within an organization. It seeks to define the principal activities
of the individuals who work within the organization, and then
traces costs first to these activities and then from the activities
to products and services. Allocation of personnel time among
the activities is used for indirect costs. This method aims to
develop more accurate measures of indirect costs, by
attributing support costs based on the actual consumption
measured by time allocation. Where data on personnel time are
absent, another approach is to apply top-down costing to
allocate costs derived from line-item budgets across inpatient
departments.

Figure 16
Process of data collection for hospital costs
Setting Scope Grouping Costs Source of Frequency of Share of

excluded information revision revenue
controlled
under fee
schedule
Australia Inpatient care, Expenditures are grouped Federal All public Every 1-2 years 70
sub-acute, across five services: admitted programs hospitals
emergency and acute, emergency, non- paid directly participate. A
outpatient admitted, sub-acute and (i.e., highly separate
services non-acute. The National specialised system of data
Efficient Price is based on the medicines, collection is
average cost of an admission. blood supply) undertaken
Case mix is adjusted by the from 91 (out
National Weighted Activity of 630) private
Unit. hospitals on a
voluntary
basis
England Acute inpatient >2800 Healthcare Resource Education All 232 Annually 47
and outpatient Groups costed for treatments and research National
care excluding with similar cost implications Health Service
psychiatric for a given condition from providers in
services, admissions to discharge. England (80
emergency care Average cost per HRG is NHS trusts and
and generated. Costs for 152 NHS
rehabilitation outpatient appointments and foundation
procedures collected on the trusts)
same basis.
France Acute inpatient 2,680 GHM (Groupe Education, 135 hospitals Annually 83
and outpatient Homogène de Malades) are research and (voluntary
care excluding generated, with four levels of expensive participation)
psychiatric case severity applied to most medicines
services, groups, using information on
emergency care, length of stay (LOS), secondary
rehabilitation diagnoses and age.
Germany Medical 1,292 DRGs and 205 add-on Nursing costs, Approximately Annually 90
treatment, payments are generated based education, 300 hospitals
nursing care, on patient diagnoses, research, (voluntary
pharmaceuticals procedures, length of stay, expensive participation)
and therapeutic ventilation hours, age, gender, medicines,
devices, board birthweight, medical unit and capital costs
and type of discharge. Each DRG and interest,
accommodation, can be split into up to five allowance for
and excluding subcategories depending on bad debts,
intensive and patient severity. Cost weights taxes, charges
emergency care are generated to reflect the and insurance
average expenditures of a
sample of hospitals.
Japan Inpatient and The global revision rate (global Normal Revenues and Every 2 years for 90
outpatient budget for expenditures) is delivery, expenditures service fees,
services, established, prices for preventive are collected annually for
pharmaceutical pharmaceuticals and devices services such from Health pharmaceuticals
and medical revised, and service fees as health Economic
devices revised. Physician and hospital screening, Survey of
services are classified into 14 education facilities.
categories. Instead of detailed and research Volume is
cost studies, the focus is on collected from
revenues and expenditures of the National
clinical departments to decide Claims
which departments should be Database
expanded or reduced.

Setting Scope Grouping Costs Source of Frequency of Share of
excluded information revision revenue
controlled
under fee
schedule
Republic of Inpatient and Bottom-up approach with Education Participating Annual 90
Korea outpatient micro-costing is conducted. and research providers
services Diagnosis related groupings
are applied to 6 disease
categories.
Thailand All operating Cost centre approach is used, Public health Initially 20 Periodically 74
(UCS) costs for in which simultaneous programs and now 900
inpatient and equation modeling is applied administered public
outpatient to allocate indirect costs from directly by hospitals
services, transient cost centres to national
including absorbing cost centres government,
staffing, (outpatient, patients), education
medicines, generating a unit cost per and research
diagnostics, admission.
and capital
depreciation
costs
USA Inpatient and Medicare severity diagnosis Education Participating Annually 40
(Medicare) outpatient related groups are generated and research providers
services for patients with similar
clinical problems. Each has a
relative weight that reflects
the expected cost of inpatient
treatment for the group.
Sources: case studies (see annexes). Note: DRG: Diagnosis related group;
NHS: National Health Service; UCS: Universal Coverage Scheme in
Thailand. Information for Thailand covers hospitals and other settings.
5.2
Process of collecting information
The process of data collection for hospital activity and costs
varies widely across settings in terms of the scope of the
exercise, grouping of clinical conditions, definition of costs for
inclusion and exclusion, and sample size and frequency of data
collection (Figure 16).
In Australia, substantial investments have been made in clinical

costing systems that monitor hospital activity. The National
Hospital Cost Data Collection is conducted by the national
regulatory authority (IHPA) through the states and territories.
This is the main data collection mechanism used to develop the
National Efficient Price (NEP). It is an annual and voluntary
collection of public hospital data that undergoes validation,
quality assurance checks, and reporting to allow benchmarking.
For Round 21 (2016-2017), cost data were submitted from 451
hospitals (65% of total hospitals) across all jurisdictions. The
NEP is revised annually and based on cost and activity data
from three years prior (as an example, the 2019-2020 pricing
model is based on 2016-2017 data).
In England, all NHS providers are required to report their costs
annually to NHS Improvement, based on a set of mandatory
costing standards. Funding for hospital-based care follows the
patient, with the aim of enabling competition for patients
based on quality rather than price. Costs are submitted for
more than 2800 Healthcare Resource Groups, which forms the
reference cost collection. In 2009, a voluntary patient-level
information and costing system (PLICS) was piloted, which
determines the cost of each medical case informed by the
actual medical records and services provided (micro-costing
approach). The 2018/19 cost collection from acute providers
will be based solely on PLICS, and these data will be used to
determine prices in the future.
In France, a national cost study for the public sector was

introduced in 1995, with 35 public hospitals participating on a
voluntary basis. Until 2006, the French hospital cost database
covered only public hospitals (40 hospitals representing 3% of
total public hospitals). Since 2006, cost information has been
collected annually from a sample of voluntarily participating
private hospitals. In 2018, the cost study covered 135 hospitals,
of which 52 are private-for-profit. The cost study includes acute
inpatient and outpatient care and excludes psychiatric services,
emergency care, and rehabilitation. Costs are calculated at the
level of the patient episode. They are allocated primarily based
on the length of stay (for inpatients) and a relative cost index
that reflects the cost of the treatment process (for technical cost
centres such as laboratories or imaging). The costs for public
hospitals cover all expenditures linked to the stay (including
medical personnel, and all the tests and procedures provided
and overheads). Those for the private sector exclude medical
fees to doctors (who are paid on a FFS basis) and the cost of
biological and imaging tests, which are billed separately.
The guiding principle for the provision of health care services

in Germany is transparency and efficiency. Costing is based on
individual patient episodes and on actual resource utilization.
Some 1,292 DRGs and 205 add-on payments are generated
based on patient diagnosis, procedures, length of stay, and
other key factors. Each DRG can be split into up to five
subcategories depending on patient severity.
In Japan, a fee schedule establishes the payment rates for

every covered service. First, the global revision rate is
established. Subsequently a line-by-line revision of the fee
schedule is undertaken, based on the global budget constraint
and changes in volume and prices. The fee schedule groups
physician and hospital service items into one of 14 categories.
The 2018 version lists about 4,000 items and conditions of
billing, and separate manuals are prepared for the Diagnosis
and Procedure Combination, the Japanese version of the DRG.
Data are used from the Health Economic Survey of Healthcare
Facilities, and information available from the National Claims
Database that compiles all provider claims. Revisions are
undertaken every two years for service fees and annually for
pharmaceuticals.

In the Republic of Korea, the bottom-up approach cost
accounting model is used based on information submitted from
providers about the provision of insured services. Providers
participate voluntarily, only a small number of hospitals
participate, and the sample changes each year. This results in
controversy over the representativeness of cost data.
Adjustments are made for different levels of providers to
account for differences in input costs, including add-on
payments of 15% for physician clinics, 20% for hospitals,
25% for general hospitals, and 30% for tertiary hospitals.
Other adjustments are made to provide incentives to reduce
the length of stay for LTC. Sophisticated monitoring and review
systems are in place.
In Thailand, under the Universal Coverage Scheme, a cost

centre approach is applied, in which simultaneous equation
In Thailand, under the modeling is used to allocate indirect costs to absorbing cost
Universal Coverage centres (i.e., patients), generating a unit cost per admission.
Data collection efforts started with 20 public hospitals and now
Scheme, a cost centre includes 900 hospitals; data are collected about all operating
approach is applied, in costs for outpatient and inpatient services. The cost per
which simultaneous outpatient visit equal to expenditure is divided by total
equation modeling is outputs, where the numerator is the total annual operating
expenditure and the denominator is the total annual outpatient
used to allocate direct visits plus total hospital admissions, weighted by a factor of 16
costs to absorbing cost for districts and 19 for provincial hospitals. The weight is
centres. generated from conventional costing studies, which are
adjusted from time to time.
In the USA, prices are established for DRGs for the Medicare
program primarily based on data about charges from individual
cost centres and costs obtained from participating accredited
providers (approximately 88% of hospitals and 40% of all
health care providers). The acute inpatient prospective
payment system pays per discharge rates based on two
national base for payment rates covering operating and capital
expenses, adjusted for patient condition and treatment
strategy. From these data, the cost per charge unit can be
generated for cost- and charge-based weights. The final cost
depends on the cost and the hospital’s ratio of cost to charges.
The DRG weights are recalibrated annually, without affecting
overall payments, based on standardized costs for all cases in
each grouping. Wage adjustments are based on market
conditions among other factors.
Under the Maryland all-payer model, an annual global budget is

established and agreed upon with each hospital, adjusted for
hospital cost inflation, changes in demographics and market
share, rising costs of new outpatient drugs and other factors.
The model guarantees a fixed revenue annually regardless of
the services provided, given that the hospital agrees on service
commitments to the community. Rates are then set for services
billed so that total payments for expected utilization match the
global budget. This provides hospitals with the incentive not to
exceed their budget.

5.3
From cost submission to price setting for
hospital services
Australia established a national system of activity-based
funding for funding hospitals in the public sector to determine
a national efficient price by collecting information on each
patient episode from all public hospitals. Activity is measured
by DRG weights, and the costing of each DRG is based on cost
data for a representative number of patient episodes. The cost
of each patient episode is calculated from actual data about
the treatment process. A reference cost is first derived by
rebasing average cost to exclude changes in case mix between
years. Then, an annual indexation rate is used to inflate the
reference cost over three years based on an annual scaling
factor modeled using the prior five years of cost data. Prices are
also adjusted for variations in the cost of delivering health
services including to remote regions, among other factors.
In England, there is a three-year lag between hospitals

submitting cost data and these data being converted into prices.
The average cost is estimated for each healthcare resource group
(HRG), by admission type across all hospitals. Several
adjustments are made that impact on the actual amounts
received by a provider. A market forces factor is used to
compensate for unavoidable cost differences in providing health
care driven by geographical variations in the costs of land, labour
and buildings. The delay between the collection of cost data and
price calculation results in changes in wages, prices and other
inputs over which providers have limited control; as such, an
inflationary adjustment (cost uplift) is made to each healthcare
resource group. This inflationary adjustment is offset by a
deflating efficiency requirement. For 2018-2019, for example,
the average inflationary adjustment was 2.1%, and the deflating
efficiency requirement is -2%. In addition, top-up payments are
made to providers offering highly specialized services, which are
not adequately reimbursed through the HRG design. For prices
traditionally calculated on average reference costs, there are a
number of “best practice tariffs” that are structured and priced to
encourage fast adoption of best practice.
In France, the hospital technical agency updates the reference

prices annually based on information from the hospital cost
database, and controls and supervises the cost accounts of all
hospitals participating voluntarily. There is always a time lag of
two years between the year of the data and the year of the
application of prices in hospitals. For example, hospital costs
data from 2013, 2014, and 2015 were averaged over the same
three years to calculate reference costs in 2016, to set prices
for hospital services in 2017. Prices are set at the national level
based on average reference costs by case-mix patient groups
(GHM) calculated separately for public and private hospitals.
Therefore, there are two different sets of tariffs: one for public
(including private non-profit) hospitals and one for private

for-profit hospitals. The tariffs for public hospitals cover all the
costs linked to a stay (including medical personnel), whereas
those for the private sector do not cover doctors’ fees or
biological and imaging tests, which are billed separately.
In Germany, the regulatory authority calculates cost weights by

DRG annually. They reflect the average expenditures of a
sample of 300 hospitals, which participate on a voluntary basis.
These data include patient-level data on the major diagnosis
and other diagnoses, clinical interventions (i.e., medical
procedures), patient characteristics (specifically age, gender,
and weight of newborn children), cause of hospital admission
and discharge, as well as accompanying cost data as measured
by workforce and technical resources and pharmaceuticals.
Based on that information, cases are assigned to DRGs, and cost
weights are set for each DRG. There is a two-year lag between
The value in costing hospitals submitting cost data and these data being converted
studies is in into relative weights and prices. The catalogue of cost weights
is approved, and the growth rate of the federal base rate is
demonstrating negotiated annually by the associations for statutory health
information about the insurance, private health insurance providers, and hospital
underlying cost federation. The three negotiating parties are obliged to
structure. A good costing mandate the regulatory authority to calculate the federal base
rate. These calculations are based on the state base rates, the
exercise can help total expenditures, and the case mix of the preceding year. The
identify the costs of growth rate of the federal base rate is based on two
different service delivery parameters: the average change rate of contributions by SHI
enrollees and the average change rate of hospital costs. The
configurations. latter is calculated annually by the German Federal Statistical
Office. If the change rate in contributions is higher than the cost
increase, this rate is chosen automatically. If costs increase at a
higher rate, the three negotiating parties (representing
statutory health insurance, private health insurance providers,
and hospitals) determine an increase in the rate, which must
fall within the range between both rates.
5.4
Changing the cost structure
Cost accounting exercises have limitations. They result in an
estimate of the average cost of service production under the
assumption that cost and production functions for health
services are fixed. They reflect how efficiently services are
being produced, existing prices, and the level of capacity and
utilization at one point in time. However, the unit costs reflect
one point on a cost curve that is unobserved. Therefore, the
“true” costs cannot be known. What may be observed is an
estimate of unit cost at one point along a function.
That point also embodies how efficiently services are being

produced, existing prices, and the level of capacity utilization.
Point estimates will not provide any certainty about the “right”
level of resource requirements. Costing exercises also reflect
the existing service delivery systems, including their

inefficiencies and quality. Bottom-up costing based on
inefficient delivery structures may include inappropriate
technologies, services, or level of care. If the purchaser uses
average costs to inform payment rates, these rates will reflect
the current clinical practices in the health system –and fail to
reward efficient behaviours (Özaltın and Cashin, 2014).
Therefore, the value of costing studies is in demonstrating

information about the underlying cost structure. A good costing
exercise can help delineate service delivery scenarios and
assumptions to identify the relative costs of different service
delivery configurations (WHO, 2015b). Such an analysis of the
different options facilitates decision-making about optimal
ways to deliver services and contributes to building a strong
purchasing system to drive efficiency and quality.
Take the primary care approach, for example. Evidence suggests

that it will cost less to deliver a large share of the basic benefits
package by doctors at the primary care level, rather than by
specialists working out of hospitals. A useful costing exercise
could provide an estimate of the investments needed to
strengthen the primary care level to change the cost structure
in other parts of the health system. Costing of specific steps
can be valuable, such as cost accounting to set provider
payment rates or costing of specific investments to produce
reform – in this example, investments in primary care facilities.
Other examples of policies that can change the cost structure
include those that influence the demand for health services
and products, including pharmaceutical price controls,
regulation of private health care providers, and health
promotion and prevention. Ultimately, costing exercises are
useful beyond the estimation of unit costs in demonstrating
service delivery alternatives that improve efficiency, quality,
and promote the appropriate volumes of care.

6/
Aligning pricing
with overall
policy goals

6.1
Adjustments and add-ons to ensure payment
adequacy and fairness
Price adjustments and add-on payments are common when
prices are set unilaterally or negotiated collectively, to ensure
that specific services or caring for specific populations are
covered, particularly where there are additional costs of
providing care or it is considered unprofitable.
Geographical price adjustments are common to ensure that

health facilities are adequately reimbursed and compensated
for factors outside their control. For example, Thailand and
Australia adjust prices for remote or rural facilities to ensure
adequate funding of operations. In England and the USA
(Medicare), adjustments are made for variations in input costs
across geographic regions, which are expected to be higher in
urban areas (Figure 17). Germany uses geographical add-on
payments for hospitals in financial deficit that provide basic
surgery for inhabitants of low-density areas.
Prices are also adjusted to promote greater coverage of specific

services or access for specific populations. In 2003, Australia
introduced financial incentives for general practitioners to
provide greater access to services through lower copayments
for specific patient groups. Australia, England and the USA
(Medicare) adjust for long-term or costly patient stays or
specialized services. In addition, adjustments are made for
goods that broadly benefit society and communities, such as
medical education (USA Medicare) and public health activities
(Australia and England). In France, regulated prices are modified
for activities related to education, research, and innovation as
well as national priorities including cancer treatment and
palliative care.
Pricing policies in Japan provide incentives to physicians to

deliver services in line with policy goals such as providing
end-of-life care at the patient’s home, and LTC and community
care. This is primarily done by establishing the conditions of
billing that set forth human resource and facility standards as a
condition of the payment. Bonus payments are also made to
provide additional incentives, for example, to nursing homes
for delivering end-of-life care within the facility rather than
transferring residents to hospitals.
Germany uses financial penalties. For example, hospitals

receive a deduction if they refuse to provide emergency care
(EUR 60 per case), if they fail to submit requested data, or if the
data are of insufficient quality. However, the effect of these
deductions is limited because the financial penalties are lower
than implementation costs, i.e., hiring additional staff for
submitting data.

Figure 17
Adjustments to ensure payment adequacy and fairness
Setting Geographic adjustments Outlier payments Public health goods
Australia Adjustments are made for Adjustments are made for For population based services that
approximately 400 hospitals long-stays receiving a per diem are not described in terms of
serving small, rural or remote rate. activity, block funding is directed to
populations based on size, location states and territories to allocate to
and type of services. hospitals.
England Costs are multipled by nationally Adjustments are made for long or Adjustments are made to support
determined market forces factor short stays and specialised specific policy goals, such as
(MFF), which is unique to each services. providing care that is compliant with
provider and reflects relative best practices.
costs of care across the country.
Providers in London attract the
highest MFF.
France Geographic adjustments are made Adjustments are made both for Add-on payments are made for
only for the Parisian area (Ile-de- long and very short stays and medical education, research, and
France) and for overseas territories. specialised services. investments for improving quality of
care. Add-on payments are also
made for local public policy goals,
such as prevention, out-reach to
populations in need, etc.
Germany Recently, the government has Since 2018, 205 add-on Add-on payments are made for
initiated add-on payments to payments were made for patients medical education, specialised units
hospitals if they are located in with high needs for nursing care, and medical centres, and the
financially unattractive regions or the provision of additional delivery of care to medically
but are vital to providing medical services and pharmaceuticals, demanding patients.
services to the region. which are not included in the
DRG system yet.
Japan None. Adjustments are made for long None. Public health goods are
stays. funded from different sources (i.e.,
screening is funded by health plans
directly contracting providers, and
public health and immunizations
while funded directly by
government and through user
charges).
Republic None. Adjustments are made for long Information not available.
of Korea stays.
Thailand Adjustments are made for districts No adjustment for outliers are No adjustments are made. Such
(UCS) having higher unit costs due to made. services are mostly funded by the
sparse populations such as Ministry of Public Health.
mountainous areas or island
districts to ensure adequate
funding for operations.
USA The Medicare Wage Index accounts Outlier payments are added for Operating and capital payment rates
(Medicare) for local market conditions, by cases that are extraordinarily are increased for facilities that
adjusting national base payment costly. operate an approved resident
rates to reflect the relative input- training program (on the basis of
price level in the local market. hospital’s teaching intensity), or that
treat a disproportionate share of
low-income patients.
Sources: case studies (see annexes). Note: UCS: Universal coverage

scheme.

6.2
Expenditure control mechanisms
Ultimately, the amount of money that the government spends
on health care is determined by the amount available to spend
(Getzen, 2006). While costing exercises are useful in
understanding the cost structure, particularly where the sample
sizes are sufficiently large, prices are also influenced by the
budget envelope representing the available funds. Therefore,
expenditure ceilings have been used to link prices to the
overall available budget, primarily to control costs. Moreover,
regulated prices can be combined with additional instruments
to control volumes. As illustrated previously, in settings that
have adopted DRGs as the main method of payment method
for inpatient care, they have also used DRGs with global
budgets as an overall volume constraint (Busse et al., 2011).
In France, ONDAM (National Goal of Health Insurance Spending)

is used to control overall hospital expenditure (with price
volume adjustments) and in negotiations for controlling prices
in the ambulatory sector. The growth in activity volumes are not
regulated at the individual hospital level but at the aggregate
level (separately for the public and private sectors). National-
level expenditure targets for acute care are set by the
Parliament each year to contain hospital expenditures. If the
actual growth in total hospital volume exceeds the target,
prices are reduced the following year. In practice, the activity
level has been higher than the targets, and prices have been
adjusted downwards regularly since 2006. The French Ministry
of Health also introduced a volume-price control mechanism at
the individual hospital level. For high volume and fast growing
DRGs (including knee prosthesis and cataract surgery), the
Ministry sets a threshold based on the growth rate for that
activity nationally. If the hospital’s caseload grows faster than
the threshold, the price is reduced by 20%. The impact of this
pricing policy is being monitored.
In Germany, hospitals face financial pressures to increase the

volumes of care provided beyond what is medically necessary
to finance infrastructure costs that are only partially covered by
the states. Some one-half of the total number of DRGs are
driven by one or more medical procedures, which provide
strong incentives for volume and surgical interventions.
Deductions are therefore used to incentivize hospitals not to
deviate from the negotiated budget. If a hospital performs
more services than agreed upon, it receives only 35% of the
reimbursement price; if a hospital performs fewer services than
negotiated, it receives a reimbursement of 20% for the
services it should have theoretically performed. Since 2017,
hospitals also face a 35% deduction on DRGs that are subject
to economies of scale, such as hip and knee replacements. This
deduction applies to additional negotiated services between
the individual hospital and its sickness funds and aims to
discourage hospitals to request budget increases.

In Japan, the Prime Minister establishes the global revision rate,
or the de facto global budget for health expenditures, based on
an evaluation of the political and economic situation. Factors
considered include information from the survey of
pharmaceutical prices and data about the revenues and
expenditures in health care facilities. Subsequently a line-by-
line revision of the fee schedule is undertaken based on the
global budget constraint and changes in volume and prices. The
government contains expenditure increases by lowering the
fees of items that have had rapid increases in volume and/or
can be delivered at lower costs by providers. For example,
physician FFS payment for an initial visit is four-times higher
than for a repeat visit.
In the Republic of Korea, copayments are used to decrease

demand. Copayments for outpatient care range from 30% to
60% depending on the level of the system (from primary to
tertiary level). This is done to prevent patients from overusing
services at private hospitals. In the Republic of Korea, for LTC
hospitals, the national health insurance reduces its price by 5%
for stays over six months and by 10% for stays over one year to
encourage hospitals not to keep patients for long stays. The
impact of these policies has yet to be evaluated. In Thailand,
the base for payment varies based on the total number of cases
to keep within the budget framework.
Under the Maryland all-payer model, an annual global budget is

established during a base period (2013) and adjusted for
subsequent years factors such as hospital cost inflation rates,
approved changes in the hospital volume based on changes in
population demographics and market share, rising costs of new
outpatient drugs, and additional adjustments related to
reductions in potentially avoidable utilization and quality
performance (Health Services Cost Review Commission (HSCRC),
2018). The global budget establishes a ceiling on hospital
revenues. This provides hospitals have an incentive to ensure
that revenues do not fall short of or exceed their budgets.
The HSCRC sets an agreement with each hospital in Maryland

following the Global Budget Revenue model. This model is a
revenue constraint and quality improvement system to provide
hospitals with strong financial incentives to manage their
resources efficiently and effectively and to slow growth in
health care costs. Hospitals that adopt the model receive a
fixed amount of revenue each year (Approved Regulated
Revenue) –regardless of the number of Maryland residents they
treat or the amount of services they deliver – provided that
they also meet their obligations to serve the health care needs
of their communities in an efficient, high quality manner on a
continuous basis.

6.3
Balance billing limitations and financial
protection
A key question for pricing policy is whether the prices are
binding for providers or whether the providers are permitted to
charge patients more than the regulated price for covered
services. In the case of balance billing, health care providers
can charge patients for amounts higher than the amount
reimbursed based on the fixed or negotiated prices. In this
case, the patient should pay the difference. Where balance
billing is permitted, some groups of patients may be excluded
from the prices determined and face additional out-of-pocket
fees. The policy of fully reimbursing regulated prices influences
the affordability of health care services to individuals.
Among the settings in this study, several prohibit balance billing,

Where balance billing is including Malaysia, Japan, the Republic of Korea, Germany,
permitted, some groups Thailand, and the USA Medicare program and state of Maryland
of patients may face for preferred providers. Thailand strictly enforces laws to
additional out-of-pocket prohibit balance billing and hospitals are legally required to
return the amount to patients should any cases occur.
fees.
Under the USA Medicare program, balance billing is generally
prohibited for preferred providers within the insurance
network. Similarly, in Maryland, preferred providers are not
permitted to balance bill. Additional protections apply to
low-income beneficiaries enrolled in the Qualified Medicare
Beneficiary program. Enrollees do not pay cost sharing (i.e.,
deductibles, copayments, and coinsurance), which is covered
by the Medicaid program in the beneficiary’s state. Out-of-
network providers can balance bill patients, but they are
limited to the Health Services Cost Review Commission-
approved hospital rate in Maryland.
The Republic of Korea does not permit balance billing for

covered services; however, physicians can provide both insured
and uninsured services in one episode and bill for uninsured
services to compensate for lower payments for covered
services. In Japan, physicians are prohibited from balance
billing. The exception is nursing care facilities, where the rules
restricting balance billing are more relaxed because equity is
considered less problematic in LTC. A separate practice of extra
billing can occur, in which services and pharmaceuticals not
listed in the Japanese Fee Schedule are billed together with
those listed in certain conditions. This practice is mainly limited
to new technology under development by hospitals. Before
being permitted to extra bill, hospitals must submit a request to
the Ministry of Health, Labour, and Welfare to carry out clinical
trials on efficacy and safety, with the objective of including the
technology in the revision of the fee schedule.

Figure 18
Conditions of balance billing in Australia, England, France, and
the USA
Setting Conditions of balance billing
Australia Doctors can charge any fee to any patient at any time with
the gap between the regulated fee and the actual price
paid by the patient. In most cases, the fees charged by
general practitioners are equal to the established fees and
the patient incurs no out-of-pocket payments. For
specialists, fees are higher than regulated prices for 59%
of services.
England Published mandated prices for hospital-based care must
be used unless providers have agreed to an alternative
price, payment approach, or to a different service delivery
model. In very exceptional circumstances, providers can
make an application to National Health Service
Improvement for an increase to a nationally determined
price. Only one application has been approved to date.
France Physicians and dentists working as sector 2 contractors can
balance bill or charge higher than the regulated fees based
on their level and experience. In some cases (but not all)
the amount above the regulated price can be covered by
private complementary health insurance. Balance billing is
prohibited for emergency care and low-income patients.
USA Health providers participating in Medicare cannot balance-
bill. Non-participating providers are allowed to balance-bill
beneficiaries, but the amount cannot exceed 15% of the
Medicare-approved payment amount for non-participating
providers for each service (95% of the Medicare fee
schedule amount). For privately insured individuals, in 29
states and the District of Columbia, there are no state laws
or regulations that protect individuals from balance billing
by out-of-network providers in emergency departments or
in-network hospitals.
Source: case studies (see annexes)
In other settings, balance billing is permitted (Figure 18). In

Australia, doctors can charge any fee to any patient at any time
with the gap being paid by the patient. If the doctor charges a
fee equal to the reimbursement level, the patient faces no
copayment. Although doctors have full discretion over their
fees, in practice, the fees charged by doctors tend to be equal
to the regulated fee (“bulk-billing”). In 2017/18, 86% of all
primary care consultations were bulk-billed, indicating that the
fee schedule acts as a floor price. The high rate of bulk billing
was the result of a major reform in incentive payments to
doctors. General practitioners were given bonus payments if
they bulk-billed (charged zero copayments to) patients who
hold a concession card (for low-income families and
pensioners) or are 16 years or younger. The payment amounted
to an extra AUS $5 for metropolitan areas, and AUS $7.50 for
rural, remote, and some outer metropolitan areas. Whereas bulk
billing is not routine in practice and concession-card holders
are more likely to have zero copayment, other types of patients
are more likely to experience an increase in their copayment.
Such price discrimination, where an identical service can be

purchased by different payers at different prices, became more
of a problem with primary care (Wong et al., 2016). Government
control over specialist prices is more limited. For specialists,
fees are higher than regulated prices for 59% of services.
In England, prices paid can exceed the schedule in certain

extenuating circumstances. Published mandated prices for
hospital-based care must be paid by commissioners unless
providers have agreed to an alternative price or payment
approach, or to a different service delivery model. In very
exceptional circumstances, providers can make an application
to NHS Improvement for an increase to a nationally determined
price when it cannot be locally agreed. Only one such
application has been approved. Patients are not financially
impacted by such decisions.
France permits balance billing for a certain category of health

workers (sector two). In the 1980s, sector two contractors were
allowed to reduce the cost of social contributions for the social
health insurance fund. Those physicians and dentists allowed
to work in sector two can charge prices higher than the
regulated fees based on their level and experience. Prices set
by sector two providers above the regulated fees may or may
not be covered by private complementary health insurance.
Patients without private complementary insurance can face
high out-of-pocket payments, which raises concerns on equity
of access to care. This practice may also drive growth in total
health expenditures since unregulated prices could be highly
inflationary. Regulations prohibit balance billing for emergency
care and low-income patients and, where applied, must be
“reasonable,” which is defined as less than three to four times
the regulated fee.
In the USA, balance billing may be permitted where the patient

selects an out-of-network provider. Six states provide
comprehensive consumer protection, including prohibiting
balance billing and protecting patients from financial liability.8
In contrast, no state laws or regulations exist in 29 states and
the District of Columbia that protect privately insured
consumers from balance billing by out-of-network providers in
emergency departments or in-network hospitals (Lucia et al.,
2017). One survey comparing charges billed by out-of-network
providers to Medicare fees reported that members were
routinely billed 10 to 20 times Medicare rates for out-of-
network care (NASI, 2015). Given that many insurance plans
have very minimal or no out-of-network coverage, exposure to
balance billing in the USA is a major concern for financial
protection (Hempstead, 2018). Recently, federal legislation has
been proposed that prohibits balance billing completely or
allows it only under consent (Dekhne et al., 2019).
8 Comprehensive protection was defined as applying consumer protection to both

emergency department and in-network hospitals settings, as well as to health
maintenance organization and preferred provider organizations. It also includes
protecting consumers by “holding them harmless” from liability of extra provider charges;
prohibiting balance billing; and adopting adequate payment standards or dispute
resolution processes between providers and insurers (Lucia et al., 2017).

6.4
Bundled payments
A bundled payment method involves combining the payments
for physicians, hospitals, and other health care provider
services into a single amount. Bundled payments can refer to
clinical pathways (i.e., maternity), to clinical episodes or to
blending inpatient and outpatient care.
A persistent challenge with the Medicare program in the USA is

that the payments are fragmented, focusing on a category of
care or provider. This allows providers to shift costs to another
part of the care system in response to cost containment
pressures (Frankford and Rosenbaum, 2017). To address this
challenge, Medicare is testing is a new voluntary episode
England adjusts payment model, the Bundled Payments for Care Improvement
regulated prices to Advanced (BPCI Advanced). It generates a single retrospective
encourage health care bundled payment for 32 clinical episodes (29 inpatient and
three outpatient clinical episodes), which begins at inpatient
providers to comply stay or outpatient procedure for 90 days starting on the day of
with best practices. Best discharge or the completion of the outpatient procedure.
practice tariffs focus on Payment is tied to performance on quality measures, and
50 procedures with the payments based on target prices are provided in advance.
Retrospective reconciliation is done with actual Medicare FFS
greatest potential expenditures for a clinical episode, which results in a positive
impact on outcome. or a negative balance based on the target price and adjusted
for quality. Positive balances are returned to the participating
facilities, and negative balances must be repaid. The first cohort
of participants started their participation on October 2018, and
the initiative will run through the end of 2023.
The Maternity Pathway Payment System was first introduced in

2012-13 by NHS England and replaced FFS arrangements for
birth and block grants for community midwifery services. The
scheme involves a single prospective national price (tariff)
provided to a NHS commissioner, which pays providers for an
integrated package of care offered to all pregnant women and
their newborns. The pathway consists of three integrated
packages of care covering the antenatal, birth, and postnatal
phases (Department of Health, 2016). The purpose of the
scheme is to give providers the financial flexibility to focus on
providing high quality, coordinated care. A new patient level
activity data set for maternity care was also introduced. The
tariff is based on the average cost of a stage of care and allows
for different levels of payment depending on the risk and
complexity profile of the woman. Her risk and complexity
profile is determined prospectively within the first few booking
appointments. The tariff for the antenatal and postnatal phase
is split into standard, intermediate, and intensive pathways,
while the tariff for the birth episode has seven payment levels,
six related to clinical complexity, and one specifically for home
births (NHS Improvement and NHS England, 2019).

6.5
Incentives for quality
Any of the payment methods can be combined with explicit
specific performance-based rewards or penalties (results-based
financing or pay for performance) to promote quality and
performance.
England adjusts regulated prices to encourage health care

providers to comply with best practices (Best Practice Tariffs
(BPTs)). BPTs focus on 50 procedures with the greatest potential
impact (i.e., high volume care, significant unexplained variation
in practice, or significant clinical impact of best practice on
outcomes), strong evidence base, and clinical consensus.
Regulated prices are adjusted upwards or downwards based on
national average costs. The price differential between best
practice and usual care is calculated to ensure that the
anticipated costs of undertaking best practice are reimbursed
while creating an incentive for providers to shift from usual
care to best practice. BPTs apply to all providers of NHS-funded
care for hospital admissions related to hip fracture, stroke,
cholecystectomy, and cataract surgery. Early evidence suggests
that the impact was positive for some conditions. Among
participating hospitals, two-fifths of episodes receive the BPT
for hip fracture. Those receiving BPT reported a larger decrease
in mortality rate (by 0.7%) and a 2.1 % higher increase in the
share of patients discharged within 56 days (Marshall et al.,
2014). Evaluators also noted the importance of the conditions
of payment, differences in quality trends, and ongoing quality
improvement initiatives (McDonald et al., 2012).
In Australia from June 2017, the pricing authority has been

working with another independent body, the Australian
Commission on Health Care Safety and Quality, to adjust prices
with the objective of promoting safety and quality. For example,
hospital admissions that include a sentinel event (i.e., serious
medical errors or hospital-acquired infections) are not paid.
Prices are adjusted downward for hospital-acquired
complications after adjusting for patient characteristics.
Discussions are underway about how to adjust prices for
avoidable hospital admissions. In the USA, all states have
non-payment polices for health care-acquired conditions such
as retaining a foreign object surgery, stage III and IV pressure
ulcers, and surgical or other invasive procedures performed on
the wrong body part. Evaluations of zero reimbursement for
sentinel events in the USA did not demonstrate an impact on
their incidence (Lee et al., 2012). Instead, such policies resulted
in perverse incentives for coding practices –implying that such
events would more likely go unreported (Kawai et al., 2015).
In the USA, the Quality Payment Program mandates incentives

for value and outcomes for eligible health care providers
through a Merit-based Incentive Payment System (MIPS) and
Advanced Alternative Payment Models (AAPMs). Under MIPS,
the performance of eligible clinicians is scored in four areas:
quality (six measures of performance that reflect the scope of
practice); improvement activities (activities appropriate to each
practice related to enhancing care coordination, shared clinical
decision-making, and expansion of practice access); promoting
interoperability (sharing information with other clinicians or the
patient); and total cost of care (CMS, 2019b). In 2019, final
scores above a fixed threshold receive a 7% positive payment
adjustment, while those below the threshold receive a 7%
negative payment adjustment. APMs give bonus payments to
provide high quality and cost-efficient care for specific clinical
conditions, care episodes, or populations.
In 2019, Maryland implemented the 10-year Total Cost of Care

Model to promote better coordination across hospital and
non-hospital settings, including mental health and LTC. The
model sets a per capita limit on Medicare total cost of care.
All-payer hospital cost growth will be limited to 3.6% per capita,
a limit set in 2014 based on long-term economic growth. Each
hospital receives a population-based payment amount to cover
all hospital services provided during the year. Hospitals can
make incentive payments to non-hospital health care providers
who perform care redesign activities to improve quality. A
participating hospital may only make incentive payments if it
has attained certain savings under its fixed global budget, and
the total incentive payments cannot exceed such savings. In
addition, primary care providers receive an additional per
beneficiary per month payment directly. These performance-
based incentives are intended to reduce hospitalizations and
improve quality (CMS, 2019a, 2019b, 2019c).

7/
Infrastructure
for costing and
pricing

7.1
Institutional entities
In some settings, the task of price setting is located directly
under the responsibilities of the government ministry (Figure
19). This occurs in England, Japan, Republic of Korea, and
Thailand. In England, the NHS responsibilities for price setting
are shared by NHS Improvement and NHS England who are
working under a joint operating model since April 2019. In
Japan, the Bureau of Medical Affairs sets forth the biennial
revision of the fee schedules and authorizes negotiations
between the Japanese Medical Association and other
stakeholders with the Ministry of Health, Labour and Welfare.
In the Republic of Korea, the Health Insurance Review and
Assessment costs and analyses provider behaviour related
to pricing.
The Thai National Health Security Board is a state agency under

the supervision of the Public Health Minister and works
towards implementation of the Universal Health Coverage
Scheme. A sub-committee on financing analyses unit costs,
utilization rates, high cost interventions, and all other
benefit packages as approved by the Board and proposes a
capitation budget. The benefits of this approach are the
linkages between payment systems for primary and inpatient
care, and the close alignment between payment systems and
government goals.
Others have set up independent agencies that are responsible

for developing and updating hospital prices and DRG
schedules. This has occurred in Australia, France, and Maryland
(Figure 20). In Australia, the Independent Hospital Pricing
Agency reports to a board chosen by the national and state and
territory governments. It has broad responsibilities for activity-
based costing, the classification system, data collection, and
calculating costs. It employed 42 staff in 2017/18, and its
operating budget was AUS$ 17.9 million. In France, the
Technical Information Agency of Hospitalization (ATIH) was
created in 2002 as an independent public administrative
institution, which is co-funded by the government and the
national health insurance funds. It collects data and categorizes
DRGs. In 2017, it employed 118 staff, and its budget was
approximately EUR 29.4 million.

Figure 19
Technical agencies mandated for price setting, where located
within the government
Setting Institution responsible Tasks Resources
England National Health Service NHS Improvement regulates resource use, NHS England and NHS
(NHS) Improvement, NHS financial levers and operational performance Improvement employs
England using a shared definition of quality and efficiency approximately 7500 staff, and
by the Care Quality Commission. Their some 75 staff work in the two
responsibilities include commissioning health pricing teams.
care services in England; contracting for general
practitioners, pharmacists, and dentists;
supporting Clinical Commissioning Groups that
plan and pay for local services such as hospitals
and ambulance services; and calcuating prices.
Japan Ministry of Health, The Prime Minister sets the global revision rate Staff in the Medical Affairs
Labour and Welfare in the bieenial revision of fees and the Division number 84 in total,
(MoHLW), under the conditions of billing that establish the human including 20 physicians, 2
Bureau of Medical Affairs resource requirements and patient conditions. dentists, 2 pharmacists, 2 nurses,
The Bureau of Health Insurance serves as the and 12 career bureaucrats, with
secretariat to ensure that the cumulative effect the rest being administrative
on item revisions are made equal to the global staff.
budget. It negotiates with the Japanese Medical
Associations, hospital associations, and specialist
groups about the details of the revisions.
Republic National Health The HIRA costs and analyses provider behaviour The NHIS has about 14,000
of Korea Insurance Corporation related to pricing. One of the key institutions workers. HIRA has about 2500
(NHIS), Health Insurance under HIRA is the Healthcare Review and staff, one headquarters (22
Review and Assessment Assessment Committee, which plays an departments), one research
(HIRA), Insurance Policy important role in the benefits design, review, and institute, and seven regional
Deliberation Committee assessment. The HIPDC approves major decisions offices. The Health care Review
(HIPDC), National Health about health insurance, including contribution and Assessment Committee
Insurance Service (HIRA), rates, benefit packages, pricing, etc. The HIRA consists of approximately 1,050
Ministry of Health and each provider association (for physicians, members, with a maximum 50
hospitals, pharmacists, etc) negotiate fees. full-time members. HIRA also has
various expert committees to
support technical decisions.
Thailand National Health Security The NHSO is a state agency under the NHSO has 881 staff (464 in the
Office (NHSO), National supervision of the Public Health Minister, HQ office, and 467 in 13 regional
Health Security Board working towards the implementation of the offices). Staff generate the annual
(NHSB) Universal Coverage Scheme. The sub committee budget, monitor and purchase
on financing under the NHSB analyses the unit services, improve access and
costs, utilization rates, high cost interventions financial risk protection to its 47
and all other benefit packages as approved by million members. The total
the NHSB, and proposes a capitation budget. administrative cost is 1.49% of
total budget (average 2003-19).
Sources: case studies (see annexes).

Figure 20
Technical agencies established for hospital
price setting
Setting Entity Responsibilities Resources
Australia Independent The IHPA’s role is price determination. It takes responsibility for the For the financial year
Hospital ongoing development of the component parts required by activity- 2017/18, the IHPA’s total
Pricing based costing, the classification system (AR-DRGs and for sub-acute expenses were AUS
Authority and non-acute services in the Australian National Sub-acute and $17.9 million and 42
(IHPA) Non-Acute Patient Classification), data collection on activity (the staff were employed.
National Hospital Data Collection), calculating costs (with a standard
framework for costing activities, i.e., the Australian Hospital Patient
Costing Standards).
France Technical The ATIH is an independent public administrative institution For the financial year
Agency for co-funded by the government and national health insurance funds, 2017, the ATIH employed
Hospital under the control of the Social and Finance Ministries. It collects 118 staff and its
Information data on hospital activity in order to establish a national schedule, expenses amounted to
(ATIH) and undertakes financial analysis of health care facilities and of the EUR 29.4 million.
health system.
Germany Institute for The INEK is jointly supported by the Federal Association of Sickness All hospitals pay a DRG
the Hospital Funds, the Association of Private Health Insurance, and the German system contribution per
Remuneration Hospital Federation. It receives data from hospitals annually to hospital case, and the
System (INEK) develop the Case Fee Catalogue for the following year. A total of InEK receives 1/3rd of
253 hospitals (13% of the total) share data that follow a the total contribution to
standardized cost accounting approach to calculate the costs of fund their activities. In
treating individual patients. Participating hospitals receive a fixed 2017, the INEK’s
allowance for sharing the cost accounting data. estimated budget was
EUR 5 million. It employs
approximately 50 staff.
Maryland, Health The HSCRC works closely with the Maryland Department of Health, The HSCRC employs 39
USA Services Cost and its seven commissioners are appointed by the Maryland full-time staff, with a
Review governor. It is authorized to establish hospital rates to promote cost budget of $14.1 million
Commission containment, access to care, equity, financial stability and hospital funded by fees collected
(HSCRC) accountability. It is given broad responsibility regarding the public from hospitals.
disclosure of hospital data. All Maryland hospitals are paid on the
basis of the rates established by the HSCRC. These rates are
updated each year based on multiple factors, including the
Medicare “market basket” forecast, economic conditions,
productivity improvements, changes in case mix and the previous
year’s performance.
Sources: case studies (see annexes).
In Germany, the Federal Association of Sickness Funds, the

Association of Private Health Insurance, and the German
Hospital Federation established the Institute for the Payment
system in Hospitals (InEK). It is not an independent entity, but a
public entity supervised by the three parties. To fund the
operations of the Institute, the three parties negotiate annually
an amount in which hospitals pay a DRG system contribution
per case. Participating hospitals receive two-thirds of the
contribution, whereas the InEK receives one-third. In 2017 and
2018, the contributions amounted to EUR 1.30 and EUR 1.31
per case, respectively. Given that the number of cases
amounted to over 19 million in 2017, this implies that the InEK
received a budget of EUR 5 million. Generally, these institutes
are responsible for the technical details of price determination,
including establishing common frameworks for price estimation
and collecting directly or commissioning the collection of data.

Notably, the InEK neither collects or commissions data. It
employs approximately 50 staff.
Maryland established the Health Services and Cost Review

Commission in 1976 to regulate hospital fees for all hospitals,
based on a list of approved fees for specific services and
departments. It works closely with the Maryland Department of
Health and its seven commissioners are appointed by the
Maryland governor. The agency is thus independent, and its
decisions are not reviewed by the legislative or executive
branches. The Commission is responsible for updating the rates
annually and publicly disclosing hospital data. It employs some
39 staff and has a budget of US$ 14.1 million funded by
hospital fees.
While situations vary, independent agencies may have more

freedom from conflicts of interest, and the political standing to
resist industry and regulatory capture. The establishment of
national independent agencies can help to promote
comparability and harmonization of clinical classifications
across hospitals. In some settings, such harmonization applies
across both public and private sectors, whether through the
contracting of services or price benchmarking.
7.2
Formal stakeholder consultation
Many stakeholders have an interest in the outcomes of price
setting and regulation, particularly medical doctors and health
care provider associations. Lack of formal consultation and
stakeholder engagement can lead to stalemates in the price
setting process. In the case of the USA, political challenges led
to the downfall of price regulation in many states in the 1980s,
despite the positive impact of fixed prices on cost savings
(Hadley and Swartz, 1989). Feedback from health care
providers involved in care provisions may ensure acceptability
of the regulated fees. A balance must be found between
maintaining dialogue with stakeholders, including the health
industry, while also observing objectivity and independence. To
address this challenge, formal consultation processes have
been implemented that involve stakeholders in the discussion
of the base price and the cost elements that it covers.
The Maryland Health Services Review Commission has an

Advisory Committee and technical working groups that conduct
formal expert technical consultation. In Australia, consultation
and stakeholder feedback is an integral part of the price setting
processes. The pricing authority works with a Jurisdictional
Advisory Committee and a Clinical Advisory Committee in
developing its systems and analyzing data. Its pricing framework
establishes various principles, including transparency, and the
framework itself is reviewed annually in consultation with the
federal government, states, and territories. There is also a period
of public consultation, and the studies are published on the
authority’s website, including the list of prices.
Japan’s consultation process takes place within the Central
Social Medical Care Council, which is composed of seven
members from payer groups (including social health insurance,
business, and labour), seven members from provider groups, six
members who represent public interests, and ten specialists
representing professional associations and industry. In the
Republic of Korea, the Health Insurance Policy Deliberation
Committee consists of 25 members, chaired by the Vice
Minister of Health and Welfare. Eight members represent
payers (including labour unions, employer associations, civic
groups, consumer associations, farmers associations, and
self-employment associations), eight from health care
professional associations (representing medical doctors,
hospitals, traditional medicine practitioners, dentists,
pharmacists, nurses, and pharmaceutical manufacturers); and
eight experts and public agency representatives (from
Ministries of Health, Strategy and Finance, Health insurance,
and independent experts). In Thailand, the proposed budget for
the Universal Coverage Scheme is evaluated by all relevant
actors including the Ministry of Finance, Bureau of Budget,
technical experts, and health care provider representatives.
In England, public consultation on the price-setting

methodology is formalized with internal stakeholders, as well
as the external clinical community, NHS service providers, and
Clinical Commissioning Groups to ensure that new proposals
make clinical sense and are practical to implement. If more than
66% of commissioners or providers object, the regulated prices
must be referred to the Competition and Markets Authority or a
new consultation is conducted.
7.3
Investments in data collection
The determination of the payment method and the collection
of data for costing is closely linked with the information that is
available. Each approach to costing requires different
information and inputs (Figure 21). Top-down costing
approaches, for example, require the availability of health
provider cost information by department and major categories
(i.e., salaries and medicines). The availability and accuracy of
this information is a determinant of how costs and prices are
calculated. Recognizing the incentives inherent in the
traditional line-item budgets, and to be able to modify payment
methods over time, investments have been made into data
collection systems to collect input costs, output volumes, and
outcomes.

Figure 21
Data management capacities required by base for payment
Capacities Line-item Global Capitation Fee-for- Case-based

budget budget service payment
Basic accounting
x x x x x
Management of enrolment database

x
Ability to project revenues and expenditures

x x x
Programming of DRG grouper

x x x
Automated claims processing

x x
Cost accounting system to calcuate relative

case weights
x x
Source: Adapted from Cashin, 2015.
Özaltın and Cashin (2014) identify a few lessons for middle-

income settings about developing the required minimum
dataset for implementing payment systems. They recommend
focusing on large expenditure items and data that are feasible
to collect. Detailed information that is difficult to collect and
does not improve the quality of the results should be omitted
from the data collection efforts. Similarly, collecting only the
data needed can avoid time spent collecting extra information
that does not inform the costing analysis. Towards this effort,
costing instruments should be pretested, reviewed and
simplified after the initial data collection efforts.
Being imperfect can be a starting point. In many settings,

pricing work can start even though only skeletal data sets are
available. In such cases, initial information can be used from
available information – whether collected from settings with
similar cost structures, historical reimbursements, or regional
price averages from commercial health insurer databases, for
example. At the same time, the minimum datasets needed can
be identified, and processes can be put into place to
continually review and improve on data infrastructure.
This is the experience of the National Health Insurance Scheme

in India, which targets over 500 million poor and vulnerable
people (Figure 22). Established under a very short time frame,
the government of India set reimbursement rates without
complete costing data by using available information, while
also putting into place a review mechanism to modify and
improve over time.

Figure 22
Pricing of Services under the National Health Insurance
Scheme of India (PM-JAY)
The Government of India launched a mega health program called

Ayushman Bharat, which focuses on primary, secondary and tertiary care
through two separate components. The first component aims to set up
approximately 150,000 health and wellness centres that will provide
comprehensive primary care. The second component is a new National
Health Insurance Scheme called Pradhan Mantri – Jan Arogya Yojana
(PM-JAY), which provides a cover of Rupees 500,000 (approximately US$
7143) per family per year for secondary and tertiary care conditions. The
scheme targets more than 500 million poor and vulnerable people across
the country, making it the largest completely government funded scheme
in the world. PM-JAY replaces an earlier scheme called Rashtriya
Swasthya Bima Yojana.
One of the critical decisions in the new scheme is the decision about
provider payment mechanisms. The government decided to use a system
of package rates, whereby a fixed rate for each procedure is paid to the
hospital. The rate is fixed by the government in advance, and hospitals
are not allowed to charge any other money from the patient. No cash is
exchanged as a part of obtaining care. For medical conditions, a fixed per
day rate is paid. Similar provider payment mechanisms have been used in
India across many government funded health insurance schemes.
Currently almost 1400 packages and their rates have been fixed in
advance by the National Health Authority, an independent agency under
the Ministry of Health and Family Welfare (MoHFW) that was set up to
manage PM-JAY.
For preparing these packages and their rates, MoHFW formed a

committee comprising various stakeholders under the chairmanship of
the Director General of Health Services. This committee formed various
sub-committees for each of the specialties. The sub-committees also
collected data about the packages and their rates for RSBY and various
other state government funded health insurance schemes. Data related
to the costs of treatment in both public and private providers was also
collected. Based on the data collected, inputs from various experts and
cost estimations, the final list of packages and their prices was prepared
by each of the sub-committees. The committee collated the packages and
rates and then finalized the list with their rates. These rates were then
shared for peer review with the think tank of the Government of India
(NITI Aayog). NITI Aayog further analysed these rates and discussed with
various industry associations, medical associations and hospitals. Based
on these discussions and other inputs, NITI Aayog provided their final
recommendations to MoHFW. Using these recommendations, the list of
packages with their rates was finalized and are now being used in the
scheme.
To address the differences in quality across various hospitals and

accommodate those in the package rates, the scheme guidelines also has
a provision for a fixed percentage incentive over the package rates to the
hospitals that are accredited. In addition, teaching hospitals and hospitals
located in rural districts (called aspirational districts) are also provided a
fixed incentive over and above the package rates.
This system of package rates is a simplistic one but, at the same time, it
prevents the huge variations in prices charged by the health care
providers and keeps the cost of the scheme under the control of the
government. The government is now working on further refining these
rates and creating a mechanism for regular feedback with respect to the
list and rates. This will ensure that the rates are in sync with market
conditions. In addition, new conditions are added regularly through a
systematic process and conditions that are not required are removed.
Source: Jain Nishant, Indo-German Social Security Programmme

7.4
Information disclosure
Price transparency, or publishing service prices charged by
health care providers, is one means to help consumers make
informed choices. Price and quality information also inform
active purchasers of health care and can, in some cases, control
overall spending and reduce price variation for routine services.
Depending on the health care markets, publishing prices could
also stimulate price competition on the supply side and force
high-priced providers to lower their prices so that they remain
competitive. Many initiatives publish average or median within-
hospital prices for individual services, and some report total
and out-of-pocket costs for care episodes (Figure 23).
Australia publishes both price and quality information for the

public (IHPA, 2019; AIHW 2019). Maryland publishes an online
price guide and a hospital performance evaluation guide
(HSCRC, 2019). The Health Insurance Review and Assessment in
the Republic of Korea publishes online its regulated prices and
quality measures. The Ministry of Health, Labour, and Social
Welfare in Japan publish their reports surveying patient
satisfaction indicators nationally (MoHLW, 2019b). In the USA,
the Centres for Medicare and Medicaid Services has developed
an online physician fee look-up tool (CMS, 2019d) for more than
10,000 physician services and their associated relative value
units. A companion site also describes hospital measures of
quality (CMS, 2019e). Many individual states also now have their
own initiatives for providing information to consumers about
hospital prices (Sinaiko and Rosenthal, 2011). All costing and
price information is in the public domain in England, and an
impact assessment is published alongside each national tariff.

Figure 23
Public release of information about price schedules and quality
Setting Published prices Scope of information reported Published quality information
Australia National Hospital Cost Data Detailed and average costs per episode National Indicators of Safety and
Collection Cost Reports for acute care admissions, emergency Quality in Health Care
department, non-admitted patient
(https://www.ihpa.gov.au/ (https://www.safetyandquality.gov.
expeditures, sub-acute and other
publications) au/our-work/indicators/)
products, and the pricing framework
England National Tariff Payment Costs from all secondary care providers Individual provider level reports and
System and Published Costs against currencies where they exist; broader reports from the Care
National prices for acute services and Quality Commission
(https://improvement.nhs.uk/
local pricing rules for services without
resources/national- (https://www.cqc.org.uk/)
national prices in secondary care
tariff-1719/)
France DRG prices, reimbursement DRG prices for public and private Quality, satisfaction and safety
rates for ambulatory services, hospitals for acute (non-psychiatric) indicators collected from all
and average prices charged by care, and range of prices and most hospitals and published by the
hospital/health professionals frequent amounts for out-of-pocket national health authority (HAS)
costs (before complementary health
(https://www.atih.sante.fr/ (https://www.has-sante.fr)
insurance coverage) for each hospital
tarifs-mco-et-had)
and health professionals
Germany Public reporting of DRGs, For hospital prices: relative weights All hospitals are required to
hospital base rates, hospital per condition, average length of stay, document quality information on
add-on payments, physician outlier adjustments and add-on 250 selected indicators
fee schedules, and nursing payments; for physician fees: the
(https://g-ba-qualitaetsberichte.
home rates reports on points and eurocents per service,
de/#/search)
websites of each nursing definition, detailed information on
home minimum required services and
billing restrictions
(https://www.g-drg.de)
Japan Outline of Health Care (In English), published descriptions Patient satisfaction indicators are
Insurance Systems, Ministry include patient co-payments, medical collected from all hospitals and
of Health, Labour and Social care benefits, cash benefits, premium clinics and published by the Ministry
Welfare rates and government subsidies of Health, Labour, and Welfare
(http://www.mhlw.go.jp/ (https://www.mhlw.go.jp/toukei/
english/wp/wp-hw6/dl/02e. saikin/hw/jyuryo/17/dl/kakutei-
pdf) kekka-gaiyo.pdf)
Maryland Price Transparency, Maryland Average hospital price per case, Maryland Health Care Quality
state, USA Health Care Commission’s average length of stay in the hospital, Reports
(MHCC) consumer website average hospital charges by certain
(https://healthcarequality.mhcc.
types of payers (i.e., Medicare,
(https://healthcarequality. maryland.gov)
Medicaid, Commercial, and other)
mhcc.maryland.gov)
USA Physician Fee Schedule Provides information for >10,000 Measure Management System,
Look-up, Centres for Medicare physician services, relative value units, Centres for Medicare and Medicaid
and Medicaid Services fee schedule status indicator, and
(https://healthcarequality.mhcc.
indicators needed for payment
(https://www.cms.gov/apps/ maryland.gov)
adjustment. Prices are adjusted to
physician-fee-schedule/
reflect regional variations
overview.aspx)
Republic Health Insurance and Review – Health Insurance and Review
of Korea Assessment Service Assessment Service
(http://www.hira.or.kr/) (http://www.hira.or.kr/)
Thailand Guidelines for obtaining Price, fee schedule, central price for Annual consumer satisfaction survey
health care expenses in reimbursements by Academic Network for Community
Universal Health Coverage Happiness Observation and
Scheme published annually Research, Assumption University of
by NHSO in the Thai language Thailand; NHSO Annual Fiscal Report
on accessibility and quality
(https://www.nhso.go.th/eng)
Sources: IHPA, 2019; AIHW, 2019; CMS, 2019d, 2019e; MHCC 2019;
MHLW, 2019a, 2019b; case studies (see annexes).

The impact of publishing prices and quality depends on many
factors. Publishing information about both quality and prices
helps overcome consumer difficulty in evaluating technical
quality. Where quality information does not accompany prices,
consumers may equate price with quality and thus choose
higher priced services – despite weak associations between
price and quality for routine care (Sinaiko and Rosenthal, 2011).
Patients may rely on information from their health care
providers about where to obtain health care and also consider
other factors such as convenience, relationships and amenities.
Insured patients are insulated from prices and therefore are
less cost conscious (Cooper et al., 2018). Even in the case
where patients want to compare prices, the patient will face
information asymmetry and time constraints for evaluating
information – constraints that would be prohibitive for
emergency care (Bai and Anderson, 2015).
Generally, common procedures performed in different settings

and prescription medicines may be appropriate for price
comparisons, particularly where co-payments result in high out-
of-pocket costs. In terms of interpretation, average unit costs
are the most readily available; however, cost per episode may
be more meaningful to patients. Quality information
must be reported alongside prices so that patients and
purchasers can make sound decisions. In the USA, some
employers offer their employees meaningful incentives to
choose higher-value providers, such as higher reimbursements
or bonuses for providers offering quality care for lower prices
(McCluskey, 2016).

8/
Best practices for

low- and middle-
income settings

We conclude the paper with lessons learned, particularly for
low- and middle-income settings that are increasing their
public funding to health and looking to other settings for useful
experiences. While this study included many highly developed
health care settings, it is notable that all policy-makers
continue to strive to align payment levels with incentives for
quality care. The lessons learned from these settings include
investing in data infrastructure and institutional capacities,
planning sequenced implementation of changes, using prices
as instruments to drive health policy goals, and establishing
systems of monitoring and evaluation to systematically identify
adjustments and modifications needed to attain health
objectives.
8.1
Investing in data infrastructure
Sound pricing and payment systems require accurate
information about costs, utilization, and quality of care.
Information systems can be one of the most important barriers
to the implementation of provider payment mechanisms in
low- and middle-income settings. DRG-based financing for
public hospitals requires substantial investments in data
collection and hospital coding. Data collection infrastructure,
coding of key information, including procedures and diagnoses,
and skilled human resources in hospitals are needed
investments for generating the minimum dataset required for
accurate analysis.
Yet, having only rudimentary data should not prevent attempts

to initiate reforms in pricing policy. In many settings, pricing
work can start even though only skeletal data sets are available.
Where data infrastructure is not yet in place, information can
be used from available sources initially. This may include
information from settings with similar cost structures, historical
reimbursements, or regional price averages from commercial
health insurer databases, for example. At the same time, the
minimum datasets required can be identified. This may focus
on large expenditure items and data that are feasible to collect.
Figure 24 is an example of this process underway in Malaysia.

Figure 24
Costing health services in Malaysia
The Ministry of Health (MoH) in Malaysia, including the Institute for

Health Systems Research (IHSR), initiated costing exercises to estimate
the budget requirements for delivering health service in government
facilities. To calculate the costs for hospital discharges, outpatient visits,
and daycare visits, the IHSR research team collected data using provider
questionnaires and estimated the share of organization-level expenditure
by departments.
One public clinic that uses electronic medical records was selected to
conduct a costing exercise to determine the cost per visit for patients
with specific conditions. Four people developed a costing template for
each service using the patient as the cost object and collected data about
staffing medicines, medical and non-medical consumables, and
equipment and devices. The team calculated the cost of 310 separate
services grouped into 11 visit categories. The visit categories were acute
upper respiratory tract infection, prenatal care, routine child health
examination, primary care for hypertension and Type 2 diabetes, dental
exam, dental caries, fever, contraceptive management, nail removal, and
dengue rapid test. They added up the costs of services in each category
to arrive at an average cost per patient visit per category. Included in the
costs were services and supplies, assets, grants and fixed charges,
building, and land. Overhead costs were distributed by assuming average
resource use across patient types, and personnel costs were assigned
based on the average staff time spent on specific procedures.
For establishing DRGs in hospitals, the team costed all hospital inpatient
cases using a top-down approach to measure and value personnel,
medical products, overheads, and capital resource use. They plan to cost
intensive care unit stays because those stays are known to be
heterogeneous in their resource use. The team also plans to use the
bottom-up approach to cost expensive laboratory tests and radiological
interventions. Between 12 to 50 staff at ten hospitals were required to
complete the exercise over a four-month period, including one month for
verification.
Source: Adapted from Özaltın & Cashin, 2014.
8.2
Building institutional capacities
Given the technical and political complexities of price
regulation, in several settings, entities with the legal authority
to set up and control payment rates have been established. The
mandate of these agencies is to develop a credible price
schedule. This includes grouping and ordering services based
on their complexity, taking into consideration the available
health resources, burden of disease, and clinical protocols and
pathways.
Whether an independent entity or designated institution,

characteristics of successful systems include political
independence, formal systems of communication with
stakeholders, freedom from conflicts of interest, and political
standing to resist both industry capture and political pressures.
In some cases, such entities have independent sources of
funding that are separate from general revenues. Clearly
delineating the technical task of establishing the price schedule

from the political process of negotiating payments to health
care providers has also been recommended (Kumar et al., 2014).
There are multiple stakeholders involved in price setting and

regulation, and systems have failed in the past when they faced
political challenges (Barber et al., 2018). Critical to the work of
price setting is a process that also involves stakeholders to
establish a base price and identify the cost elements that are
covered by the unit of payment. To do this objectively, it is
important to establish formal systems of collaboration with
medical doctors and specialists, health care providers, and
payers. Formal and transparent systems can help establish a
balance between maintaining dialogue with stakeholders while
also observing objectivity and independence.
Appropriate institutional oversight can help insulate the

authority from external influences. Mechanisms for price
setting are instruments to achieve broader system goals. Where
clear policy goals and priorities have been articulated, they can
be used to guide action and may avoid overly complex
implementation processes. Regular public reporting on
performance standards and targets linked to the overarching
policy priorities can increase accountability. Such mechanisms
also allow for modifying processes that have become overly
complex that inhibit performance and responsiveness.
An important issue for low- and middle-income settings is how

to make use of all health resources available to attain coverage
and financial protection. Price setting for only one part of the
health system (either public or private) could create incentives
for providers to shift care to other settings that are not subject
to price regulation (Frakt, 2011). This would diminish the impact
of pricing policies on coverage and desired outcomes. A
comprehensive price setting system could be used to create a
level playing field and eliminate the fragmentation across
public and private sectors. In this sense, price schedules are a
public good, whereby private health plans can use prices set by
the government as benchmarks. Given finite resources for
health, price regulation can be used to promote greater value
for all payers, and both public and private health spending.
8.3
Planning sequenced implementation
Particularly for settings that employ line-item budgets,
substantial long-term planning is needed to change payment
systems, estimate prices, and use prices and payment systems
to reach policy goals. Figure 25 illustrates an example of a
planning exercise to implement such changes over a period
of a few years including investing in institutional capacities
to sustain changes in how providers are paid (Özaltın and
Cashin, 2014).

Figure 25
Hypothetical example of sequencing the change in payment
methods
Preparation Initiation Strengthening implementation
Planning Analyse utilization of health Plan new formula for setting budget Establish caps and budgets based
activities services across providers. caps that gradually introduces on data about activities and
volumes. population.
Plan to gradually consolidate and Begin consolidating and reducing Flexibility given to providers to
reducing budget line items. line items for budget formulation move budgets across line items.
and implementation.
Primary Estimate population for capitation. Introduce new formula for Initiate electronic registration for
health care calculating base payment. population database for capitation.
capitation
Conduct cost analysis of PHC Introduce mechanisms to account Expand incentives for health
benefits package to estimate base for mobile and migrating promotion and disease prevention.
payment. populations.
Estimates adjustments for different Apply geographic adjustments.
regions.
Outpatient Analyse volumes and delivery for Explore bundled payment options Introduce bundled payments with
bundled acute outpatient services: day for episodes of care among different a cap, and incentives for the
payments surgery, dialysis, cancer. providers. management of chronic conditions.
Hospital Analyse current case-based Develop new case groups and Expand number of groups, adjust
payments groupings and cost per case adjustable base payments. for severity and comorbidities.
(based on distribution within each group.
DRGs)
Conduct simulations.
Source: Adapted from Cashin, 2015.
For any payment reform, the starting point is developing a

classification system of the services that are currently being
delivered. This involves an analysis of utilization and costs for
the different categories of care and facilities, and a plan to
consolidate budget line items. Subsequently, new formulas for
setting budget caps can be initiated to gradually introduce
volumes. The budget formulation process can utilize
consolidated line items for implementation, and data collected
in the first stage can be used to calculate base for payments
while incorporating adjustments for payment adequacy by
region. During implementation, the budget planning process
can be based on data about activities and population, and
greater flexibility given to providers to move budgets across
line items. Investments in health information systems could
allow for electronic registration of the population to create the
database for capitation. Finally, monitoring systems could
inform adjustments in prices and payment systems to expand
on incentives for important public health goals, such as quality
care and disease prevention.
This is not to endorse any one payment or pricing method,

which should be determined based on local needs and
capacities. For example, should there be a plan to implement
capitation, in many settings, the first task would be to decrease
balance billing for covered services that may lead to
catastrophic spending.

Low- and middle-income settings typically initiate payment
reforms while also building critical capacities in health systems.
Given that the strength of these fundamental capacities can
affect the speed and quality of implementation, continued
investments in broader health systems capacities should
receive greater attention. Unbiased clinical care standards
and treatment pathways are the basis of purchasing and
pricing. Managerial capacities at central and health facility
levels are needed to analyse and implement changes and
manage contracts. Strong professional associations can
establish systems of self-regulation and enable participation
in negotiation processes. The strength of professionals
representing primary care, for example, may affect the extent
to which primary care is recognized and rewarded. Hospital
autonomy can ensure that hospitals have decision-making
authority to respond to incentives for efficiency. Policy-makers
can shape the health care market through trade and
competition policies, which can influence hospital mergers
and acquisitions that affect prices.
8.4
Establishing prices that approximate the
most efficient way of delivering care
Prices should approximate the cost of delivering services in the
most efficient way that enables quality and health outcomes.
This minimizes incentives for inappropriate levels of care and
enables accurate budget projections. Costing aims to collect
information that reveals the costs of delivering services and
providing quality patient care. To do this, different
methodologies have been used to approximate the costs of
health services and allocate indirect costs. Costing studies
should be sufficiently large to capture cost variations. In
instances where unit costs are not available, other options
include using information and experiences from other settings.
Costing studies have important limitations in reflecting costs

at one point in time within existing service delivery structures,
including their inefficiencies. Costing exercises can be useful
if they reveal information about the underlying cost structure
of service delivery and enable the development alternative
scenarios about modes of service delivery that offer higher
levels of efficiency and quality. Thus, costing exercises should
not be considered one-off exercises. Costing is a part of an
ongoing process to collect information about the different
alternatives to align resources and service delivery
configurations with the desired outcomes, i.e., coverage,
quality, financial protection, and health (WHO, 2015b).

8.5
Using prices as instruments to promote
value for health spending
We have emphasized that prices should reflect actual costs.
However, the price level not only ensures adequacy in covering
the costs of delivering services but also provides important
incentives for health care providers. In each of the settings
studied, pricing and payment systems are recognized as
powerful tools to drive broader health system goals.
Geographical price adjustments are used to ensure that health

facilities are adequately reimbursed and compensated for
factors outside their control. Prices are also adjusted to
promote greater coverage of certain services or access for
specific populations to attain broader policy objectives. For
example, prices have been adjusted in many settings to ensure
the provision of care in rural and remote areas and for those
providers treating high numbers of low-income or high-cost
patients. Regulated prices are frequently modified to promote
education, research, and innovation in addition to national
health priorities. Pricing policies have been used to control
volumes and overall expenditure levels through reductions in
prices for repeated unplanned outpatient visits or hospital
readmissions. A number of countries prohibit or restrict balance
billing. This ensures that patients are fully reimbursed at
regulated prices and ensure that covered services can be
accessed and remain affordable.
8.6
Strengthening the national role in setting
prices
While the methods for setting prices vary and are grounded in
historical developments, we can conclude that unilateral price
setting by a regulator eliminates price discrimination and
performs better in controlling growth in health care costs. In
contrast, individual negotiations between buyers and sellers
are the weakest along these same parameters. Both collective
negotiations and unilateral administrative price setting also
have the potential to improve quality better than individual
negotiations. Generally, macro-budgeting tools and limits on
the rate of budget growth have provided strong controls on
expenditures under different payment systems.
Where prices are used as instruments to attain policy goals, a

strong central role in guiding the process is required. Among
those settings in this study, including the USA Medicare program
and the Maryland all-payer system, national governments have
played active roles in price setting and price regulation to reach
policy objectives. Across many settings, the price and fee
structures are centrally determined (i.e., France, Japan, the
Republic of Korea, and Australian specialists working privately).
In countries such as Germany, fees can additionally be tailored
to state specificities reflecting the country’s federal structure.
8.7
Establishing systems of ongoing revision,
monitoring and evaluation
Payment systems and price levels are being continuously
revised, particularly because there are many factors driving
prices that are not under control of health care providers such
as input costs. When a new technology is introduced,
evaluations are required to compare its impact with existing
technology. In addition, the total fiscal resources for health
continually change. At the same time, health care providers and
other stakeholders quickly adapt to the incentives (and
disincentives) inherent in each payment mechanism and try to
“game” the system to their benefit.
Flexibility is needed to respond to the evolution of pricing and

payment methods, to identify changes in the market structure
and factors outside of the control of providers, and to adapt to
unintended changes in provider behaviour so that the system
can function as intended. In many settings, systems of
monitoring enable adjustments in response to unintended
consequences or negative incentives. Ongoing reviews can
inform about whether the pricing and payment systems are on
track towards the larger system goals of financial protection,
efficiency, coverage, and quality. Reviews at specific regular
intervals may be better than waiting for a problem to arise.
Given the potential impact on provider behaviours, it is

important to maximize the use of pricing policies to attain
better outcomes. There are many experiments underway to link
pricing and payment systems to quality of care through
bundled payments and value-based purchasing, for example.
Price adjustments and payment reform need to be monitored
and evaluated to dynamically adjust the price level to induce
desirable health care provider behaviours. In addition,
unintended consequences can result. More research is needed,
for example, about the impact of the different methods of price
setting and regulation on quality of care. Systematic testing and
evaluation is critical to inform about the impact of payment
systems on behaviours and determine the feasibility of scale-
up within a given setting and replicability elsewhere.
In conclusion, policies about pricing and purchasing health care

services attempt to overcome the imperfections of health care
markets. They are grounded in each country’s institutional
history, and level of resources dedicated to health. In each
setting, approaches have been implemented that help address
the broader system objectives – whether to promote better
coverage, quality, financial protection, and health outcomes.
Ultimately, it is these objectives that guide policy choices.

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Health Coverage
Case studies
lessons for advancing Universal Health Coverage
Sarah L Barber, Luca Lorenzoni, Paul Ong
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Case studies
Australia
England
France
Germany
Japan
Malaysia
Republic of Korea
Thailand
United States of America
Lessons for advancing Universal Health Coverage
Australia 1
Jane Hall, Maryam Naghsh Nejad, Kees Van Gool
and Michael Woods
England 31
Sue Nowak and Alberto Marino
France55
Germany89
Contents Japan133
Naoki Ikegami
Malaysia165
Chiu Wan Ng
Republic of Korea 197

Soonman Kwon
Thailand219
Viroj Tangcharoensathien, Walaiporn Patcharanarumol,
Taweesri Greetong, Waraporn Suwanwela,
Nantawan Kesthom, Shaheda Viriyathorn,
Nattadhanai Rajatanavin, Woranan Witthayapipopsakul
United States of America and Maryland 255

Luca Lorenzoni
iv Price setting and price regulation in health care

Case study
Australia
Jane Hall, Maryam Naghsh Nejad, Kees Van Gool
and Michael Woods
University of Technology
Sydney, Australia
1
Australia
Abbreviations 3
Abstract 4
Background 5
1 Hospital care 9
Public hospital pricing 10

Pricing for private hospitals 12
2 Primary care 13
New Medicare items to target high-need

populations and incentivize quality of care 15
Contents Price-based incentives for access to care 16
Health care homes bundled payment 16
3 Outpatient care 17
Outpatient services covered by the

Medicare Benefits Schedule 17
Privately provided allied health services 20
Hospital-based outpatient departments 20
4 Residential/long-term care 22
Context and objectives 22

Funding arrangements 23
Care funding 24
Care fee 24
5 The market price of accommodation

and additional and extra services 25
The price of accommodation 25

Fees for additional and extra services 25
6 Instruments and institutions 26
Fees and Payments Principles and

Schedules of Fees and Charges 26
Aged Care Financing Instrument 26
Aged Care Pricing Commissioner 27
Aged Care Financing Authority 27
References 28

Abbreviation Term
ABF Activity Based Funding
ACFA Aged Care Financing Authority
ACFI Aged Care Financing Instrument
AIHW Australian Institute of Health and Welfare
AMA Australian Medical Association
CPI Consumer Price Index
DRG Diagnosis Related Groups
GP General Practitioners
Abbreviations HCH Health Care Homes
HTA Health Technology Assessment
IHPA Independent Hospital Pricing Authority
MBS Medicare Benefits Schedule
MSAC Medical Services Advisory Committee
NWAU National Weighted Activity Unit
PBS Pharmaceutical Benefits Scheme
WASE Weighted Ambulatory Service Event

The Australian health system consists of a mix of public and
private service providers. Health is a shared responsibility
between the various levels of government across the eight
state and territory governments and the federal government.
The actual responsibilities that fall on each level of government
are largely historical, and, in some cases, are enshrined in the
Constitution of the federal government and serve to limit
government functions. The actual responsibilities that fall on
each level of government were determined by the Australian
Federation in 1901, with health care left to the states (and
private interests) apart from a national quarantine service. The
federal government gradually acquired greater responsibilities
over time, particularly with the power to raise income taxes
(during World War II) and to provide pharmaceutical, sickness
and hospital benefits and medical and dental services
(Constitution Alteration, 1946). This allowed the establishment
of federally funded pharmaceutical benefits and medical
Abstract benefits and federal grants to states to support public hospitals

due, in large part, to this history and ongoing constitutional
limitations. Thus, a myriad of ways has developed in which
health care is funded. Each part of the health system therefore
has its own set of funding rules, including the determination of
pricing.
In this case study, we examine a range of Australian

experiences in the determination of health care prices, from a
system that is heavily influenced by market factors to one that
is highly regulated and based on a cost-input approach. We
discuss arrangements in four different sectors comprising
hospitals, primary care, outpatient care and aged care,
recognising that arrangements vary across (and even within)
these sectors. In each instance, we describe the price setting
arrangements as they currently stand, with a focus on recent
developments.

Background
Australia’s universal health insurance arrangements have been
designed and implemented within the context of Australia’s
constitution. Funding is provided by all levels of government,
health insurers, and non-government organisations and by
individuals. Medicare (or Medibank as it was originally known)
was introduced in 1974, dismantled between 1976 and 1983,
and re-introduced in 1984.
About 70%1 of total healthcare expenditure is funded by

government. Of this, the federal government (also referred to as
Commonwealth) funds two thirds, and the state, territory and
local governments contribute the other one third. These
proportions have been fairly steady over the last decade
(Figure 1).
Figure 1
Source of funding as share of total health expenditures
2006–07
2007–08
2008–09
2009–10
2010–11
2011–12
2012–13
2013–14
2014–15
2015–16
2016–17
0 20 40 60 80 100
Australian Government Individuals

State/territory and local Other(a)
Health Insurance funds
Includes funding by injury compensation insurers and other private

(a)
funding. All non-government sector capital expenditure is also included

here, as the funding sources of non-government capital expenditure are
not known. If funding sources were known, this capital expenditure would
be spread across all funding columns.
Source: AIHW, 2018.
The federal government’s contributions are mainly through

national health subsidies comprising:
__ Medicare Benefit Scheme (also known as Medicare):
subsidizes the cost of a wide range of health services
provided out of hospital and for private inpatients.
__ Pharmaceutical Benefits Scheme (PBS): subsidizes payments
for a large proportion of prescription medicines bought from
community pharmacies.
1 In 2016-2017, this number was 68.7% (AIHW, 2018). The other 31.3% of total health
care expenditure in those years was funded by individuals, private health insurers, and
non-government organizations.

__ Through the 2011 National Health Reform Agreements
between the federal government and governments for each
State and Territory: the federal government contributes to
the cost of public hospitals based on activity and efficient
prices.
In addition to the above schemes, the Australian government

also provides funding for health care through social welfare
arrangements, regional and remote health care programs,
funding programs for chronic and complex conditions,
indigenous health, and health care arrangements for Australian
Defence, veterans and support of clinical education and
training. Figures 2 and 3 show the percentages of total health
expenditure by area across different funding sources in the
year 2016-17.
Figure 2
Total health expenditure percentages by funding source across
areas of expenditure (%), 2016-2017
Areas of Federal State/ Total Private Individual Other Total non- Total health
expenditure local government health government expenditures
funds expenditures
Hospitals 0.343 0.67 0.461 0.57 0.109 0.534 0.298 0.411
Public hospital 0.292 0.646 0.42 0.076 0.049 0.328 0.088 0.319
services
Private hospitals 0.051 0.023 0.041 0.494 0.06 0.206 0.21 0.093
Primary health care 0.369 0.223 0.316 0.176 0.678 0.364 0.488 0.369
Unreferred services 0.137 0.087 0.026 0.22 0.039 0.073
Dental services 0.02 0.02 0.02 0.12 0.196 0.008 0.152 0.06
Other practitioners 0.029 0 0.018 0.053 0.078 0.063 0.069 0.034
Community health 0.014 0.172 0.071 0.008 0.037 0.009 0.052

and other
Public health 0.017 0.031 0.022 0.001 0.026 0.003 0.016
Benefit-paid 0.143 0.092 0.047 0.027 0.072

pharmaceuticals
All medications 0.009 0.006 0.003 0.322 0.011 0.189 0.062
Referred services 0.185 0.118 0.104 0.102 0.091 0.11
Other services 0.046 0.087 0.061 0.15 0.111 0.039 0.115 0.077
Patient transport 0.004 0.066 0.027 0.014 0.014 0.017 0.015 0.023
services
Aids and appliances 0.011 0.007 0.044 0.096 0.022 0.072 0.027
Administration 0.03 0.021 0.027 0.093 0.001 0 0.029 0.027
Research 0.058 0.02 0.044 .. 0 0.063 0.007 0.033
Total recurrent 1 1 1 1 1 1 1 1
expenditure
Source: AIHW, 2018. Note: Each column shows the share of each health
expenditure item as a total of each funding source expenditure.

Figure 3
Total health expenditure percentages by areas of expenditure
across funding sources (%), 2016-2017
Areas of Federal State/ Total Private Individual Other Total non- Total health
expenditure local government health government expenditures
funds expenditures
Hospitals 0.369 0.409 0.778 0.131 0.047 0.044 0.222 1
Public hospital 0.406 0.51 0.916 0.023 0.027 0.035 0.084 1

services
Private hospitals 0.244 0.063 0.307 0.503 0.115 0.075 0.693 1
Primary health care 0.444 0.152 0.595 0.045 0.326 0.033 0.405 1
Unreferred services 0.835 0.835 0.063 0.102 0.165 1
Dental services 0.149 0.082 0.232 0.187 0.577 0.004 0.768 1
Other practitioners 0.378 0.001 0.378 0.148 0.41 0.063 0.622 1
Community health 0.116 0.832 0.949 0 0.027 0.024 0.051 1

and other
Public health 0.468 0.47 0.938 0.007 0.054 0.062 1
Benefit-paid 0.884 0.884 0.116 0.116 1

pharmaceuticals
All medications 0.064 0.064 0.004 0.926 0.006 0.936 1
Referred services 0.746 0.746 0.089 0.165 0.254 1
Other services 0.26 0.284 0.544 0.183 0.255 0.017 0.456 1
Patient transport 0.079 0.726 0.805 0.058 0.111 0.025 0.195 1

services
Aids and appliances 0.187 0.187 0.153 0.633 0.027 0.813 1
Administration 0.484 0.193 0.677 0.318 0.005 0 0.323 1
Research 0.781 0.154 0.935 0.001 0.065 0.065 1
Total recurrent 0.443 0.251 0.694 0.094 0.177 0.034 0.306 1

expenditure
Source: AIHW, 2018. Note: Each column shows the share of health
expenditure item as a total of each funding source expenditure.

Figure 4 shows the increase in the health price index as a unit
from 2006 to 2017. The total health price index was developed
by the Australian Institute of Health and Welfare (AIHW) and is
derived as annual ratios of the estimated total national health
expenditure at current prices to the estimated total national
health expenditure at constant prices. It shows that among
expenditures, the wage rates for health professionals had the
highest increase during this period.
Figure 4
Health price index
140
130
120
110
100
2006–07 2007–08 2008–09 2009–10 2010–11 2011–12 2012–13 2013–14 2014–15 2015–16 2016–17
GDP IPD Medicare medical services fees charged(b)
Government final consumption expenditure

Professional health workers wage rates
on hospitals and nursing homes
Dental services(a) Total health price index(a)
(a)
implicit price deflator (IPD): An index obtained using the ratio of current
price expenditure to constant price expenditure, constructed by the AIHW.
(b)
Chain price index, constructed by the AIHW.
Source: Authors using data from AIHW, 2018. Note: The implicit price
deflator (IPD) is an index obtained using the ratio of the current price
expenditure to the constant price expenditure. (a) IPD constructed by the
AIHW. (b) Chain price index constructed by the AIHW.
Governments have been concerned about growing health care

expenditure and the impacts on their budgets. The main
pressures are considered to be expensive technologies,
population expectations, and an ageing population with a
growing burden of chronic disease. Although health sector
inflation has outstripped general price rises, there has been no
explicit objective around price control. However, policy aimed
at hospital pricing and medical fees (as explained below) is
evidence of some objectives to restrain price increases.

1
Hospital care
The funding of Australian hospitals reflects both the intricacies
of Federal-State financial relationships and the interplay of
public and private interests. State governments own and
operate public hospitals but are reliant on financial transfers
from the federal government, which has greater tax raising
powers. Until 2011, specific bilateral agreements for public
hospital funding (most recently termed Australian Health Care
Agreements) were negotiated on a five-year basis since the
1940s. The introduction of Medicare in 1984 gave every
Australian the right to treatment in a public hospital free of
charge. This required a higher level of financial compensation
from the Federal government, which has been around 50% of
total public hospital expenditure (Deeble, 2008). However, this
share was not fixed and was influenced by the timing of
elections and the cycle of the Australian Health Care
Agreements, reaching a low of 38% in 2007. This funding was
provided to State treasuries, which then determined how to
channel it to hospitals and other services. Increasing budgetary
pressures for all governments, increasing hospital costs and
growing demands, and public concern about their access to
public hospital care provided the perfect environment for each
level of government to blame the other for not providing
sufficient funds and ineffective management.
The National Health Reform Agreement of 2011 introduced a

basis for shared hospital funding (NHRA, 2011). The new
arrangements provided increased federal government funding
determined by the growth in public hospital activity and
hospital costs. Activity was measured by DRG (Diagnosis
Related Groups) weights. Hospital costs were set by
determining a national efficient price. Federal government
funding was paid directly to local hospital networks comprised
of regionally based groups of hospitals. States and territories
were designated the system managers with responsibility for
managing volume growth, and their treasuries provided the
balance of funds, a relationship that was expected to ensure a
constraint on volume growth.
The NHRA initiated the establishment of a national Activity

Based Funding (ABF) for the public hospital sector. Australia has
had a long collected national case-mix data on activity and
costs. These data included Australia’s own version of DRG
(Australian Refined-DRGs). The state of Victoria was the first
jurisdiction in the world to introduce case-mix funding
(Duckett, 1995). Over time, most but not all states and
territories had moved to this form of funding in whole or in
part. Although the introduction of a national ABF represented a
significant change, there was already considerable
infrastructure in place around case-mix classification, activity
measurement, and costing.

Public hospital pricing
The 2011 Agreement established a new body, the Independent

Hospital Pricing Authority (IHPA), to determine the national
efficient price for public hospital services (IHPA, 2018a). IHPA
has a responsibility for the ongoing development of the
component parts required by ABF: a classification system
(AR-DRGs; and for sub-acute and non-acute services, the
Australian National Subacute and Non-Acute Patient
classification), data collection on activity (the National Hospital
Data Collection) and calculating costs (with a standard
framework for costing activities; the Australian Hospital Patient
Costing Standards). Expenditure is split across five types of
services: admitted acute, emergency, non-admitted, sub-acute
and non-acute, and ‘other’.2 For the financial year 2017-2018,
IHPA total expenses were $A 17.9 million, and IHPA employed
42 staff at year’s end (IHPA, 2018e).
The National Efficient Price is based on the average cost of an

admission (IHPA 2017; IHPA 2018d). IHPA faced the challenge
of determining what would represent the efficient price in the
absence of any discussion of how this should be defined in the
NHRA. Initial analyses showed wide variation in the cost per
case across hospitals. ABF was intended to drive efficiency
through pricing, but at the same time provide stability and
certainty in the federal funding contributions. IHPA determined
to adopt average pricing initially, as this would not remove
funding from the hospital system while still providing a robust
incentive to reduce costs. Case mix is adjusted by the National
Weighted Activity Unit (NWAU), with more complex cases
having a NWAU of greater than one. NWAUs are a common
metric across admitted, sub-acute, emergency and outpatient
services. Prices are also adjusted “to reflect legitimate and
unavoidable variations in the cost of delivering health services”
(NHRA, 2011), including indigeneity, the remoteness of
patients’ residential area, and the remoteness of the treating
hospital. Prices are updated annually.
There are some other adjustments to ensure the

Commonwealth does not pay twice for the same services.
Where the federal government makes direct payments under
special programs (i.e., highly specialized drugs, supply of blood,
etc.), these payments are deducted from the calculation of the
National Efficient Price. Public hospitals can also treat privately
insured patients who can use their private insurance or pay for
their own stay. In this case, private insurers and the federal
government (through the reimbursement of fees for private
medical practitioners) make payments to hospitals, and the
National Efficient Price is adjusted to allow for this (IHPA, 2017).
Adjustments are made for outliers, with long-stays receiving a
per diem rate. This latter adjustment is intended to reduce the
revenue (and hence the incentive) for long stay patients, while
recognising that some long stay outliers are inevitable.
2 SNAP is applied to admissions for rehabilitation care, palliative care, geriatric evaluation
and management, or maintenance care.

Australian geography is such that there are a number
(approximately 400) of small hospitals serving small and often
rural or remote population groups where ABF is not viable. IHPA
determines a National Efficient Cost based on size, location,
and type of services. A National Efficient Cost is also
determined for services which are not yet able to be described
in terms of activity. For these services, block funding amounts
are directed to states and territories to allocate to the hospitals.
Consultation and stakeholder feedback is an integral part of the

price setting process. IHPA works with a Jurisdictional Advisory
Committee and a Clinical Advisory Committee in developing its
systems and analysing the data. Its pricing framework
establishes various principles, including transparency, and the
framework itself is reviewed annually in consultation with the
federal government, states and territories, along with a period
of public consultation. Its work is published on the IHPA
website. This includes full details of pricing frameworks and the
list of prices.
One important provision of the National Health Reform

Agreement is that, where changes are made to the classification
systems or costing methods, these should not result in
unwarranted payments (either due to apparently more or less
activity). IHPA has developed a back-casting policy for the
purpose of calculating federal government funding,
remembering that this contribution is based on a share of
growth in both prices and activity (IHPA, 2018b). The National
Hospital Cost Data Collection is independently reviewed to
assess quality (IHPA, 2018c). Because states and territories and
the federal government scrutinize IHPA’s determinations, there
is considerable scope for review.
There have been several developments over time, reflecting

improved data collection, changes in practice, and new
technologies. From June 2017, pricing was required not just to
recognize efficiency, but also to address safety and quality.
IHPA worked with another independent body, the Australian
Commission on Health Care Safety and Quality, to develop its
approach. Hospital admissions that include a sentinel event
(never events) attract no payment. Hospital-acquired
complications attract a lower payment, which is risk adjusted
for patient characteristics. Avoidable hospital admissions have
been investigated, but as yet are not included in pricing or
funding (IHPA, 2017).
Finally, IHPA has a responsibility in price determination. The

actual payment of monies is the province of the National
Funding Administrator, who recommends payments to the
Treasurer after reconciliation of the activity data.

Pricing for private hospitals
Private hospital charges cover accommodation and facility fees

(such as operating theatres, intensive care, etc.), and other costs
such as prostheses. The federal government sets minimum
prices, for which private insurers must pay. Many of these
prices were significantly reduced in early 2018 following a
review but are still significantly higher than prices paid in the
public sector or compared to international best practice.
Medical fees, including imaging and pathology, are generally
billed directly by the professional providers under private
practice arrangements. This means that a private patient can
receive a series of accounts related to one hospital stay, for
which private insurance does not reimburse the full amount.
This was the cause of widespread consumer dissatisfaction.
Simplified billing arrangements mean that the hospital provides
one account for an admission, though this does not necessarily
include medical fees. It is not clear how widespread simplified
billing arrangements are. There is no evidence that simplified
billing arrangements have been accompanied by better co-
ordination of care, and it is unlikely this would be the case,
given that these arrangements were financial administrative
arrangements only.
Private hospitals principally treat private patients covered by

private health insurance; a small group of patients choose to
pay themselves, with others covered as veterans or as
claimants under workers compensation or motor vehicle
accident insurance. Private health insurers negotiate directly
with hospitals on accommodation and facility fees, with each
fund separately reaching agreements with each insurer. The
federal government sets the default benefit payable for
accommodation in the absence of an agreement.
There is also National Cost Data Collection for private hospitals

undertaken by IHPA. Participation is voluntary (91 from a total
of 630 private hospitals in Australia in 2015-16, representing
60% of overnight admissions) for the purpose of reporting a
range of hospital costs and activity data. No comparisons have
been made with public hospital performance. Private hospitals
are also required to submit data to the federal government
Department of Health (DOH) for each admission on the DRG
case type, benefits paid and charges, length of stay and
demographic data. The AIHW publishes data on private hospital
activity and expenditure (AIHW, 2014).

2
Primary care
Primary care services in Australia have historically been
provided by general practitioners (GPs). GP practices are, by
and large, privately owned but are publicly funded through the
Medicare Benefits Schedule (MBS) and, to a lesser extent,
copayments paid by patients directly.
Although health care is a shared responsibility between the

various levels of government, the MBS is funded solely by the
federal level of government. Ever since the 1946 constitutional
referendum, the federal parliament has powers to make laws
with respect to a range of social benefits, including medical
services but not so as to authorize any form of civil
conscription.
In the context of price setting, the ‘civil conscription’

prohibition has important implications on the government’s
ability to exert price controls. For example, former High Court
Justice Michael Kirby stated that “any form of civil conscription”
acts as a guarantee against any federal intrusion into what was
in effect the small business option for the provision of medical
services in Australia. The test for attracting the prohibition is
whether regulation intrudes into the private consensual
arrangements between the providers of medical services and
the individual recipients of such services. The most obvious
intrusion would occur if an attempt was made to nationalize
the healthcare professions or to force their members into
full-time or part-time work for the federal government or its
agencies (Faunce, 2009).
The MBS funds primary care for all Australian citizens and
permanent residents. Under this scheme, patients are entitled
to a rebate for treatment from eligible providers who have been
issued a Medicare provider number. In the case of primary care,
providers are usually medical practitioners as well as nurse
practitioners working directly under the supervision of a
general practitioner.
GPs are paid on a fee-for-service basis, with patients receiving

a rebate that is equivalent to 100% of the MBS fee.3 The MBS
fee is determined by the Federal government. When the MBS
list was first introduced, the fees were based on the Australian
Medical Association’s (AMA) indicative list of “most common
fees” charged. At that time, the AMA’s fees reflected a market-
based price based on a practice costs and patient’s willingness
to pay.
3 Since 2004, Australians have also been eligible to receive benefits under the Extended
Medicare Safety Net (EMSN). This program exists for those families who have incurred
very high out-of- pocket costs during a year for out-of-hospital services. Once a family
qualifies, they are eligible to receive an amount that is higher than 100% the MBS fee.
Approximately 5% of the Australian population qualifies for the EMSN each year. Whilst
primary care consultations are covered by the EMSN, the majority of benefits (90%) are
actually directed towards specialists’ services. Further details of the EMSN and its effect
on prices will be provided in the outpatient’s specialist section of the Australian case
study.

Since the introduction of Medicare, MBS fees for primary care
consultations have routinely been indexed based on a
discounted version of the wage-price index and the consumer
price index. As part of various austerity measures, the federal
government froze MBS indexation arrangements in 1996-97
and also between 2013 and 2018 (Parliament of Australia,
2019). This method of indexation has led the AMA to argue that
the growth in MBS fees is far behind the rising cost of medical
practice. The AMA reports that between 1985 and 2015, MBS
fees increased by 80%, whereas practice costs (defined by CPI
and wage indexes) increased by 220% over the corresponding
period.
It should be noted that doctors, including GPs, are not bound

by the MBS fee. Doctors have the freedom to charge any fee to
any patient at any time. However, any GP fee that is higher than
the MBS fee creates a gap that the patient must pay. No
supplementary private health insurance is available for out-of-
hospital services that are covered by Medicare.
The MBS rebate acts as a floor price for doctor fees. If the
doctor charges a fee that is equal to the MBS rebate, the patient
faces a copayment amount of zero. From the doctor’s
perspective, there is no financial reason to charge less than the
rebate. If they were to do so, the patient copayment would still
be zero, and hence would not affect demand for their service.
However, it would reduce their revenue. Although doctors have
complete discretion over their fees, it turns out that in most
cases, the fees charged by GPs are, in fact, equal to the MBS
fee. This practice is commonly known as ‘bulk-billing’. In 2017-
2018, 86% of all primary care consultations were bulk- billed,
indicating that in all these instances, the MBS fee acts as an
effective floor price and the patient incurs no out-of-pocket-
cost for the consultation.
For the remaining 14% of primary care services, the average

gap between the doctor’s fee and the MBS rebate is just over
$A 37 (DOH, 2018). This indicates that, on average, for those
consultations that are not bulk-billed, the GP fee is $A 37
higher than the MBS fee. For reference, the most commonly
claimed GP MBS item has an MBS fee of $A 37.60.4 This implies
that for the 14% of non-bulk-billed services, the average GP
price is $A 74.60 for a standard consultation.
Due to the extensive use of bulk-billing in primary care, the

government has strong regulatory power over prices through its
control over the MBS fee. It can control a highly effective floor
price. That said, its control is tempered by the GP’s ability to
switch from bulk-billing their services to charging fees above
the MBS fee at any time.
4 Item 23 is described as a professional attendance by a GP at consulting rooms (other than

a service to which another item in the table applies) lasting less than 20 minutes and
including any of the following that are clinically relevant: (a) taking a patient history, (b)
performing a clinical examination, (c) arranging any necessary investigation, (d)
implementing a management plan, and (e) providing appropriate preventive health care
for one or more health-related issue with appropriate documentation for each
attendance.

The aforementioned mechanisms provide an accurate
description of the historical manner by which the federal
government has exercised influence over GP prices. These
mechanisms remain current for the vast bulk of GP
consultations. In addition, the federal government has
introduced a raft of reforms that have some bearing on the
prices paid to GPs. In particular, the government has introduced:
__ new Medicare items to define primary care services.
__ price-based incentives to meet government objectives.
__ staged roll-outs of bundled payments.
The remainder of this section will focus on the mechanisms

used to set prices in primary care under the auspices of the
MBS as well as recent reforms that have the potential to
influence price settings.
New Medicare items to target high-need populations and

incentivize quality of care
Over recent decades, there has been a considerable expansion

of the types of services listed in the MBS that relate to primary
care. Back in 1997, for example, the MBS listed 48 different
items that primarily related to the types of services provided by
GPs. Back then, the most distinguishing features between items
were the length of the consultation and the place of the
consultation (e.g. at the patient’s home, at the doctor’s office, or
nursing home). The June 2018 edition of the MBS counts 148
items relating to primary care. In most instances, these
additional items provide a more in-depth description of the
type of consultation that is required before a claim can be
made against such items. Examples of these new items are:
__ Multidisciplinary case conferencing and care planning for
people with chronic and complex needs
__ Health assessments for people with chronic illnesses or at
risk of developing chronic illnesses such as diabetes
__ Home medication management review in collaboration with
a community pharmacy
__ Out-of-hours consultations
__ Completion of an annual cycle of care for patients with

chronic diseases such as diabetes and asthma
The main difference between these items and those that were
previously listed on the MBS is that new items are more
prescriptive. The new items tend to define the type of medical
services and/or are targeted at particular types of patients
before patients are eligible to make a Medicare claim. For
example, some items can only be claimed by patients of a
certain age or with certain conditions. Items have also been
added that expand the types of professions able to claim
Medicare benefits including nurse practitioners and
psychologists working alongside GPs.

The federal government has, in general, made the MBS fee for
these new items more financially rewarding for GPs than
previous ones. For example, the MBS fee for the health
assessment of a person with a chronic disease is $A 137.90 –
well above the $A 37.60 for a standard consultation.5 Through
the establishment of these new items, the federal government
has created a new set of price signals to direct care towards
specific target populations and also for providing more
comprehensive care. There is no unequivocal evidence that this
has changed the process or improved the quality of care or
patient outcomes. It is clear, however, that larger and better
organized practices are more likely to bill these new items.
Price-based incentives for access to care
Similar to the establishment of new item descriptions, the

federal government has also used price-based incentives to
improve access to care. In 2003, the federal government
introduced financial incentives for GPs to provide greater
access to services through lower copayments for particular
patient groups. These incentives were introduced after a
sustained period of increasing copayments (Wong et al., 2017).
In the six years leading up to this reform, the percentage of
bulk-billed GP services (where patients pay zero copayment)
fell from 84% to 68%.
The new incentives gave metropolitan-residing GPs an extra

$A 5 if they bulk-billed (i.e. charge zero copayments) patients
who hold a concession card (i.e., lower income families and
pensioners) or are 16 years or less. The corresponding incentive
for GPs practicing in rural, remote, and some outer metropolitan
areas was $A 7.50. The reforms were strongly associated with a
rise in bulk-billing, but evidence also showed that price-
discrimination became a stronger feature of the primary care
system. Wong et al. (2017) showed that while concession-card
holders were more likely to face a zero copayment, other types
of patients were more likely to witness an increase in their
copayment. This reflects a change of pricing behaviour on the
part of GPs, where concession card status became a greater
marker of a doctor’s decision to charge lower fees compared to
fees charged to the general population.
Health care homes bundled payment
In 2017, the Australian government commenced the first roll

out of its Health Care Homes (HCH) program. This program
moves away from the traditional fee-for-service model by
providing a capitated payment to general practitioners to care
for the chronic condition needs of complex patients. It is
intended to give practices greater flexibility in the delivery of
services by allowing them to broaden the use of technology
and the roles of the workforce.
5 Medicare item 703 versus item 23.

GP practices and Aboriginal Community Controlled Health
Services are eligible to become HCH. Once they become an
approved HCH, they can enrol patients into the program. Three
tiers of payments are available depending on the patient’s level
of complexity and need. The value of each tier is:
__ Tier 3 — the highest level of patient complexity: $A 1795
per annum
__ Tier 2 — increasing level of patient complexity: $A 1267 per
annum
__ Tier 1 — the lowest level of patient complexity: $A 591 per
annum
The payment values represent an ‘average’ payment based on a

bundle of services that complex patients are expected to use
for the management of the chronic disease and were previously
funded through the MBS. It should be noted that enrolled
patients can still access care outside of their HCH and are also
able to access MBS funded fee-for-service episodes of care not
related to a patient’s chronic conditions. However, the
government expects that for the vast majority of HCH patients,
the number of fee-for-service episodes will be small (DOH,
2017).
3
Outpatient care
Outpatient care in Australia is funded through a myriad of
public and private financial sources. As such, the price setting
arrangements depend very much on the funding source. In this
section, we will cover price setting arrangements for:
__ Outpatient services covered by the MBS
__ Privately provided allied health services
__ Hospital based outpatient departments
Outpatient services covered by the Medicare Benefits

Schedule
Aside from general practice consultations, the MBS covers a

vast range of outpatient services including specialists’
consultations (including psychiatry), pathology services and
diagnostic imaging, some allied health services as well as a
large range of procedures and operations. The funding and
pricing rules are identical to those described in the primary
care sector. However, because the market structures are very
different across these different types of services, the pricing
mechanisms vary accordingly.

The Medicare rebate for most outpatient services is set to 85%
of the MBS fee. There are two exceptions to this rule. The first
exception is primary care items (e.g. GP consultations) which,
since 2005, are reimbursed at 100% of the MBS fee. The
second exception is the Greatest Permissible Gap (GPG) rule.
This rule requires that the difference between the MBS fee for
an item and the 85% Medicare benefit must not be greater
than a specified amount. From 1 November 2018, the GPG has
been set at $A 83.40. For example, if the MBS fee for an item is
$A 1000, then the 85% benefit would be $A 850, which means
that the gap is $A 150. In this case, the GPG would apply and
the patient would receive a Medicare rebate of $A 916.60, not
$A 850. This amount is indexed by the consumer price index
each year. In 2018, the GPG is relevant for any out-of-hospital
Medicare item which has an MBS fee of $A 556.30 or more.
Above, we discussed the role of the Medicare rebate acting as a

floor price for services. In primary care, this is a highly effective
pricing mechanism because 85% of GP consultations adhere to
the Medicare rebate. High rates of floor price adherence can
also be found for pathology services, optometry, practice nurse
consultations and diagnostic imaging. Figure 5 reveals the
percentage of services where the doctor fee is equivalent to
the Medicare rebate. Overall, the fees for 86.4% of all Medicare
claims in the out-of- hospital sector are equivalent to the
Medicare rebate and therefore incur zero copayment. For these
services, the floor price is the effective price. However, this
percentage varies considerably between different types of
health care providers. In the primary care market, this
percentage is influenced by high levels of competition
(particularly in metropolitan areas) and the patient’s ability to
consult any doctor (there is no registration). For specialists’
attendance, on the other hand, the Medicare rebate acts as an
effective floor price for only 41.3% of all services. This implies
that for the remaining 58.7% of services, the doctor’s fee is
higher than the floor price. In fact, as shown in figure 5, the
specialist attendance fee, on average, is $A 79.94 higher than
the floor price. The reason for the higher price often relates to
supply-side market power and the patient’s ability to pay. The
number of specialists are controlled by training places
accredited by specialist colleges. Further, patients require a GP
referral for a specialist attendance so it is not so straightforward
for a patient to find another specialist. There is also a strong
positive association between higher fees and the wealth of the
area in which the specialist practices.
When doctors charge fees that are higher than the Medicare
rebate, the government’s control over pricing is limited.

Figure 5
Medicare claims, fees, benefits and copayments out-of-
hospital (2017-18)
Services Services with Average Average fee Average Average copayment

zero benefit per charged per copayment excluding services
copayment service service with zero copayment
per capita % $A $A $A $A
Total 15.3 86.4 53.33 61.87 8.54 63.47
GP 5.5 84.9 45.54 51.04 5.5 36.5
Practice nurse 0.1 99.6 13.38 13.39 0.02 4.43
Specialist attendants 1 41.3 84.86 131.79 46.94 79.94
Obstetrics 0.1 61 64.82 162.52 97.69 250.27
Pathology 5.2 99.3 20.37 20.43 0.06 24.54
Diagnostic imaging 1 84.3 135.31 150.9 15.59 99.52
Operations 0.3 68.5 107.35 135.93 28.58 90.76
Optometry 0.4 94.3 46.6 48.07 1.48 26.08
Radiotherapy and 0.1 76.1 210.21 223.48 13.26 55.5

nuclear medicine
Allied health 0.5 62.7 74.73 91.95 17.22 46.11
Other 0.4 74.3 160.04 189.1 29.06 112.89
Source: Department of Health, 2018.
As noted in the primary care section, the setting of the rebate

for each MBS item has, by and large, been historical. However,
there are clear processes in place to advise the Minister for
Health about new items proposed to be listed on the MBS. A
formal Health Technology Assessment (HTA) is required on any
proposed new (or amended) service to evaluate the safety,
effectiveness, cost-effectiveness and budget impact. The
Medical Services Advisory Committee (MSAC) considers the
evidence and makes recommendations to list or not to list the
proposed new service to the Minister.
A 2011 Government Discussion Paper articulates the MBS

principles upon which proposals for new items should be made
(DOH, 2011). The paper proposed an improved evidence-based
MBS fee setting process by making explicit the components of
fees for new and revised MBS items. The new process aims to
increase transparency in the resource inputs, measurements
and calculations going into a recommendation for an MBS fee.
In doing so, MBS fees are based according to their time and cost
components, consistent with the broad range of MBS fees for
services offered within a specialty. It is expected that MBS fees
will become more incentive-neutral than is currently the case
so that there are fewer perverse incentives to provide particular
services as well as less cross-subsidisation from one item to
another (DOH, 2011).

It is not entirely clear from public documents how the
discussion paper recommendations have been implemented.
The costing information for many MSAC proposals has been
redacted and is not available to the public (see http://www.
msac.gov.au for details). That said, under the MSAC guidelines
for the proposal of new items, applicants are asked to indicate
the likely cost of providing the proposed medical service,
including any equipment and consumable costs as well as to
specify how long the proposed medical service typically takes
to perform. On the basis of these inputs, applicants are asked
to provide an indicative MBS fee for the proposed service,
which is then included in the cost-effectiveness analysis. This
implies that the MBS fee is based on an input cost basis but
assessed on the basis of value for money through a formal HTA.
While MSAC may give advice on MBS fees, it does not set them.
Once MSAC makes a positive recommendation to list a service
on the MBS, the DOH will consult with stakeholders to finalize
the MBS fee. If the final fee greatly differs from the proposed
fee considered by MSAC, then DOH reserves the right to
redirect the proposed fee back to MSAC for further
consideration.
Privately provided allied health services
Although the MBS covers some allied health services, these can
only be accessed under strict conditions and constrained to a
limited number of allied health professions. For example, the
MBS will cover up to 10 consultations per year with a clinical
psychologist if the patient is referred by a medical practitioner
and has a GP Mental Health Treatment Plan. Coverage of allied
health services by the MBS is a relatively recent addition, and
coverage is by no means complete. Dental and physiotherapy
services, for example, are mostly excluded from the MBS.
Consumers can purchase private health insurance for

outpatient allied health services that are not covered by the
MBS. In general, allied health practitioners set their own fees,
and private health insurance companies will contribute a fixed
amount towards the cost of a service. Services are described in
a similar fashion to the MBS, however, instead of the
government paying a set benefit, the private health insurance
company does. Insurance companies can and do enter into
agreements with some allied health providers that restrict the
prices charged by providers and, as a result, the copayments
faced by patients.
Hospital-based outpatient departments
Public hospitals have traditionally been owned, operated and

funded by the state and territory governments. Prior to the
introduction of Medicare (universal health coverage in 1984),
outpatient services were provided free of charge to patients
meeting a means test. Under Medicare, all Australians are
entitled to the same level of reimbursement for medical
services provided out of hospital, which resulted in a

substantial move of this form of care from hospital campuses to
private consulting rooms funded through the MBS. The extent
to which hospital outpatient clinics declined varied from state
to state.
As noted above, until 2013, the federal government

contributed to the funding of public hospital services through
5-year block grants. Since the National Health Reform
Agreements were signed in 2011, the federal government has
paid state governments on an activity-funded basis.
Funding for public hospitals applies across several service

streams in addition to inpatient activity including emergency,
non-admitted, sub-acute and non-acute, and ‘other’. Sub-acute
and non-acute services are applied to admissions for
rehabilitation care, palliative care, geriatric evaluation and
management, or maintenance care. Under the 2011 Reform
Agreement, the federal government share of funding includes
all hospital emergency services and some non-admitted
services. The current funding agreements cover specialist
clinics which were reported prior to 2011 and non-admitted
services which meet the following criteria: directly related to an
inpatient admission or Emergency Department (ED) attendance,
substitute for an admission or ED attendance, or are expected
to improve the health of people who have a history of frequent
attendance or admission. However, certain services are
excluded, including primary care, family planning, and aged
care assessment (IHPA, 2018a).
Activity and cost data for outpatient services are collected as

part of the national hospital cost collection. At this stage, there
is no non-admitted services classification that is patient
centred and suitable for the Australian setting. Therefore, these
services are categorized by the nature of service and type of
clinician involved.
State governments are still in the process of fully implementing

these reforms, although some states such as Victoria have
provided details of their new funding and pricing model.
In 2017–18, Victoria introduced the Weighted Ambulatory

Service Event (WASE) funding model for acute non-admitted
specialist clinic activity, covering, for example, home renal,
radiotherapy, and home enteral nutrition. The WASE model is
intended to encourage health services to improve their data
reporting, drive technical efficiency, and deliver greater
transparency and accountability for the funding received
(DHS, 2018).
Under the WASE model, activity will be counted as service

events and classified according to the national Tier 2
classification with cost weights calculated based on Victorian
cost data. Tier 2 classifications are published by the IHPA and
categorize a hospital’s non-admitted services based on the
nature of the service provided and the type of clinician
providing the service. The major categories are: procedures,
medical consultation services, diagnostic services, and allied

health and/or clinical nurse specialist intervention services.
Hospitals have been allocated an activity target that matches
their historical non-admitted specialist clinics funding. The
framework has been established to adjust funding when health
services under-achieve their targets. Currently, the WASE model
will not have a direct impact on health service funding in
2018-2019 (DHS, 2018).
4
Residential/long-term care
Context and objectives
The federal government subsidizes the cost of services which

provide non-medical care and support for the elderly
(Australian Government, 2017). The subsidies are given to
consumers (for home care) or providers (for long-term
residential care). Not-for-profit and private for-profit providers
deliver care and are paid the same rates of subsidy. In home
care, there is open competition between authorized providers
(those who meet safety, quality and prudential requirements).
In residential care, there is restricted competition as the
government limits the number of licensed beds in each region
and allocates the licences to authorized providers through
recurring competitive Approval Rounds (Australian Government,
2017).
The aged care programs are undergoing a medium-term agenda

of reform (Australian Government, 2017). The agenda is based
on a report by the Australian Productivity Commission in 2011
titled Caring for Older Australians (Productivity Commission,
2011), together with consultation by the government and
subsequent studies. The first tranche of legislation to enact the
reforms came into effect in July 2014. Despite changes of
national governments, there is bipartisan support, and the
reforms continue within the initial framework.
The objectives for providing public subsidies to support the

delivery of aged care services, including long-term residential
care, are set out in legislation of the federal parliament known
as the Aged Care Act 1997 (as amended). The objectives (in
summary) are to:
__ Provide care recipients (and carers) with access to diverse,
flexible, responsive and affordable high-quality care and
accommodations that achieve appropriate outcomes.
__ Promote ageing in place and encourage independence and
choice.
__ Provide funding based on the quality of care and the type
and level of support delivered.
__ Hold providers accountable for the funding they receive and
outcomes achieved.

__ Consider equity and merit given the limited resources
available.
__ Target services to places and people with the greatest need
and integrate aged care with related health and community
services.
The reforms have adopted a market approach to the delivery of

aged care and therefore prices play an integral part.
__ Care recipients should contribute to the costs of their care
and accommodations according to their income and assets.
They should have choice and control, be the subsidy fund-
holders and ‘purchase’ care from authorized providers
according to quality, quantity, price, and timeliness.
__ Public subsidies must be sustainable over the long term,
particularly given the fiscal impact of the ageing of
Australia’s population (reduced per capita revenue from
taxation as well as increased public expenditure on aged
care and health care, including salary pressure from the
increasing demand for a proportionately declining
workforce).
__ The forces of market competition between providers should
be harnessed to deliver more efficient, effective and higher
quality services that are attuned to the consumers’ needs.
The sector needs to be viable overall, but individual
providers must make their own market judgements and can
fail. The regulation of safety and quality must be rigorous,
and consumer information must be accessible.
__ Funding for an adequate level of approved care is treated
separately from residents paying the market price for
accommodation (with safety nets) and paying for additional
care.
The Aged Care Act 1997 provides the legislative authority for
funding and price setting. The next two sections describe the
relevant funding and fee setting arrangements, and the final
section explains the legal instruments and institutions.
Funding arrangements
There are four main forms of funding for residential aged care:6
__ Paying for basic daily services. This covers day-to-day living
costs such as meals, cleaning, laundry and air-conditioning.
With minor exceptions, all residents are required to pay a
basic daily fee.
__ Care funding. This is the amount received by a provider for
delivering care to the residents according to their needs.
Apart from residents with low income and assets, nearly all
residents make a financial contribution for their care
according to their capacity to pay. The government makes a
balancing subsidy payment.
6 Please refer to https://www.myagedcare.gov.au/aged-care-homes/working-out-the-costs

for more information.

__ Accommodation funding. Providers charge separately for the
cost of the accommodation they offer. Some residents have
their accommodation costs fully funded by the government,
and some others receive a partial subsidy. The remainder
pay the full cost of their accommodation.
__ Paying for additional and extra services. Residents can agree
to pay extra for a higher standard of accommodation or for
additional services.
Care funding
Care funding to the provider
The level of funding to the provider is determined by the

provider assessing the care needs of the residents in
accordance with the Aged Care Financing Instrument (ACFI).
This provider assessment can be subject to independent audit.
The funding comprises a care fee which is paid by residents
whose income and assets are over a certain threshold, together
with a balancing government subsidy.
The ACFI is a regulatory funding instrument, but it is not a

comprehensive clinical assessment of care needs. It consists of
12 sets of questions about assessed care needs, each having
four ratings (A, B, C or D) as well as two diagnostic sections. The
government claims that the ACFI provides sufficient precision
to determine the overall relative care needs profile and the
subsequent funding for each of the residents. Providers pool
the funding received for resident care within each of their
facilities and deliver care to the residents according to
residents’ needs. By way of contrast, recipients of home care
services are allocated individual funding and exercise control
over its expenditure.
Care fee
Residents pay a means-tested care fee as a contribution

towards the cost of care. The amount paid depends on an
assessment of their combined income and assets (set out in
regulation), which is conducted by a government agency and
the cost of their care, as determined by the assessed input
costs of delivering the care needs (ACFI). However, there are
limits in place. For persons of low income and assets, the
government funds providers for the full cost of the resident’s
care. There is a sliding scale to an upper threshold, above which
residents pay a capped maximum fee. Fees are subject to
quarterly reviews. There are annual and lifetime caps in place
to limit the amount of the means-tested care fee that a resident
can be asked to pay.

5
The market price of accommodation and
additional and extra services
The price of accommodation
Aged care homes can, within a wide limit, set the price of their
accommodation in the market. They must publish their
maximum accommodation prices on the government’s My Aged
Care website, their own website (if they have one), and in other
relevant materials they provide to people who are considering
becoming residents. There may be different maximum
accommodation prices for different room types in an aged care
home. The published accommodation prices are the maximum
a provider can charge, but a lower price can be negotiated.
Providers wanting to charge accommodation prices of more

than $A 550 000 as a lump sum (or the rental equivalent) must
have their prices approved by the Aged Care Pricing
Commissioner (an independent statutory office holder
appointed under the Aged Care Act 1997 who reports to the
Minister for Aged Care).
The government fully funds the costs of accommodation for

those on low income and assets and provides a tapering
subsidy for partially supported residents. All other residents
pay the full agreed price of their accommodation.
Residents who must pay a partial contribution or the full price

can choose between making a lump sum, fully-refundable
accommodation payment (at nominal, not real, value) or a
rental-type daily accommodation payment. The daily payment
is set by a regulatory formula to provide the provider a return
that is the equivalent of the refundable lump sum.
The government provides incentives to providers to upgrade

their standard of accommodation and provides financial
disincentives to have less than a minimum proportion of
residents who are fully subsidized.
Fees for additional and extra services
Residents can agree to pay extra for a higher standard of

accommodation or for additional services. The prices and the
services must be published and explained to the residents.
Extra service fees are to be approved by the Aged Care Pricing
Commissioner. Residents cannot be charged additional fees for
other care or services that they do not receive a direct benefit
from or that cannot be used for care. Residents cannot be
charged for additional or extra services that the aged care
home is required to provide by law.

6
Instruments and institutions
Fees and Payments Principles and Schedules of Fees and

Charges
The Aged Care Act 1997 authorized the Minister to make

principles relating to a wide range of issues including provider
accountability, consumer information, quality of care, sanctions,
subsidies, fees and payments. The Fees and Payments
Principles 2014, No. 2, specify the Rules and Approval
Processes. They cover such matters as:
__ Resident fees
__ Accommodation payments and accommodation

contributions
__ Calculation of the equivalence between refundable
accommodation contributions (lump sums) and daily
accommodation contributions (rental payments)
__ Approval of higher maximum accommodation payment
amounts
__ Financial hardship
__ Prudential standards of providers
The DOH publishes up-to-date schedules of fees and charges

for residential aged care (and home care), which have been set
in accordance with the Act and the Principles.7 Each schedule
also specifies the period for which the fees and charges are
current.
Aged Care Financing Instrument
In addition to these short-term measures, the government is

investigating alternative approaches to determining residential
care funding that delivers more stable funding arrangements.
The government is engaging with the residential care sector on
the development of longer-term reform. One of the actions has
been to commission a Resource Utilization and Classification
Study to determine the characteristics of residents that drive
residential care costs.
7 For the most recent schedule, please refer to https://agedcare.health.gov.au/funding/

schedule-of- fees-and-charges-for-residential-and-home-care-from-20-september-2018.

Aged Care Pricing Commissioner
The Aged Care Act 1997 established the position of the Aged
Care Pricing Commissioner. The Commissioner is an
independent statutory office holder appointed under the Act
who reports to the Minister.
The functions of the Commissioner are set out in the Act and
are to consider and approve extra service fees and
accommodation payments that are higher than the maximum
amount of accommodation payment determined by the
Minister.
The functions of the Commissioner increase the level of

transparency in the pricing of the specified residential aged
care services and aim to ensure that aged care recipients are
charged appropriately through approval of these prices.
Aged Care Financing Authority
The Aged Care Financing Authority (ACFA) is a committee of

experts established by legislation and appointed by the
Minister to provide independent advice to the government on
funding and financing issues. The committee is informed by
consultation with consumers and the aged care and finance
sectors.8 ACFA publishes research that it has commissioned as
well as an annual report titled “Funding and Financing of the
Aged Care Sector”. The report examines developments, issues
and challenges affecting the sector, and provides a range of
statistics and analyses of the provision of aged care in Australia.
ACFA has no price setting or other regulatory responsibilities.
8 More information is available at https://agedcare.health.gov.au/aged-care-reform/

aged-care- financing-authority.

Australian Government. Aged Care Act 1997. Federal Register of
Legislation. Health; 2017. (https://www.legislation.gov.au/
Details/C2017C00241, Accessed 14 March 2019).
Australian Institute of Health and Welfare (AIHW). Australian

hospital statistics 2012-13: private hospitals. AIHW; 2014.
Australian Institute of Health and Welfare. Health expenditure

Australia 2016-17. Health and welfare expenditure series.
Canberra 2018;64:HWE74.
Constitution Alteration (Social Services); 1946. (https://www.

legislation.gov.au/Details/C1946A00081, Accessed 14 March
2019).
Council of Australian Governments. National Health Reform

Agreement 2011; 2011. (https://www.publichospitalfunding.
gov.au/national-health-reform/agreement, Accessed 14 March
2019).
References Deeble JS. Medicare: where have we been? Where are we
going? Australian and New Zealand Journal of Public Health
2008;23:1-7.
Duckett SJ. Hospital payment arrangements to encourage

efficiency: the case of Victoria, Australia. Health Policy
1995;34:113-34.
Department of Human Services (DHS). Department of Health

and Human Services policy and funding guidelines 2018
Volume 2: Health operations 2018–19. DHS; 2018. (https://
www2.health.vic.gov.au/about/policy- and-funding-guidelines,
Department of Health (DOH) Development of a quality

framework for the Medicare Benefits Schedule. DOH; 2011.
(http://apo.org.au/system/files/21205/apo-nid21205-43271.
pdf, Accessed 14 March 2019).
Department of Health (DOH). Health Care Homes: factsheet:

payment information. DOH; 2017. (https://www.health.gov.au/
internet/main/publishing.nsf/Content/health-care-homes-
cp/$File/payment-information-factsheet-letterhead.pdf,
Department of Health (DOH). Annual Medicare Statistics. DOH;

2018. (https://www.health.gov.au/internet/main/publishing.
nsf/Content/Medicare+Statistics-1, Accessed 14 March 2019).
Faunce T. Constitutional limits on federal legislation practically

compelling medical employment: Wong v Commonwealth;
Selim v Professional Services Review Committee. Journal of Law
and Medicine 2009;17(2):196-205.
Independent Hospital Pricing Authority (IHPA). Pricing

Framework for Australian Public Hospital Services 2018-19.
IHPA; 2017. (https://www.ihpa.gov.au, Accessed 14 March
2019).

Independent Hospital Pricing Authority (IHPA). Annual Review
of the General List of In-Scope Public Hospital Services; 2018a.
(https://www.ihpa.gov.au, Accessed 14 March 2019).
Independent Hospital Pricing Authority (IHPA). Back-casting

Policy; 2018b. (https://www.ihpa.gov.au, Accessed 14 March
2019).
Independent Hospital Pricing Authority (IHPA). National

Hospital Cost Data Collection, Independent Financial Review,
Round 20 (Financial Year 2015-16); 2018c. (https://www.ihpa.
gov.au, Accessed 14 March 2019).
Independent Hospital Pricing Authority (IHPA). National

Efficient Price Determination 2018-19; 2018d. (https://www.
ihpa.gov.au, Accessed 14 March 2019).
Independent Hospital Pricing Authority (IHPA). Annual Report

2017-18; 2018e. (https://www.ihpa.gov.au, Accessed 14 March
2019).
National Health Reform Agreement (NHRA). Council of

Australian Governments; 2011. (http://www.
federalfinancialrelations.gov.au/content/npa/health/_archive/
national-agreement.pdf, Accessed 14 March 2019).
Parliament of Australia. Medicare. 2019. (https://www.aph.gov.

au/About_Parliament/Parliamentary_Departments/
Parliamentary_Library/pubs/rp/BudgetReview201718/,
Accessed 2 May, 2019)
MedicareProductivity Commission. Caring for Older Australians.

Final Inquiry Report No. 53. Canberra; 2011.
Wong CY, Greene J, Dolja-Gore X, van Gool K. The Rise and Fall
in Out-of-Pocket Costs in Australia: An Analysis of the
Strengthening Medicare Reforms. Health Economics
2017;26(8):962-979.
Barber SL, Lorenzoni L, Ong P, editors. Price setting and price

regulation in health care: lessons for advancing Universal
Health Coverage. Case Studies. Geneva: World Health
Organization, Organisation for Economic Co-operation and
Development; 2019.

Case study
England
Sue Nowak
National Health Service, England
Alberto Marino
Organisation for Economic Co-operation and
Development, France
31
England
Abstract 33
1 The National Health Service: payment

mechanisms, budgets, and commissioning 34
Funding flows in the NHS: budgets

and commissioning shifts 35
2 Price setting across NHS services 40
Primary care 40
Acute services 42
Community and mental health 46
Contents Nursing and care home funding 47
3 Discussion 48
The current NHS is evolving to adapt its

payment system to its stated objectives 48
Policy lessons across services 49
System objectives and other policy levers 50
References 52

The current English National Health Service payment system
has evolved greatly over the last decade and employs a mix of
different payment methods across different services and
sectors. The predominance of activity-based payment in the
acute sector, introduced at a time of long waiting lists,
encouraged activity in hospitals. At the same time, block
budgets in community services and capitated budgets in
primary care offer little incentive to increase activity or
enhance efficiency in these settings.
New payment models are being developed and tested in local

areas. As an example, a version of capitation-based payment
known as ‘whole-population budgets’ has recently been
suggested to support new models of care delivery. However,
improved arrangements for ongoing evaluation of these new
payment systems and spreading of best practice must be
developed.
Abstract Two key messages are reflected throughout the report:
First, that there is no such thing as an “ideal” payment

mechanism (or combination thereof) per se, but that each
approach has defined (and often empirically sound) advantages
and disadvantages that can help policy-makers reach defined
objectives. These objectives should be the guiding light that
defines how prices are set in a health system, with key
emphasis on making clear which objectives should be
prioritized. Trade-offs are commonplace in the mechanics of
incentive structures. However, if there are too many objectives,
and priorities are not set, the effectiveness of a specific
combination of price-setting mechanisms is muddled.
Second, that price setting is just one of many policy tools

available to help reach key policy objectives. There are far too
many actors at different levels of the system for the price-
setting mechanism to be able to significantly incentivize every
single one of them. One of the key arguments is that price
setting and regulation could provide incentives to hospitals but
may not have as much of an effect on individual practitioners,
who may be less likely to modify their practice in the intended
ways.

1
The National Health Service: payment
mechanisms, budgets, and commissioning
Payment mechanisms in the National Health Service are
blended across and within types of services, with the aim to
optimize incentives and minimize the disadvantages of each
mechanism
The National Health Service has a long history of change aimed

at continuous improvement. Established in 1948 with the core
idea that good quality health care should be available to all
regardless of their income, it was one of the key drivers for
shifting expectations (both nationally and internationally) on
health care as a good – from a standard economic good to a
much more complex public good that seeks to reduce
inequalities. The complexity of health care as a non-standard
good has been the subject of extensive research efforts and
constitutes one of the main reasons why provider payment
systems have evolved so rapidly, especially in the last decade.
In the United Kingdom health is run separately in England,
Wales, Scotland and Northern Ireland. This report only covers
payment mechanisms for the National Health Service in
England (henceforth referred to as the NHS), although the
founding principle of free universal healthcare applies across
the United Kingdom.
The NHS employs a range of payment mechanisms across its

core services – primary care, acute care, community and mental
health services. Each mechanism comes with advantages and
disadvantages, with the optimal mix dependent on the priorities
of the system. It is therefore common to not only adopt different
mechanisms for different services (since objectives and
incentives in each service might differ), but also to blend
different payment practices within a specific service to mitigate
some of the drawbacks of the main payment system in place.
The NHS incorporates block budgets, capitation, and activity- or

case-based models (Wright et al., 2017). These mechanisms can
be described primarily based on the extent to which they
bundle payments for services:
__ Block contracts bundle payments for all services provided in
the sector, with a lump sum paid to providers at a specified
interval (much like a salary), and may be independent of the
level of activity;
__ Capitated budgets bundle payments prospectively per
patient enrolled in the system, often with a risk-adjustment
weighting for more complex patients;
__ Case-based payments made prospectively for an episode of
care, which therefore involve less bundling than capitated
payments since they do not involve periods where there
may or may not be activity for any given patient (Marshall,
Charlesworth and Hurst, 2014).

The NHS currently uses capitation as the main form of payment
for primary care, block contracts for the community and mental
health sectors, and case-based payments for the acute sector.
The following sections detail how each of these three services
has evolved in the past decade with regard to its objectives,
funding and payment system, together with a general overview
of the NHS as a whole and future integration plans encouraging
the use of global budgets as set out in the “Five Year Forward
View” (2015) and reinforced in the “Long Term Plan” (NHS
England, 2019).
Funding flows in the NHS: budgets and commissioning shifts
With a broadly static health budget in real terms over the five
years leading to 2015-2016, the NHS was asked to make
efficiency savings of 4% per year over this period, equating to
a total of £15-20 billion. A key tool for incentivising higher
efficiency has been the payment system through which NHS
commissioning bodies purchase health care from hospitals,
general practitioners (GPs) and other providers (King’s Fund,
2017a).
The NHS is primarily funded through general taxation and

National Insurance contributions from employees, employers
and the self-employed. General taxation accounts for around
80% of NHS funding (£125 billion in 2017-2018). A small
percentage of funding is generated through patient charges,
such as prescriptions, dental care and spectacles. For the year
2015-2016, user charges amounted to £1.3 billion,
corresponding to 1.1% of the budget (King’s Fund, 2017a). The
level of overall funding for the NHS is set through the UK
Government’s Spending Review process. Estimates are made of
the projected income generated by the three sources. When
the spending generated by user charges and National Insurance
is lower than estimated, funds from general taxation are
adjusted to provide the planned level of funding.
Following a period of mostly static budgets (and cuts in real

terms) between 2009-2010 and 2012-2013, the budget for the
Department of Health1 is expected to grow by 1.2% between
2010 and 2021 in real terms (King’s Fund, 2018). Figure 1
below details this planned budget growth, with funding
pledged mainly for staff salaries and medicines, to support
expansion of the number of NHS services provided seven days
a week, invest in new clinical strategies for cancer and mental
health, improve the integration of health and social care, and
fund posts for 10 000 new nursing and other health
professionals (Department of Health, 2015). In June 2018, a
new long-term funding settlement was announced. The
priorities for the NHS were set out in the long-term plan in
January 2019 (NHS England, 2019).
1 Now renamed Department of Health and Social Care.

Figure 1
Department of Health total departmental expenditure limit
(TDEL)
140
120
100
80
£ billions
60
40
20
0
2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21
Actual spending
Planned spending
Source: King’s Fund, 2018. Note: Figures are expressed in real terms at
2017-2018 prices using deflators published by the Office of Budget
Responsibility in November 2017.
The commissioning structure of health services was reformed in

2013. Figure 2 below shows the reformed commissioning
structure. PCTs were replaced by clinical commissioning groups
(CCGs). These are clinically-led, and their governing bodies
include GPs, other clinicians, patient representatives, general
managers, and in some cases practice managers and local
authority representatives (King’s Fund, 2017b). CCGs are now
responsible for the commissioning of most NHS services: acute
care, mental health and community services, urgent and
emergency care (including out-of-hours), rehabilitative care
and, increasingly, primary care and some specialized services
(NHS England, 2018a). The initial number of CCGs was 211 and
was 191 on 1 April 2019. This is due to mergers and joint and
integrated commissioning at the local level across a larger
geographical footprint, with many areas sharing staff or
structures between CCGs.

Figure 2
Funding the NHS in England
Parliament Other arm’s length

bodies, including
NHS Improvement,
Care Quality
£122.2 billion1 Commission and
Health Education
Public Health England
Department
England £4.2 billion £7.4 billion
of Health
£105.9 billion
NHS England £2.1 billion Sustainability

£3.4 billion2 and Transformation Fund
£76.6 billion
Local Better Clinical £12.8 £15.4

authorities Care Fund3 commissioning
groups4 5
billion billion
Public Community Mental Hospital Ambulance Primary care Specialized

health services health services services services
1
All figures are for 2016/17.
2
Public health grant.
3
With the aim of integrating health and social care services, NHS
commissioners and local authorities pool some of their annual budgets
(around £5.8 billion in 2016/17) to create the Better Care Fund.
4
From April 2017, all CCGs have assumed some responsibility for
commissioning primary medical care services. Sixty-three have taken on
full delegated responsibility; the rest have joint responsibility with NHS
England.
5
NHS England transfers money to those CCGs that have taken on full
delegated commissioning of primary medical care services.
Source: Reproduced with permission, King’s Fund, 2017c.
Figure 3 below shows the funding flows of the total NHS

budget (in percentage estimated from expenditures in 2016-
2017). Around 60% of the total NHS budget is managed by
CCGs, and more than half of the budget managed by CCGs –
which represents one third of the total NHS budget – is used to
pay for acute care.

Figure 3
Distribution flow of NHS budget
Directly Commissioned
100% NHS Commissioning Public Health (screening programmes, 1%
child health info, immunisation, sexual
assault) prison healthcare, armed forces
families, some specialized services 5%
87%
3.4% DH programmes
Other Primary Care
Community pharmacy, dental services,
4%
ophthalmic (eye tests, glasses)
NHS Support 5.3%
Activity
Total CCG place-based allocations
Section 7a
4.3% 61% Specialized Services

Care for some uncommon conditions,
for which there are few providers or 12.5%
1%
costs are very high.
Running
CCGs cost cap
Clinical 1%
General Practice
Commissioning Primary care – GP surgeries,
6%
groups GPs and practice teams
0.6%
Cost of medicines prescribed
by GPs for their patients 7%
Public Health
Public Social Care Community Health
health including care homes, Community nursing/ other support 6%
grants drop-in centres,
Continuing Healthcare 4%
2.7% voluntary sector
LAs Better Care Fund (BCF) – programme to

152 local join up health and social care services
authorities 3%
Acute Care
Accident and Emergency (A&E), maternity,
outpatient, acute hospital care, elective /
day case, non-elective, ambulances 33%
Mental Health
Treatment in dedicated facilities and
other care settings, Improving Access
to Psychological Therapies (IAPT) 6.5%
Source: Reproduced with permission, NHS England, 2018b.
Initiatives like the Better Care Fund require CCGs to work

together with local authorities by pooling budgets to deliver
more integrated care. Similarly, the creation of Sustainability
and Transformation Partnerships (STPs)2 have brought together
CCGs, local authorities and NHS England to plan services
around long-term needs of local communities (King’s Fund,
2017b). Overall, CCGs are responsible for about two thirds of
the NHS commissioning budget.
Most of the remaining budget is managed by NHS England,

which is responsible for strategic oversight for the NHS and
directly commissioning most specialized services and, jointly
with CCGs, primary care services, including GPs, pharmacists
and dentists. NHS England is also responsible for some public
health services, such as immunization and screening
programmes.
2 In 2016, the NHS and local councils came together in 44 areas covering all of England to
develop proposals to improve health and care. They formed new partnerships – known as
STPs – to run services in a more coordinated way, to agree on system-wide priorities and
to plan collectively how to improve residents’ day-to-day health.

Lastly, local authorities are responsible for commissioning
social care services (such as providing home and residential
care), and most public health services (such as sexual health,
school nursing and addiction services), with a specific ring-
fenced budget since 2013 (King’s Fund, 2017c) (Figure 4).
Figure 4
Commissioner-provider structure in the NHS
Commissioners contract with Providers regulated by Regulators
£
Clinical Private providers Care Quality Commission
commissioning Independent regulator for quality
groups (CCGs)
Voluntary sector
NHS England
Sustainability
and NHS Improvement
transformation GPs and other Brings together the functions previously
partnerships1 primary care undertaken by Monitor and the NHS Trust
Local authorities development Authority. it is responsible
for the financial regulation, performance
management and governance of NHS
NHS trusts and
trusts and foundation trusts, and also
foundation trusts supports service improvement
Greater
Manchester Accountable
devolution3 care systems2
1
ince December 2015 NHS providers, CCGs, local authorities and other
S
health care services have come together to form 44 STP ‘footprints’.
These are geographic areas that are co-ordinating health care planning
and delivery, covering all areas of NHS spending on services from
2016/17 to 2020/21.
2
From mid-2017, eight areas of England are evolving into accountable
care systems. This involves commissioners and providers assuming
responsibility for a budget to deliver integrated services for a defined
population.
3
From April 2016, leaders in Greater Manchester have taken greater
control of the region’s health and social care budget. This includes
taking on delegated responsibility for several commissioning budgets
previously controlled by NHS England. Other areas – including London
and parts of Surrey – are also pursuing devolved arrangements.
Source: Reproduced with permission, King’s Fund, 2017c.
Commissioners are increasingly working together across the

larger STP footprints to deliver long-term plans for the NHS. In
some cases, such as Greater Manchester, there are additional
devolved responsibilities (Greater Manchester Health and
Social Care Partnership, n.d.) for commissioning health and
social care services from a range of providers – GPs and other
primary care health professionals, NHS trusts and foundation
trusts, private providers, and the voluntary sector. All STPs will
have to evolve to form an Integrated Care System over the next
two years. Alternative payment approaches are being
developed, and in a few cases, commissioners have contracted
to manage a single budget to deliver a range of services for the
local population (King’s Fund, 2017b).

Providers are regulated by two main entities: the Care Quality
Commission (CQC), which is primarily responsible for quality
and safety assessments for all health and social care services;
and NHS Improvement, which regulates resource use, financial
levers and operational performance using a shared definition of
quality and efficiency with the CQC.
2
Price setting across NHS services
In this section, the current price-setting mechanisms for
primary care, acute services and community and mental health
services are described, with an emphasis on how these systems
have changed in the past decade to better align with the
objectives set out at the national level.
In this context, it is important to underline that there is a wide

range of choices available to NHS patients as long as this is
clinically appropriate. These are set out in the Choice
Framework (Department of Health and Social Care, 2016). They
include statutory rights to choose for elective acute and mental
health services, where diagnostic tests will be undertaken, and
the right to have a personal health budget where certain
prerequisites are met. Patients should also be offered choices
for maternity and community services, although these are not
set out in legislation. Patients should also be offered choices
for maternity and community services, although these are not
set out in legislation. Patients can review the choices that are
available to them for particular procedures and treatments on
the NHS website, as well as the waiting times at each provider.
Primary care
GP services are primarily funded through capitation. The

services are commissioned by NHS England, and increasingly
by CCGs with delegated responsibility for four primary care
contractor groups (medical, dental, eye health and pharmacy)
(NHS England 2018). The negotiations for GP reimbursement
are carried out between NHS England and the General
Practitioners Committee (GPC) of the British Medical
Association (BMA) on the General Medical Services (GMS)
contract, under which most GPs (individuals and practices) are
contracted.
GPs have traditionally worked as independent contractors

under the GMS, usually in GP practices in which each GP is a
partner with a stake in the financial success of the practice.
Today, an increasing number of GPs are employed on a salaried
basis, usually by other GPs who own the practice.
GP practices are now working together to form Primary Care

Networks (PCNs) (National Health Service, 2017) covering a
population of 30 000-50 000 patients, with the ambition to
encourage more collaboration and delivering a more proactive
and personalized approach for primary care services in each

area. Additional funding for PCNs is being made available
throughout 2019, and new contractual arrangements for GPs to
reflect the role of GPs in PCNs start in April 2019 (National
Health Service, 2019).
The General Medical Services (GMS) contract is the main

contractual form used to commission primary medical services,
and it delivers core medical services at a nationally agreed
price. The capitated funding received by each GP practice to
deliver these services is based on each practice’s registered list
size with a fixed, nationally agreed price per patient, weighted
by the demographic mix of patients and levels of deprivation.
Personal Medical Services (PMS) contracts provide similar core
services to GMS contracts but can also include extra health
services ‘over and above’ the standard services, are issued to
address specific local health needs. Funding for such contracts
is agreed locally.
Lastly, Alternative Provider Medical Services (APMS) contracts

enable primary care organisations (PCOs) to commission or
provide other primary medical services within their area to the
extent that they are necessary. They allow PCOs to contract
with non-NHS bodies, such as voluntary or commercial sector
providers, or other GMS/PMS practices, to provide enhanced
and additional primary medical services. Around 62.5% of
practices operate under GMS contracts, 34% under PMS, and
3.5% under APMS deals (Figure 5).
Where a practice opts out of delivering out-of-hours services

their contract value is reduced to reflect this.
Figure 5
GP practices by contract type
Source: Bostock, 2016. Note: Snapshot from 2016 data. OpenStreetMap

contributors, © CARTO. Map created by Nick Bostock.

In addition to these core contracts, a range of voluntary and
additional contracts are used to cover specific needs or to
incentivize prevention and quality in primary care. These
include Enhanced Services (ES), which are locally contracted
and cover a range of functions such as sexual health screening,
smoking cessation programmes, blood pressure monitoring and
weight management (Addicott and Ham, 2014); other
community-based services and public health services such as
screening and immunisation programmes; and, importantly, the
Quality and Outcomes Framework (QOF).
Introduced in 2004, the QOF provides additional income to GP

practices that deliver improved quality of care as measured by
performance against a range of metrics (mainly related to
patients with long-term conditions) (National Health Service,
2018a). Most practices on GMS contracts, and many on PMS
contracts, take part in the QOF. For the 2013-2014 GP contract,
QOF thresholds were raised to further improve performance,
and new indicators were added. The National Institute for Health
and Care Excellence (NICE) took a new role in the QOF context
by producing a menu of evidence-based, clinically and cost-
effective indicators selected on the basis of criteria such as
accuracy of data, clarity of diagnosis and relevance of actions.
The indicators are being updated further from April 2019.
Acute services
The last decade has seen major reforms to the payment system
for acute and emergency services. Before 2003, hospitals in
England were paid through block contracts for most services.
These contracts specified minimum and maximum levels of
provision, with activity falling above or below these thresholds
triggering actions such as renegotiation or data validation
(Marshall, Charlesworth and Roberts, 2014). A series of reforms
in 2002 introduced the current dominant activity-based
payment scheme, initially known as Payment by Results (PbR),
and now called the National Tariff. It initially financed a small
proportion of inpatient elective hospital care, was expanded to
cover all elective care by 2006, and by 2007 covered most
acute activity, including non-elective, outpatient, and accidents
and emergencies (A&E) (Department of Health, 2012). By
2014-2015, PbR covered 67% of acute income and 60% of the
total income received by all NHS trusts (Wright et al., 2017).
The National Tariff sets out nationally determined currencies3

and a schedule of prices. It is the main way that commissioners
pay acute health care providers for each patient seen or
treated, taking into account the complexity of the patient’s
health care needs.
Activity based funding has meant that money ‘follows’ the

patient and, because prices are fixed, competition for patients
has been on the basis of quality rather than price. For inpatient
3 Currencies are the unit for which a payment is made. They take a number of forms
covering different time periods from an outpatient attendance to a year of care for a
long-term condition. They include Health Resource Groups (HRGs) for inpatient spells.
Tariffs are the set prices for each currency.

stays, providers are reimbursed for ‘spells’ of activity. Spells,
which cover the period from admission to discharge, are coded
as Healthcare Resource Groups (HRG) based on the types of
patient and treatments with similar cost implications (Marshall,
Charlesworth and Roberts, 2014). There are currently more than
2800 HRGs included in the national tariff.
Costs are reported by all NHS providers in the annual reference

cost collection. Reference costs give the most comprehensive
picture available of how the 232 NHS providers in England (80
NHS trusts and 152 NHS foundation trusts) spent £68 billion
delivering health care to patients during the financial year
2017-2018 (the most recent year for which data has been
published) (National Health Service, 2018b). This is 62% of
total NHS expenditure and includes core admitted patient care
(APC) costs of £27.7 billion, mental health costs of £7.2 billion,
community care costs of £5.5 billion, ambulance costs of £1.9
billion, as well as outpatient care.
It is mandatory for NHS trusts and foundation trusts to submit

their cost data. These data have been collected since 1997, and
since 2003 have fed into the calculations that determine the
published tariffs.
The reference cost data is publicly available at the provider and

aggregate levels. It is a rich data source and has many uses,
from informing price setting to public accountability to
Parliament. NHS trusts have a responsibility to improve their
internal costing processes and systems to help them better
understand the cost of delivering services, leading in turn to
the submission of improved cost data. NHS Improvement has a
responsibility to ensure the costs collected are fit for purpose
and support this responsibility by producing comprehensive
and clear guidance.
National cost collection submissions are subject to audit as part

of the costing assurance audit program, and all acute NHS trusts
and foundation trusts are selected for audit at least once every
three years. The purpose of the audit program is to provide
assurance that reference costs have been prepared in
accordance with the Approved Costing Guidance.
England’s NHS trusts and foundation trusts are in the process of

moving to a new national approach of cost data collection
based on patient-level costing (known as PLICS). This will be
the mandated approach for all acute providers from the
financial year 2018-2019.
The tariff (price reimbursed) is typically based on the national

average cost of providing care for each currency unit as
estimated on the basis of the reference cost submissions. There
is a formal consultation process with providers and
commissioners about each National tariff package, including
the draft prices, calculation methodology, and any policy
changes. Stakeholder views are taken into account in the final
published tariff package.

The price actually received for an intervention or procedure by
each acute provider is then multiplied by a nationally
determined market forces factor (MFF), which is unique to each
provider and reflects relative costs of care across the country.
London providers have the largest MFF. There may also be other
adjustments to the tariff for long or short stays, specialized
services, and support for specific policy goals such as providing
care compliant with Best Practice (Department of Health, 2012)
(Figure 6). Some tariffs were also traditionally adjusted to take
account of NICE guidelines on cost-effective technology. Figure
7 shows the information flow from treatment to payment.
Figure 6
Best Practice Tariffs
A 2008 review of the NHS found a substantial amount of non-compliance

with best practice for hospital services. As a result, a policy commitment
was made to set some tariffs that financially incentivize providers to
provide care compliant with best practice – referred to as Best Practice
Tariffs (BPTs). The aim of this approach was to encourage the payment of
services that followed clinical guidelines and to discourage variation in
practice that did not follow best practices (Marshall et al., 2014). BPTs
target hospital activities according to the following criteria: high potential
impact (e.g. volume, significant unexplained variation in practice, or
significant impact of best practice on outcomes), strong evidence on best
practice, and clinical consensus on characteristics of best practice. In
2010, BPTs applied to all providers of NHS-funded care, including both
NHS and independent providers, for hospital admissions related to hip
fracture, stroke, cholecystectomy and cataract surgery. BPTs can be higher
or lower than HRG tariffs based on national average costs. The price
differential between best practice and “standard” care is set to ensure
that the anticipated costs of undertaking best practice are reimbursed,
while creating an incentive for providers to shift from standard care to
best practice. Coverage of BPT has steadily increased from four in 2010
to more than 50 procedures. The tariffs are set centrally, which leaves
very little room for local price negotiation between providers and
commissioners, although there are some non-mandatory BPTs
(OECD, 2016).
Private providers may choose to offer their services to NHS

patients, in this case they are also reimbursed by
commissioners using the prices published in the National tariff.
For their private patients, these providers set their own prices.
Around 30% of income to providers comes from NHS patients
(LaingBuisson, 2018).
The development of an activity-based payment system was led

by the Department of Health. Since 2014, responsibility has
been shared between NHS Improvement4 and NHS England for
the tariff, currency design and price setting.
For the tariff which took effect from April 2019, England has
introduced a ‘blended’ payment approach for emergency care
taking place in acute hospitals. This comprises a fixed amount
(linked to expected levels of activity) and a volume-related
element that reflects actual levels of activity, as well as some
4 NHS Improvement is the organisation responsible for overseeing foundation trusts and
NHS trusts, as well as independent providers that provide NHS-funded care. NHS
Improvement offers support to give patients consistently safe, high quality,
compassionate care within local health systems that are financially sustainable.

sort of risk-share between provider and commissioner (National
Health Service, n.d.).
The payment model covers A&E attendances, non-elective

admissions (excluding maternity and transfers) and ambulatory
emergency care. It is the new ‘default’ reimbursement model
for emergency care but does not stand in the way of local
systems that want to move faster towards other population-
orientated payment models.
This approach is designed to provide greater stability and

encourage providers and commissioners to focus on how to use
resources most efficiently and effectively to improve quality of
care and health outcomes. The approach shares responsibility
for the resource consequences of increases in acute activity
and the benefits of system-wide action to reduce growth in
emergency care, and ensure that care takes place in the most
appropriate setting.
Figure 7
Payment by Results (PbR) from treatment to payment
1 Treatment
– Admitted patient care, outpatients, A&E
2 Coding
– On discharge, care is coded by clinical coders
– There are separate classification systems for diagnoses
and interventions
– These codes, and other data including age and length of
stay, are recorded on the hospital’s computer system
3 Grouping
– Data are submitted to the Secondary Uses Service
– SUS assigns an HRG based on clinical codes and other
patient data
4 Tariff
– Tariff price depends on the HRG and type of admission
– There are tariff adjustments for long or short stays,
specialized care and best clinical practice
5 Money
– Providers may be paid a variable amount based on the
activity undertaken as reported through SUS
– Alternatively, monthly payments from commissioner to
provider may be agreed in advance based on an estimated
activity plan in the NHS standard contract
– Actual activity transmitted from provider to commissioner
via SUS is used to adjust these payments
Source: Department of Health, 2012. Note: SUS: Secondary Uses Services.

Community and mental health
Putting mental health care on a level footing with physical

illness has been a top priority for the NHS in England in recent
years. The blueprint for improving mental health services was
set out in 2016 in NHS England’s Five year forward view for
Mental Health, supported by an additional £1 billion
investment and informed by the views and needs of thousands
of patients, their families and medical professionals. The
Long-Term Plan for the NHS reinforces this focus with a
commitment for a further £2.3 billion increase in annual real
terms investment by 2023-2024. Since 2015, spending has
increased £10 979 million in 2015-2016 to £11 976 million at
the end of financial year 2017-2018, around 13.7% of overall
allocations to CCGs.
While almost two thirds of hospital activity are covered by

activity-based payment through the national tariff, the
predominant payment system for the remaining secondary care
services has been through the agreement of a block contract
used to reimburse around 90% of community services and two
thirds of mental health care. Commissioners and providers can
agree to prices and a payment approach locally for mental
health and community services in line with the local pricing
rules published by NHS Improvement. Pay-for-performance
aspects have also been added to the payment system for
mental health and community services through the
Commissioning for Quality and Innovation (CQUIN) schemes.
The national currencies for mental health were introduced in

2012. These are needs-based currencies under the three broad
diagnostic categories of psychotic, non-psychotic and organic
presentations. However, only a small number of contracts have
been agreed on the basis of such currencies. Currencies also
exist for the Improved Access to Psychological Therapies (IAPT)
service and are being developed by Child and Young People’s
Mental Health Services (CAMHS) (Marshall, Charlesworth, and
Hurst, 2014).
The Mental Health Investment Standard was introduced in

2016 to try to ensure that CCGs increase spending on mental
health in line with the overall increase in funding available to
them. CCGs must report on their compliance with the standard.5
The National Tariff also proposed that blended payment would

be the default payment approach for mental health services
from April 2019. This combines a fixed payment with a variable
element where activity exceeds planned levels, and an element
linked to delivery of agreed outcomes.
The other key group of services not covered by a tariff payment

system is community health services. Community health
5 The Mental Health Five Year Forward View (MH FYFV) sets out the plans for improving and
expanding mental health care, which continues to be central to the NHS as part of the
Long-Term Plan. The MH FYFV dashboard brings together key data from across mental
health services to measure the performance of the NHS. The dashboard provides
transparency in assessing how NHS mental health services are performing, alongside
technical details explaining how mental health services are funded and delivered.
https://www.england.nhs.uk/mental-health/taskforce/imp/mh-dashboard/

services are diverse in function and differ widely between
localities across England. They include a wide range of services
that are delivered at clinic or in patients’ homes, including care
for long-term chronic conditions, preventive services, and
assessment and rehabilitation services, plus some inpatient
community hospital services and hospice care. Together, these
services accounted for 12% of NHS funding in 2014-2015
(Lafond, Charlesworth and Roberts, 2016).
A project is underway to test a community currency model with

providers and commissioners. This work will draw upon data
from the community dataset, which was introduced in October
2017, and is a nationally mandated dataset for all providers of
community services. The currency model will be tested during
2019 and is focused on the changing needs of patients through
their life-course.
Nursing and care home funding
The funding of places in nursing and care homes in England is a

complex area. The type of care provided in such homes is often
a mix of health and social care. Whilst there is no legal
definition of social care, previously published NHS guidance
(Davies, n.d.) defines it as a social care need “that is focused on
providing assistance with activities of daily living, maintaining
independence, social interaction, enabling the individual to
play a fuller part in society, protecting them in vulnerable
situations, helping them to manage complex relationships, and
(in some circumstances) accessing a care home or other
supported accommodation”.
State funding for social care needs is a local authority

responsibility and is means tested. Therefore, if a person needs
to go into a care home or nursing home for mainly social care
needs and their income and savings fall above a certain
threshold, they will have to meet the costs of their care through
their savings or through the sale of their home.
Where the person has some nursing needs and lives in a

nursing home, they will be entitled to some NHS funding. The
money is paid directly to the nursing home, and from April
2018 the standard rate is £158.16 per week. For those people
whose needs are deemed to be predominantly health related,
they may be entitled to NHS Continuing Health Care funding,
which will pay for the entirety of their care whether at home, a
care home or nursing home (National Health Service, 2018c). A
multidisciplinary assessment is made of the person to decide
on the entitlement.
Various governments have committed to introducing an upper

cap on the requirements for an individual to contribute to their
social care and have also discussed new schemes to fund social
care in the future. The current UK Government has committed
to publishing a Green Paper on this topic in 2019.6
6 This is a forthcoming green paper for which no publication date has yet been decided
https://researchbriefings.parliament.uk/ResearchBriefing/Summary/CBP-8002

3
Discussion
The current NHS is evolving to adapt its payment system to its

stated objectives
The current NHS payment system has evolved greatly over the
last decade and employs a mix of different payment methods
across different services and sectors. Moves away from block
budgets to activity-based payment approaches have improved
provider productivity in the acute sector. However, block
contracts are still the predominant payment mechanism for the
community and mental health sectors. Moreover, the structure
of incentives across services does little to support policy
ambitions to shift care that does not need to be delivered in
hospitals into a community setting, with the payment systems
often giving conflicting signals. The predominance of activity-
based payment in the acute sector, introduced at a time of long
waiting lists, encouraged activity in hospitals; at the same time,
block budgets in community services and capitated budgets in
primary care offer little incentive to increase activity or
enhance efficiency in these settings (Marshall, Charlesworth
and Hurst, 2014).
Although a combination of methods is likely to be appropriate

in most instances, the current combination of a case-based
system for most acute care and block budgets in out-of-
hospital services has provided a balance of incentives that are
counter to the national ambition to provide more care out of
hospitals and to treat mental and physical health services with
parity. Equally, they do not provide incentives for prevention or
early intervention.
New payment models are being developed and tested in local

areas in line with the development of the various new models
of delivering care. As an example, a version of capitation-based
payment known as ‘whole-population budgets’ has recently
been suggested to support these new models of care. However,
arrangements for ongoing evaluation of these new payment
systems and spreading of best practice are not currently clear,
and must be developed and shared (Wright et al., 2017).
New models of care were proposed in the five year forward

view are now in their third year and piloted by 50 vanguard
areas in England. STPs published plans in 2017, and these
plans will evolve into Integrated Care Systems over the next
two years. The aim of these developments is to drive
collaboration and more integrated care across providers to
better meet the needs of local populations. These new ways of
delivering care may require new ways of paying for care too.
Under the current system, payments are made within
organisational boundaries (Wright et al., 2017).

Policy lessons across services
Although the ultimate purpose of the health care system is to

improve patient outcomes, there is currently limited evidence
for the impact on outcomes of financial incentives to providers.
There has, however, been only limited experimentation and
even scarcer robust evaluation. This is in part due to the fact
that outcomes are far more difficult to measure and attribute
than the processes of care. For something to be incentivized, it
must be both measurable and directly attributed to the
provider. Outcomes are often difficult to measure, distant in
time from the care activity, and influenced by multiple
determinants, including many outside the control of the health
sector, making attribution to a specific provider difficult. There
are also inherent risks to incentivising outcomes which need to
be managed, including the impact on equity and equality of
access to care.
Conceptually, the measurement of outputs should include the

quality of care as well as the volume of care. However,
measuring outputs in health care is complex, and there are
concerns that quality differences are not effectively captured.
Measures of efficiency of health services are therefore often a
simple comparison of activity and cost, rather than quality-
adjusted output (Marshall, Charlesworth and Hurst, 2014).
There is still limited evidence that the increasing attempts of

pay-for-performance schemes to improve quality of care are
actually able to do so, both in the NHS and at the international
level (Marshall, Charlesworth and Hurst, 2014). Financial
incentives are more useful in influencing processes of care
rather than patient outcomes.
For the QOF scheme in primary care, there is a consensus that it

improved processes as well as quality of care for chronic
conditions. However, there is concern that this kind of financial
incentive may have a detrimental effect on the intrinsic
motivation of health professionals (Glasziou et al., 2012).
Glasziou et al., (2012) found that motivation was reduced due
mainly to the fact that professionals disputed the evidence
base for one of the quality indicators used to assess them.
For activity-based funding in acute care, there is strong

evidence that the tariff system has resulted in reductions in
length of stay and increases in day cases across most groups of
patients, providers and HRGs (Farrar et al., 2010). These
changes came with a resource saving of around 1-3% over a
five-year period and an increase in the number of spells of
3-9%. Overall, this evidence is broadly consistent with
international evidence of similar DRG-based payment systems
introduced in place of block budgets.
Moreover, since DRG-based systems require good information

on costs, quality and outcomes, there is the risk that
inaccuracies in cost data will result in reimbursement levels
that do not reflect true underlying costs (Marshall, Charlesworth
and Hurst, 2014).

Regarding BPTs, evaluations show mixed effects. There is clear
clinical support for BPTs due to their promotion of evidence-
based protocols. It is, however, unclear whether the financial
incentives alone are sufficiently high to change care or
significantly reduce variation (Gershlick, 2016).
System objectives and other policy levers
The scale of change required in a payment system is hard to

determine without clear objectives in mind. Figure 8 shows the
difference in how many priorities were identified in the NHS for
the tariff system compared with countries with similar DRG
payment schemes.
Figure 8
Policy objectives for DRG payment in European countries
England Finland France Germany Ireland
Increase efficiency √ √ √ √
Expand activity √
Enhance patient choice √
Increase patient satisfaction √
Reduce waiting lists √
Improve quality √ √ √
Control costs √
Ensure the fair allocation of resources (or

funding ) across geographical areas and across √ √ √ √
and within health care sector
Shift patterns of service provision away from
√
historical patterns
Encourage the development of new, cost-
√
effective, treatment pathways
Improve transparency of hospital funding,
√ √ √ √
activity and management
Encourage providers to be responsible to
√
patients and purchasers
Cover costs of production √
Create a level playing field for payment to

√
public and private hospitals
Improve documentation of internal processes
and increased managerial capacity, which would √
in turn improve efficiency and quality
Establish link between activity and funding √ √
Source: Reproduced with permission, O’Reilly et al., 2012.

Achieving so many objectives through the payment system will
lead to an overly complex system that is ultimately unable to
deliver on any of them (Wright et al., 2017).
The payment system can play an important – although limited

– role in improving the quality of care and efficiency of services
provision, but it cannot by itself overcome the many challenges
that characterized complex care systems. Where payment
mechanisms have improved quality and efficiency, the effect
tends to be small. Their impact is also very dependent on the
wider policy and delivery context.
A number of factors (e.g. organisational culture, relationships

between organisations, and system-wide funding and demand
pressures) can either undermine or enhance the impact of a
payment system, and thus must be considered. Payment rules
are just one lever among a range of tools that should be
considered to maximize effectiveness (Wright et al., 2017).

Addicott R, Ham C. Commissioning and funding general
practice. Making the case for family care networks. King’s Fund.
London; 2014.
Bostock N. Map: Find out where GPs are on APMS, PMS and GMS
contracts. GPOnline; 2016. (https://www.gponline.com/map-
find-gps-apms-pms-gms-contracts/article/1401067, Accessed
1 May 2019).
Davies T. What is the Difference Between Healthcare and Social

Care? Compass continuing healthcare. N.d. (https://www.
continuing-healthcare.co.uk/continuing-healthcare-guidance/
difference-between-healthcare-and-social-care, Accessed 2
May 2019)
Department of Health. Spending Review 2015; 2015. (https://

www.gov.uk/government/news/department-of-healths-
settlement-at-the-spending-review-2015, Accessed 14 March
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Development; 2019.

Case study
France
Institute for Research and Information in
Health Economics
Paris, France
55
France
Abstract 57
1 Background on the French health system 58
Health status 58
Health care financing 58
Health care provisions 59
Regulation and management 59
Macro-level cost containment 59

2 Price setting for ambulatory services 61
Setting fees for primary care and

Contents outpatient specialist services 61
Regulation of prices in sector 2 64
A progressive shift towards value-based payment 65
Setting fees for medical ambulatory procedures 68

3 Price setting for drugs and medical devices 70
Setting prices of drugs and medical devices

used in ambulatory settings 70
Definition of prices of pharmaceuticals and
medical devices used in hospitals 72

4 Price setting for acute hospital care 73
Hospital context 73
Price setting in acute care hospitals: the
DRG payment model 74
Definition of GHM tariffs 75
Using prices to regulate hospital activity 79
Payments for acute psychiatric hospital care 79

5 Price setting for rehabilitation
and long-term care (LTC) 80
Inpatient rehabilitation services 80

Long-term residential care for elderly 80
Annex 1
Indicators taken into account for bundled
payments to physicians 83
References 84

The French system encourages plurality in health care
provision, which relies on a mix of public and private providers.
This plurality, with a high share of private providers working
under public insurance regulation, explains partly the relatively
good results concerning waiting times and patient satisfaction.
However, the high degree of autonomy and choice both for
providers and patients together with primarily fee-for-service
payments for health care providers requires careful regulation
of prices and of the health care market to contain health
expenditures and to tackle issues of care coordination, access
and efficiency.
The level of remuneration of health professionals is partly the

result of the power relations between the stakeholders. In a
system where most health professionals are paid on a fee-for-
service basis and where the social health insurance funds act
as a single payer, the French experience shows that price
regulation at the central level combined with macro-level
Abstract expenditure controls is instrumental for steering health care
providers. France has put in place successfully several
mechanisms for controlling the fees for providers, services,
medications, etc. at the national level. The regulation of prices
for major health services and medications reduces financial
burden of care for patients and allows improved access for the
whole population. Private providers contracted with public
payers under regulated fees contribute to easing the pressure
on public resources and satisfying the increasing demand.
However, the French experience also shows that concentrating
only on provider fees, without questioning the quality or
appropriateness of services, is not enough for cost containment
in the longer term. Under fee-for-service, and activity-based
payment in hospitals, providers tend to compensate for
(potential) lost revenues by increasing the volume and intensity
of their services.
Therefore, increasingly, the attention is turned on alternative

modes of payment with development of value-based contracts
and bundle payments to incentivize quality of care both in the
ambulatory and hospital sector. In the hospital sector, there is
also a growing tendency to use prices for encouraging
treatments, which are considered as “better practice” or
discouraging “low value care” rather than paying for any
volume of activity.

1
Background on the French health system
Health status
France is a high-income country with relatively good health
outcomes. Compared with other industrialized countries, France
ranks high in terms of life expectancy both at birth and at
advanced age. In particular, older persons remain in better
health with one of the highest life expectancies at the age of
65 over among OECD countries (24 years for women and 19
years for men) (OECD, 2018a; 2018b). Cancer survival rates,
which are often used as a more direct indicator of the
performance of the health care system, are also high compared
with most other European countries (Eurocare, 2014). At the
same time, France suffers from a high rate of premature male
deaths from accidents and unhealthy habits (smoking and
alcoholism), and social and geographic inequalities in health
remain substantial (Lang and Ulrich, 2017).
Health care financing

Health care is financed via a social insurance system where the
coverage is effectively universal. Health-related costs are
covered by a mixture of compulsory social health insurance
(SHI) and private complementary health insurance (CHI)
schemes. The benefit package is comprehensive, uniform, and
of overall good quality. In addition, France has one of the
lowest levels of out-of-pocket payments among OECD
countries (OECD, 2017).
Enrollment in SHI depends on the employment status and is

automatic for workers (covering their spouses and dependent
children). Consumers cannot choose their scheme or insurer
and cannot opt out. Since 2000, there is a state funded scheme,
Universal Medical Coverage, for very-low income groups
(Couverture Maladie Universelle, CMU). There are no competing
health insurance markets for the core health coverage in France.
There is however a very competitive private complementary
insurance market with about 95% of the population owning
private CHI. This is due to the fact that patients need to pay
part of the cost for almost all services, including doctor
consultations, hospital care and prescriptions. CHI is mostly
used to cover the share of cost left to patients for services
included in the public benefit basket.
Funding of the SHI comes mainly from income-based

contributions of employers and employees, and increasingly by
taxes on a broader range of income with additional revenues
from earmarked taxes on tobacco, alcohol, pharmaceutical
companies, etc.

Health care provisions
Health care provisions rely heavily on private providers.
Ambulatory care is mainly provided by self-employed private
health professionals including physicians (general practitioners
[GPs] and specialists), nurses, dentists and medical auxiliaries,
working in their own solo practice or in health/medical centres
and hospital outpatient departments. More than half of all
surgeries and one fourth of obstetric care are provided by
private-for-profit hospitals that are contracted with and paid by
the SHI fund.
Historically, health care is organized around four principles

delineated by law: confidentiality of medical information;
freedom of practice for physicians; patient’s free choice of
provider; and office-based fee-for-service (FFS) practice in the
ambulatory sector. Doctors are free to choose where and how
they practice. Patients have free access to any physician or any
facility with no limit on the frequency of visits. There is very
little control of access to hospital and specialist care. While
some of these principles have been challenged with recent
reforms, there is still a high degree of independence and choice
both for providers and patients.
Regulation and management
The regulation and management of the health care system is

mainly divided between the state (parliament and government
with several ministries) and the statutory health insurance
funds. The state/government sets out sector-level expenditure
targets, determines the levels of health care provision and
training, regulates care quality, and defines priority areas for
national programs. On the other hand, the statutory health
insurance funds play the main role in defining the benefit
baskets; regulating the prices of procedures, drugs, and devices,
which will be reimbursed to patients; and defining the levels of
copayment. Statutory health insurance oversees setting tariffs
for health professionals in private practice via collective
negotiations with professionals’ unions.
Macro-level cost containment
Health is the second largest area of public spending in France.

Health care and other social security deficits have been a
persistent problem over the course of the 2000s. The
specification of an overall expenditure target for health care,
known as the National Objective for Health Insurance Spending
(Objectif National de Dépenses d’Assurance Maladie, ONDAM),
has been a key aspect of the French strategy to control health
spending. This involves setting an a priori global budget for
health each year. Traditionally, the French government has not
played a proactive role in controlling overall health care
spending, with independently operated compulsory insurance
funds responsible for managing their own spending. ONDAM
marked a significant break from this tradition and represents
the reassertion of the government’s control of health care
spending (Barroy et al., 2014).
ONDAM is specified in monetary terms as the total amount of
health spending for the forthcoming calendar year and gives all
stakeholders a precise objective in terms of spending. The
monetary ONDAM target is used to signal the percentage of
health spending growth that the government is willing to
accept in any given year. ONDAM’s overall target is split into
three sub targets for the main health service providers:
ambulatory care, hospitals, and medico-social facilities. The
budgets for hospital and medico-social facilities are further
divided into two envelopes, one for public and private non-
profit hospitals and one for private for-profit ones.
Initially set as objectives, ONDAM targets became binding over

time with a dedicated committee following the evolution of
health expenditures toward more responsibility and powers for
the health insurance funds contain costs. Despite the initial
uncertainty of its influence, the budgetary processes ushered in
by ONDAM appear to achieve better containment of health
expenditures as well as better working relations between
stakeholders. The growth rate of health expenditures has been
decreasing for a decade, and ONDAM targets have been
successfully met since 2010 (Figure 1).
Figure 1
Evolution of health expenditure growth against ONDAM targets
% 6
2004
5
2007
2005
4
2009
2011
3
2008 2014
2006
2017 2018
2 2010 2016
2012 2015
2013
1
0
125 135 145 155 165 175 185 195
Source: CCSS, 2018. Note: The abscissa shows expenditure in billions of

euro and the ordinate shows growth rate. The size of each bubble
represents the extent of the deficit (in light blue) or surplus (in dark blue)
with respect to the ONDAM target voted in the parliament. In 2018, total
expenditure of health insurance funds was €195.2 billion, representing a
constant growth rate of 2.3%, which is slightly under the set target. In
comparison, the ONDAM target was 4% in 2004, while the actual growth
rate observed was 4.9%.

2
Price setting for ambulatory services
Health professionals working in the ambulatory sector and
those working in private hospitals contract with the health
insurance fund and are paid on a FFS basis. The prices of the
services (consultations and procedures) provided by these
professionals are set at the national level by the SHI fund.
Setting fees for primary care and outpatient specialist

services
Primary care and outpatient specialist services are mostly

funded on a negotiated FFS basis. However, recent initiatives
from the SHI fund have tweaked the funding by introducing a
pay-for-performance (P4P) scheme that is completed by
structural bundled payments. The fees are set through formal
negotiations between the union of statutory health insurance
funds (UNCAM), the government, the union of complementary
health insurance schemes (UNOCAM) and unions of health
professionals, which led to a national collective agreement
(convention nationale), a contract that aims to regulate the
expenditure and activity of the ambulatory sector. These
negotiations have been national since the 1970s and lead to
uniform fees corresponding to official tariffs for reimbursement
by SHI (Régereau, 2005). UNCAM first provides a proposal
which takes into account financial constraints set by the sub-
target of ONDAM for the ambulatory sector. The proposal sets
the principles and modalities for respecting the expenditure
target (notably, modification of tariffs or fees for services) as
well as a range of measures for incentivizing better medical
practice to achieve the priorities set by the SHI fund (such as
better geographical and financial access to care, improving care
coordination, health prevention and promotion and quality of
care) (Union nationale des caisses d’assurance maladie et al.,
2016).
The UNCAM proposal is discussed with different provider

unions. Medical professionals’ unions exert considerable power
through lobbying in the parliament. The Ministry of Health
therefore plays a significant role in the negotiations, which can
be complicated between UNCAM and unions of physicians, in
particular. Unions obtaining more than 30% of the votes from
their professional groups can sign the agreement on their own,
while those obtaining between 10% and 30% of the votes
need to sign the agreement together with the other unions.
Agreements for each professional group cover a period of five
years. At the same time, regular amendments occur (at least
annually for doctors) to adjust for changes demanded by the
Social Security Finance Act, which sets the ONDAM expenditure
targets and defines new provisions and measures to reach the
targets each year.

Traditionally the fees have been increased regularly, mainly by
taking into account inflation and depend on the bargaining
power of the professional unions (Figure 2). In 2011, the SHI
fund had introduced a P4P scheme (see below) and froze the
prices until 2016. However, in the national agreement of August
2016 (just before the presidential elections), physicians
obtained a significant increase in tariffs (from €23 to €25 for a
regular GP consultation and from €28 to €30 for a regular
consultation with most specialists). This agreement introduced
higher fees for consultations with complex patients (a tariff
reaching €50) and very complex patients (with a tariff of €60)
(CNAM, 2018c). These consultations are dedicated to patients
with multiple, complex and unstable conditions, and to specific
services with strong public health stakes (such as screening and
prevention). The visits that can benefit from these new tariffs
are defined by the SHI fund in the national agreement. Complex
consultations include, for example, visits for contraception and
prevention of sexually-transmitted diseases for teenagers,
while very complex visits include, for instance, initial visits to
organize treatments for severe chronic conditions, such as
cancer and neurodegenerative disorders (Union nationale des
caisses d’assurance maladie et al., 2016). Since 2016, the SHI
fund has also offered a lump-sum payment (of €50 000) for
physicians setting up their practice in a medically underserved
region with a complementary payment of up to €5000 per year
to compensate low revenues in less populated areas.
All medical professionals are subject to the terms of the

national agreement, except if they explicitly choose to opt out
(less than 1% of all physicians), in which case their
consultation fees are not reimbursed at all. The SHI fund pays
the social contributions, including the pension, of physicians
who agree to charge patients on the basis of the nationally
negotiated fees (called sector 1 contractors). About 75% of
private physicians are sector 1 contractors and are generally
not allowed to charge higher fees with very few exceptions1
(France Assos Santé, 2017).
Some physicians and dentists are allowed by SHI to charge

prices higher than the regulated fees (sector 2 contractors)
based on their level and experience. Doctors working as sector
2 contractors are free to charge higher fees, but must purchase
their own pension and insurance coverage. The creation of
sector 2 contractors in 1980 aimed to reduce the cost of social
contributions for the SHI fund, but did not have the expected
impact, and the demand for the sector was much higher than
predicted. Consequently, access to sector 2 has been limited
since 1990; each year, only 1000 new doctors are allowed to
work in sector 2.2
1 When patients do not respect the gate-keeping system (médecin traitant) developed
under the 2004 Social Security Finance Act to support coordinated care pathways, the
physician is allowed to charge a supplemental fee (maximum 17.5% of the nationally
negotiated fees) that complementary insurances are not allowed to cover.
2 The attributes of doctors allowed to work in sector 2 are listed in the national agreement
and include doctors with previous public hospitals positions (former medical chief
resident, former hospital assistant, hospital practitioner appointed permanently, and
part-time practitioner with at least five years of experience) and physicians or surgeons in
the army.

The amount exceeding the regulated price (balance billing) is
not covered by SHI but can be covered by private CHI.
Nevertheless, the generosity of CHI contracts varies largely with
different price limits on extra billing. Around one quarter of
physicians are sector 2 contractors, but this proportion shows
strong variation across regions and medical specialties and is
higher for specialists (43%) than for GPs (10%) (France Assos
Santé, 2017).
Figure 2
Evolution of ambulatory care spending
Type of spending 2016 2017 Percentage Contribution Share of Mean annual

change to growth spending (%) growth
(2016-17) (%) between
2006 and
2016 (%)
(in million €) (in million €)
Medical fees
General practitioners 5889 6054 2.8 8.1 8.4 2.6
Specialists 9677 10008 3.4 16.3 13.9 2.9
Midwives 228 248 8.6 1 0.3 10.4
Dentists 2762 2807 1.6 2.2 3.9 1.4
Allied health professionals’ fees

Nurses 5384 5631 4.6 12.2 7.8 8.1
Physiotherapists 3233 3325 2.8 4.5 4.6 4.6
Speech therapists 605 628 3.8 1.1 0.9 5.8
Orthoptists 67 70 4.1 0.1 0.1 6.2
Medical laboratories
Total 2899 2935 1.2 1.8 4.1 1
Health products
Drugs 19361 19595 1.2 11.5 27.2 1.4
Medical devices 5395 5614 4.1 10.8 7.8 6.9
Source: CCSS, 2018. Based on data from SHI (Caisse nationale de

l’Assurance Maladie, Régime général).

Regulation of prices in sector 2
Prices set by sector 2 physicians above the regulated tariff may

or may not be covered by CHI depending on the contract. This
means that for some patients, out-of-pocket payments to see a
physician may be too high, which raises concerns both on
equity of access to care and health care expenditure growth,
since unregulated prices could be highly inflationary. Therefore,
the SHI fund has introduced several regulatory mechanisms
and tools to control the prices in sector 2.
First, for emergency care and when patients are covered under
low-income schemes (couverture maladie universelle
complémentaire, CMU-C, or aide au paiement d’une
complémentaire santé, ACS), balance billing is not allowed.
These schemes are partly funded by the state with the
objective of reducing the burden of cost-sharing for these
populations. Sector 2 doctors have to charge national/
negotiated tariffs to patients with CMU-C and ACS.
Second, the social security code (Section L162-1-14-1) as well

as the medical code of ethics impose that balance billings have
to be a reasonable amount (tact et mesure). Until recently, there
was no regulatory or legislative definition of the term “tact et
mesure” or what is considered to be a reasonable amount. In
2012, under pressure from the SHI fund, the French national
medical council (Conseil national de l’ordre des médecins,
CNOM) recognized it as a fee exceeding three or four times the
regulated prices.
More recently, SHI introduced a new contract in order to

regulate prices charged by sector 2 physicians: “controlled tariff
option” (option de pratique tarifaire maîtrisée, OPTAM), which is
a yearly and optional contract. Physicians who choose this
contract commit to freeze their fees (at the average of the three
previous years) and not to charge more than double (100%)
the regulated tariff. They are also asked to perform a share of
their services at regulated tariff levels. In return, they receive a
bonus proportional to the share of their activity respecting the
rules. There is also an option with similar modalities for
specialists who performed at least 50 surgical or obstetrical
procedures/year in private practice or in hospitals (option de
pratique tarifaire maîtrisée chirurgie et obstétrique, OPTAM-CO).
In 2017, more than 12,000 doctors, representing close to 40%
of sector 2 contractors, have signed this contract (Foult, 2017).
Penalties exist for physicians who do not comply with the

requirements of their sector. They include an adjournment of
the payment of social contributions by SHI for physicians in
sector 1 or the adjournment of the right to extra bill for
physicians in sector 2.

A progressive shift towards value-based payment
While the existing system, based on collective negotiations, can

be considered as effective for controlling prices of services, it is
not entirely effective for assuring cost containment in the
ambulatory sector. Overall, between 2006 and 2016, physician
revenues have increased on average 2.8% annually, which is
largely above inflation based on the consumption prices/index
(Figure 2). Physicians appear to increase the volume of their
services for achieving a target income. Increasingly, the SHI
fund questions the value or quality of services provided with a
progressive development of value-based payments in primary
care. Given the high level of freedom of choice for patients,
supporting GPs as gatekeepers in the system to improve both
the quality and the efficiency of the care provision has been an
important pillar of reforms in the past decade.
Since the 2005 national agreement, GPs have committed to

improve the care coordination of their patients, promote
prevention and improve their patients’ prescription habits by
respecting guidelines, reducing the overall volume of
prescriptions and increasing generic prescriptions (which is
very low in France – see Figure 3). In return, they have
benefited from an increase in their consultation fees. However,
these objectives were non-binding for individual physicians
and have therefore had limited impact on GPs’ practice.
Therefore, in 2009, SHI introduced P4P contracts for improved
individual practice (contrats d’amélioration des pratiques
individuelles, CAPI) for GPs in an attempt to enhance and
support the quality of primary care and more efficient
prescribing. The development of these contracts was facilitated
by the 2004 reform introducing the preferred doctor scheme,
which enabled the identification of a patient list per physician.
The contracts, initially proposed to primary care physicians and
signed on a voluntary basis by individual GPs, had the same
objectives in terms of improving clinical quality of care and
encouraging prevention and generic prescription, but did not
alter the existing FFS scheme. Participating physicians received
additional remunerations on top of their normal FFS income if
they met the targets set: up to €7000 annually if all targets
were achieved or proportionally to their progress if objectives
were not fully achieved (Bousquet, Bisiaux and Ling Chi, 2014).
Despite a lack of evaluation of the impact on outcomes and
costs, SHI decided to extend the scheme. It was generalized to
all GPs in the 2011 national agreement, which stipulated that
the payment of primary care providers could be related to their
performance. The P4P scheme was renamed “the payment for
public health objectives scheme” (“rémunération sur objectifs de
santé publique”, ROSP) and extended to other physicians.

Figure 3
Market share of generic drugs in selected countries
France
Norway
Italy
Spain
Finland
UK
Germany
Netherlands
0 10 20 30 40 50 60 70
Generics as a percent of market share
2011
2015
This P4P scheme represents a significant change in paradigm,

as this new P4P scheme has officially replaced the traditional
increase in the FFS tariffs, which were regularly obtained by
physicians without being accountable individually for their
results. This new scheme has been progressively extended to
specialists, starting with cardiologists, gastroenterologists and
endocrinologists, and now covers all physicians who signed the
national collective agreement of 2016. However, physicians are
allowed to opt out by writing to their local health insurance
fund in the three months following the national collective
agreement (Union nationale des caisses d’assurance maladie et
al., 2016). There are 29 indicators in the latest version of the
ROSP scheme (25 are calculated from the claims data and four
rely on physicians’ own statements). Initially the list included
structural indicators (mostly related to organization of the
office practice), but they now only focus on medical practice in
three areas: prevention (for instance counseling for smoking
cessation or vaccination) and screening (in particular for
cancer); follow-up of chronic disorders (such as the follow-up of
cardiovascular risk); and efficiency of drug prescriptions (with
the objective of reducing inadequate prescribing and
increasing generic prescriptions) (CNAM, 2018c). Indicators can
vary according to the type of doctor involved (GP for adults or
children, cardiologist, gastroenterologist or endocrinologist).
Targets are fixed during the national collective negotiations
between the stakeholders based on national good practice

guidelines or taking the average practice as baseline if there is
no such guideline. There is no penalty for physicians who do
not reach the targets.
It is difficult to make a conclusion on the cost efficiency of the

P4P scheme in France since there is no proper evaluation of the
reform. The national health insurance fund reports some
improvements, in particular, concerning colorectal cancer
screening and antibiotics prescription. However, it is difficult to
disentangle the effect of the scheme from other programs
introduced recently to improve the quality of care such as
national awareness campaigns for cancer screening. The total
annual cost of the ROSP scheme reached €250 million in 2017,
with the average annual sum earned through that scheme
reaching €4522 for GPs, €1726 for cardiologists and €1436 for
gastroenterologists (CNAM, 2018c). While the introduction of
ROSP appeared to be cost-neutral initially, with slower
increases in prices and volumes, it is not clear yet what will be
the impact of the latest increases in tariffs on overall
expenditure. Therefore, while there has been a progressive shift
towards more value-based payment with an annual growth rate
of 9.1% in SHI spending dedicated to P4P between 2012 and
2016 and an increased number of physicians covered by P4P
schemes, this still represents a small part of physician income
(Figure 4).
In the 2016 national collective agreement with physicians,

structural indicators previously including the ROSP scheme
became part of a specific bundled payment for all physicians
whatever their medical specialty. The bundle is divided in two
parts: one for improving the organization of office practice (in
particular the development of electronic records), and the other
for providing better services to patients (such as participation
in training, patient education, etc.; see Annex for the list of
indicators used). Physicians earn a bundled payment, which can
reach up to €1750 yearly, if they meet all the indicators. The
total bundle is expected to increase to €4620 over 2019-2020
(CNAM, 2018b).

Figure 4
Share of P4P in GP revenues: evolution between 2008 and
2017
8000
7000
6000
5000
Millions of EUROs
4000
3000
2000
1000
0
2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
Consultations and visits Capitation

Over-billing for consultation and visits P4P
Medical procedures
Source: DREES, 2018.
Setting fees for medical ambulatory procedures
Medical ambulatory procedures are funded on a FFS basis

similarly to consultations and are also subjected to the same
regulations of over-billing. They account on average for about
50% of the fees (revenues) received by private providers
(CNAM, 2018a). However, since 2005, the prices of ambulatory
procedures have been valued separately from consultations.
The first step was the creation of a French classification of
medical procedures (classification commune des actes médicaux,
CCAM) defining the estimated time and costs of performing
each procedure in order to assign a tariff. This classification has
been developed during nearly a decade. The objective was to
promote equitable fees for medical procedures for all doctors
and between different specialties in order to avoid the
selection of procedures based on their profitability (Bras,
Vieilleribiere and Lesteven, 2012).

CCAM currently covers more than 8000 medical procedures
and includes imaging procedures, technical medical procedures
(such as diagnostic procedures), surgical, obstetrical and dental
procedures as well as procedures of anatomo-cytopathology.
Each act is hierarchized according to a methodology partly
based on the Resource-Based Relative Value Scale (RBVRS)
developed in the US for physician services (Hsiao et al., 1988).
The tariff of each medical act in CCAM is calculated by adding
an estimated cost related to medical work (coût du travail
medical) to an estimated cost related to office practice (coût de
la pratique). The cost related to medical work is expressed as a
global score (score travail) and takes into account the effort to
perform the procedure (time, stress, mental effort and technical
skills) for a regular patient. This score is converted into a
monetary value in euros by setting a conversion factor. Its value
is set in the national collective agreement between UNCAM and
health professionals, similarly to consultation tariffs. The costs
related to medical practice cover structural costs supported by
health professionals (staff, rent, social contributions, etc.) in
each medical specialty (Bras, Vieilleribiere and Lesteven, 2012).
This complex system for fixing the prices of medical procedures

has faced several difficulties. First, strong pressure from the
unions of health professionals resulted in a situation where
tariffs set for new procedures via this classification were never
lower than the previous ones even when the cost scale from
the classification suggested lower tariffs. Second, there has
been no regular update of the estimated costs to take into
account evolutions in medical practice and technology over
time, except for imaging procedures. Third, the number of
medical procedures considered in France appears important in
comparison to other countries (for instance more than 8000 vs.
5200 in the current revision of the Australian classification of
medical procedures) (Task Force “Réforme du financement du
système de santé”, 2019). In 2016, the national collective
agreement decided that CCAM should be revised. A new
commission is now in charge of grading medical procedures
within CCAM and reducing the delays in registration of new
procedures (Union nationale des caisses d’assurance maladie,
2016).

3
Price setting for drugs and medical devices
Setting prices of drugs and medical devices used in

ambulatory settings
The prices of drugs and medical devices are regulated through

multiannual framework agreements between the state, which is
represented by the Economic Committee for Health care
products (Comité économique des produits de santé, CEPS), and
the pharmaceutical industry since 1994 (Grandfils, 2008). The
agreement defines common objectives for market trends (in
terms of expenditure) as well as price setting mechanisms. The
latest agreement was signed in 2016 for three years. In the
frame of this agreement, prices of drugs are negotiated
between each pharmaceutical company and CEPS. Prices are
re-evaluated every five years according to similar modalities.
The main elements that are taken into account in the
negotiations include the added therapeutic value of the drug
(amélioration du service médical rendu, ASMR), which is
measured in comparison to the clinical benefits of existing
drugs or therapies in the market and varies from 1 (the highest
added therapeutic value) to 5 (the lowest therapeutic value), as
well as its cost-effectiveness (since 2012), as assessed by the
National Health Authority (Haute autorité de santé, HAS). In price
negotiations, the prices of other drugs with the same
therapeutic objective and the expected or observed volumes of
sales are also taken into account. If there is no agreement
between the two parties, CEPS sets unilaterally the price of
drugs, but pharmaceutical companies benefit from some
guarantees for drugs with a significant clinical added value. For
drugs with an added value of 1, 2, 3 or in specific cases 4, the
price set cannot be lower than the price in four reference
European markets (Germany, Spain, Italy and the UK). This
guarantee is to make France an attractive location for the early
marketing of innovative drugs (Cour des comptes, 2017).
The price of a drug is set before the decision to include it (or

not) in the public benefit package. To be reimbursed by the SHI
fund, drugs have to be evaluated and registered in a positive
list (liste des spécialités pharmaceutiques remboursables). The
prices are defined by the Ministry of Health based on the
advice from HAS and CEPS, while the reimbursement rate
(65%, 30%, 15% or 0%) is defined by the SHI fund based on
the therapeutic value of the drug (service médical rendu, SMR).
SMR is assessed by HAS and takes into account the severity of
the illness targeted by the drug, its effectiveness, its impact on
public health and its side effects with regards to all other drugs
or treatments targeting the same health condition. Traditionally,
complementary insurance funds covered the remaining costs
for patients of any reimbursed drug. Since 2012, the SHI fund
encourages (with tax returns for responsible contracts) the CHI
funds to reimburse only the cost of drugs with a major and
important SMR, but the coverage of costs by CHI varies
significantly depending on the type of contract chosen by the
beneficiary. For drugs reimbursed by SHI, the price set by CEPS
serves as a basis for reimbursement, while the prices of drugs
that are not included in the benefit package are not regulated.
Between 2008 and 2017, the prices of drugs not reimbursed
increased by about 20%, while the prices of drugs on the
positive list (reimbursed) dropped by about 30% (Figure 5).
Figure 5
Trends in drug prices over time (Price in 2008=100 as
reference)
130
Non-reimbursed drugs
120
110
Year 2008=100
100
90
80 All drugs
70
Reimbursed drugs
60
2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
Therefore, this price setting mechanism in France appears to be

successful, since drug prices in France are relatively low in
comparison with other OECD countries (Figure 6).

Figure 6
Drug prices for the 30 most commonly prescribed drugs,
2006–2007
1.0
Drug prices relative to the price in the USA (=1)
0.8
0.6
0.4
0.2
0.0
USA Canada Germany Switzerland UK Australia Netherlands France New Zealand
Source: Commonwealth Fund, 2019. Note: USA prices are set as reference
at 1.0
Definition of prices of pharmaceuticals and medical devices

used in hospitals
The prices of hospital drugs were set freely via negotiations

between pharmaceutical companies and individual hospitals
without any regulation until 2004. Therefore, the same drug
could have different prices in different hospitals depending on
the hospital’s negotiating power. With the introduction of
activity-based payment (ABP), most drugs are now included in
the tariffs of the diagnosis-related groups (DRG). While their
price is not directly regulated and is still negotiated between
the pharmaceutical industry and hospitals, drugs are
reimbursed to hospitals by the health insurance fund in the
limit of a maximum fixed tariff (tarif de responsabilité), which
becomes in practice the regulated price. This tariff is set
according to modalities similar to those used to set the prices
of drugs in the ambulatory sector (through the involvement of
CEPS).
Furthermore, there are some specific measures for regulating

the costs of very expensive and innovative drugs. Their
significant cost relative to DRG tariffs as well as the need for
assuring quick access to innovation justified the development
of a list of drugs for which payments are made on top of DRG
tariffs. These drugs (mostly for cancer) are included on a
specific list (liste des médicaments facturables en sus des
prestations d’hospitalisation) based on strict criteria (a strong

added therapeutic value of the drug, a cost superior to 30% of
the DRG tariff, and an indication for less than 80% of the
patients included in the DRG). A specific targeted budget for
this list of drugs is set in ONDAM, and the prices of these drugs
are regulated via negotiations between each pharmaceutical
company and CEPS mainly using European prices (in Germany,
Italy, Spain and the UK) as a reference. While this procedure has
been created as a temporary option for funding innovation
(once a drug is part of regular treatment, it should be included
in the DRG tariff), in practice the number of exclusions from the
list overtime is low (Gandré, 2011).
Expenditure for these drugs and devices has increased by

almost 20% between 2011 and 2015 (18.5% for drugs and
23% for medical devices) to reach €4.8 billion (5.3% of total
hospital care spending). Rising spending is mostly driven by the
public sector and by drugs for the treatment of cancer and
autoimmune diseases. While there were 150 drugs on the list
in 2015, 10 drugs accounted for two thirds of the total
expenditure associated to the list (DREES, 2017).
4
Price setting for acute hospital care
Hospital context
The French hospital sector is characterized by a high number of

public and private providers. Patients can freely choose
between them without a referral. While 90% of the hospital
expenditure is funded through public health insurance, one
third of this expenditure occurs in private-for-profit hospitals.
Public hospitals represent 60% of hospitals and 65% of all

acute inpatient beds. They have the legal obligation of ensuring
the continuity of care, which means providing 24-hour
emergency care, accepting any patient who seeks treatment,
and participating in activities related to national/regional
public health priorities. The private-for-profit sector represents
25% of all inpatient beds, but 45% of surgical beds. The
market share of private hospitals depends heavily on the type
of hospital activity: more than half of all surgery and one fourth
of obstetric care are provided by private-for-profit hospitals.
Their market share goes up to more than 80% in some areas of
elective surgery, such as eye surgery (cataract in particular), ear
surgery, and endoscopies. In contrast, certain complex
procedures are carried out almost exclusively by public
hospitals, for example in the case of burn treatments (92%) or
treatment of patients with surgery of serious multiple trauma
(97%).
Until 2004, public and private hospitals were paid under two
different schemes. On the one hand, public and most private
not-for-profit hospitals had global budgets mainly based on
historical costs, making little adjustment for hospital efficiency.

On the other hand, private for-profit hospitals had an itemized
billing system that was inflationary with daily tariffs covering
the cost of accommodation, nursing and routine care, and a
separate payment based on the diagnostic and therapeutic
procedures carried out, with separate bills for costly drugs and
medical devices. In addition, doctors working in private
hospitals are paid on a FFS basis unlike those working in public
hospitals who are salaried.
The difference in payment between public and private

hospitals has always been a subject of conflict. Public hospitals
considered global budgets as an instrument of rationing, which
strangled the most dynamic hospitals and was insensitive to
changing demand. Private hospitals advocated that global
budgets rewarded inefficiency and fair benchmarking; they
believed that they would be more efficient and increase their
market share under activity-based payment. Therefore, the
introduction of ABP (tarification à l’activité, or T2A in French) in
20053 to pay for acute hospital services was very welcomed
initially. The major objectives of ABP were to increase hospital
efficiency, to create a ‘level playing field’ for payments to public
and private hospitals, and to improve the transparency of
hospital activity and management. The initial objective of
shifting to ABP for funding rehabilitation facilities and
psychiatric hospitals has been postponed several times due to
difficulties in implementation and problems faced in the acute
sector.
Price setting in acute care hospitals: the DRG payment model
Under ABP, the income of each hospital is linked directly to the

number and case-mix of patients treated, which are defined in
terms of homogeneous patient groups (called GHM in French,
Groupe Homogène de Malades). The classification system used
in France was inspired initially from the US Health Care
Financing Group classification (HCFA-DRG) but adapted to the
French system and modified regularly over the years. The GHM
classification has changed three times since the introduction of
T2A, passing from 600 groups in 2004 to 2680 today (in 2018).
The current version (version 11), introduced in 2009,
significantly complicated the classification with four levels of
case severity applied to most GHM, using information on length
of stay (LOS), secondary diagnoses and age.
The institution responsible for developing the patient

classification system and calculating prices is the Technical
Agency for Hospital Information (Agence technique de
l’information sur l’hospitalisation, ATIH). ATIH was created in
2002 and is an independent public administrative institution
co-funded by the government and public health insurance
funds. It has an advisory committee, involving representatives
of public and private health care facilities, which make
suggestions based on their experiences with the system.
3 Implemented progressively in the public sector between 2004 and 2008.

Definition of GHM tariffs
The information for calculating prices (reference costs) comes

from the hospital cost database (Etude nationale de coûts à
méthodologie commune, ENCC), which provides detailed cost
information for each hospital stay from voluntary hospitals.
Until 2008, the cost database covered only 3% of public and
private non-for-profit hospitals (about 40). The number of
participating hospitals has increased slightly since 2008. In
2018, the ENCC covered 135 hospitals (of which 52 are private-
for-profit) (ATIH, 2017).
GHM reference costs are updated annually by ATIH on the basis

of information from the hospital cost database. However, there
is always a time lag of two years between the year of the data
and the year of the price application in hospitals. For example,
hospital costs data from the years 2013, 2014, 2015 (three-
year average) were analyzed during the year 2016 in order to
define GHM prices for hospital payments in 2017.
GHM prices (tariffs) are set at the national level based on

average reference costs by GHM calculated separately for
public and private hospitals. Therefore, there are two different
sets of tariffs: one for public (including private-non-profit)
hospitals and one for private for-profit hospitals. Moreover,
what is included in the price differs between the public and
private sectors. The tariffs for public hospitals cover all of the
costs linked to a stay (including medical personnel, all the tests
and procedures provided, overheads, etc.), while those for the
private sector do not cover medical fees paid to doctors (who
are paid on a FFS basis) or the cost of biological and imaging
tests (e.g. scanners), which are billed separately. The initial
objective of achieving price convergence between the two
sectors started in 2010 on about 40 GHM (highly prevalent
both in public and private hospitals) and pursued until 2012,
but was abandoned afterwards against fervent critics from
public hospitals (where the tariffs are higher).
In principle, GHM prices are not adjusted to take into account

“unavoidable variations” in the cost of delivering services, but
public hospitals (and private hospitals participating in so-called
‘public missions’) receive additional bundled payments to
compensate for costs linked to education, research and
innovation related activities (MIGAC) and some public missions
(activities of general public interest such as investing in
preventive care, outreaching to under-privileged populations,
etc.). Hospitals can also receive funding from regional health
agencies (agences régionales de santé, ARS) to finance
investments for quality improvement. The costs of maintaining
emergency care and related activities are paid by fixed yearly
grants, plus a FFS element taking into account the yearly
activity of providers. Finally, a restricted list of expensive drugs
and medical devices is paid retrospectively, according to the
actual level of prescriptions made.
The actual prices per GHM are not exactly equal to reference
costs. They are determined by the Ministry of Health taking into
account the overall budget for the acute hospital sector
(ONDAM target expenditure) and public health priorities. In
order to contain the level of hospital expenditure, national-
level expenditure targets for acute care (with separate targets
for the public and private sector) are set by the Parliament each
year. If the actual growth in total hospital volume exceeds the
target, prices go down the following year. The growth of activity
volumes is not regulated at the individual hospital level but at
an aggregate level (separately for the public and private sector).
Prices have been adjusted downwards quite regularly since
2006, since the hospital activity volumes have been increasing
consistently faster than the targets set. Furthermore, GHM
reference costs (“raw” tariffs) are modified in an opaque way to
integrate various objectives set by the government and the SHI
fund each year when computing actual prices. For example, in
2009, ATIH noted that GHM prices were modified to adjust for
the increase in the additional budgets for specific ‘missions’,
including education, research and innovation related activities,
the growth of expenditures for additional payments on
expensive drugs, and national priorities (for cancer treatment
and palliative care) as well as the evolution of overall activity
volumes. However, it is not entirely clear how these different
elements influenced the prices of different GHM.
Globally, this mechanism appears to be successful in containing

overall hospital expenditures, since the share of hospital
expenditures in total expenditure growth has decreased visibly
since the introduction of ABP (Figure 7). In recent years
(2014/15), the hospital sector managed even to underspend
with respect to the target set by ONDAM. However, this macro-
level regulatory mechanism has its downsides (Or, 2014). It
created an opaque environment where it became very difficult
for hospitals to predict their budget situation for the next year,
since prices change every year as a function of overall activity.
The lack of information on the specific objectives pursued with
the payment policy also created frustration and resentment
about T2A at the provider level. In the absence of clear price
signals and lack of cost data for benchmarking hospitals,
providers appear to be concerned mainly on balancing their
accounts by increasing their activity.

Figure 7
Annual percentage increase in hospital expenditures
4
Percent annual growth
2000/05 2006/07 2007/08 2008/09 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17
Despite a positive trend in productivity of public hospitals

since 2004, with a strong rise in case-mix weighted production,
there is also evidence of patient selection with increased
specialization in the private sector and induced demand for
some types of surgery (Or et al., 2013; Studer, 2012). Moreover,
external controls carried out by SHI to identify “unjustified”
billing of services show that up/incorrect coding was an issue,
at least in the initial years of ABP. Between 2006 and 2009,
three quarters of hospitals were audited at least once, and,
among these, half were audited more than once. In 2006, more
than 60% of inpatient stays (more than 80% for ambulatory
episodes) had some kind of coding error or inconsistency in
procedures billed (CNAM, 2009). If up-coding or incorrect
coding is detected, hospitals have to reimburse received
payments. In addition, they may have to pay financial penalties
which can go up to 5% of their annual budgets. The revenues
recovered from these penalties amounted to €51 million in
2008 and €23 million in 2010 (Daudigny et al., 2012). Overall,
DRG-based payment addressed some chronic problems
inherent to the French hospital market and improved the
overall transparency of information concerning hospital
activity. Nevertheless, it also created its own problems.

Figure 8
Hospital expenditure growth: Price versus volume effect
Public sector Private sector

5 5
4 4
3 3
2 2
In % increase
1 1
0 0
-1 -1
-2 -2
2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
Volume
Price
Today, it is largely recognized that ABP provides incentives to

develop hospital activity, sometimes beyond what is medically
necessary, raising questions about the appropriateness of
hospitalizations for certain procedures and conditions (Figure
8). A survey of the French Public Hospital Association showed
that, according to hospital physicians, one-quarter of the
procedures and medical tests carried out in hospitals were
medically unjustified (Fédération hospitalière de France, 2012).
Furthermore, there is a growing consensus that ABP does not
favor cooperation between different providers or between
different services within the same hospital to assure care
coordination and a holistic approach in care provision.
In 2016, a quality-based payment scheme (Incitations

financières à l’amélioration de la qualité, IFAQ) was introduced to
encourage investment in quality. A modest proportion of
providers’ income is linked to the achievement of nationally set
objectives concerning a battery of quality indicators (mostly of
care process and structure/organization, but also patient
satisfaction in 2018). The IFAQ payment framework can cover
up to 1.5% of a hospitals’ annual income, and this percentage
is expected to increase in coming years. The current
government is also planning to reduce the share of ABP in
hospital payment, with several propositions for bundling
payments beyond acute hospital reimbursement (especially for
chronically ill and multi-morbidity patients) and including

rehabilitative services. However, this may be more difficult to
bring about than initially thought due to the lack of robust cost
data across providers.
Using prices to regulate hospital activity
In parallel, DRG tariffs are used increasingly to influence

hospital activity and incentivize better practice. In two areas,
prices were used actively: for developing ambulatory surgery
and for controlling caesarean section rates. The prices of
ambulatory stays are aligned with non-complicated overnight
stays for most common procedures in order to encourage
hospitals to invest in ambulatory surgery. Increasing
ambulatory surgery rates has been a long-term objective for
the hospital sector, but it is only recently, since 2011, with price
adjustments that rates have been picking up (from 44% in
2011 to 54% in 2016). As for caesarean sections, tariffs for
uncomplicated programmed caesarean sections have been kept
relatively low in recent years to make sure that the profit
margins for these operations are very low. Currently, there is
some discussion on identifying other areas where financial
incentives may support good practice or on sanctioning
unwarranted hospitalizations.
Since 2014, the Ministry of Health has introduced a volume-

price control mechanism at the individual hospital level. For a
number of high volume/fast growing DRGs (including knee
prosthesis and cataract surgery), the Ministry sets a national
rate of activity growth. If a hospital’s case load (for a given DRG)
grows faster than the threshold set, the tariff of the concerned
GHM goes down by 20% for the hospital. There is not enough
information on the impact of this policy on hospitals, but a very
recent note from the Ministry of Health announced that there
will be further measures for reducing interventions considered
as “low value” care.
Payments for acute psychiatric hospital care
The ABP system has not been extended to acute psychiatric

hospital care. This is related to the difficulties in establishing a
diagnosis for mental health problems, the diversity in the forms
of psychiatric care provided, and the historical territorial
organization of mental health care in France. In addition, there
is no conclusive experience of the DRG-based payment system
for acute mental health care abroad (Denk et al., 2011; Wolff et
al., 2015; Lin et al., 2016; CNAM, 2018d). The psychiatric care in
public and non-profit hospitals is therefore funded through an
annual prospective global budget which is paid by SHI and
allocated by regional health agencies on the basis of historical
costs adjusted by the expected annual growth rate of hospital
spending. The global budgets are defined in the frame of
ODAM, which is a sub-objective of ONDAM for hospitals not
funded through the activity-based model (Cour des Comptes,
2011). These global budgets include capital investments which
do not benefit from specific dedicated funding. Payments to
for-profit hospitals are based on predetermined daily rates
fixed according to the type of care provided (for instance
full-time or part-time hospitalization). These rates are adjusted
yearly at the regional level by the ARS in line with the national
expenditure targets set by ONDAM for hospital care (Cour des
Comptes, 2011).
Many successive institutional reports have criticized these

funding mechanisms for acute psychiatric hospital care and
suggested a global reform of the payment model (Piel and
Roelandt, 2001; Cour des Comptes, 2011). Planned evolutions
include an adjustment of the global budgets for public and
non-profit acute psychiatric hospitals on the characteristics of
the population served, including their socio-economic
characteristics, from 2019 onwards. Adjusting budgets on
indicators of quality of care, similarly to what is done for acute
care hospitals, and harmonizing the payment models of the
public and private for-profit sector are also listed as future
reforms by the government (Task Force “Réforme du financement
du système de santé”, 2019).
5
Price setting for rehabilitation and long-
term care (LTC)
Inpatient rehabilitation services
Rehabilitation in institutions (soins de suite et de réadaptation,

SSR) were funded until 2017 based on a model similar to the
one for acute psychiatric hospital care through an annual
prospective global budget for public and private non-profit
hospitals and through a daily fixed rate for private for-profit
hospitals. Since 2017, the global budgets have been adjusted
to take into account the volume and case-mix of the patients
treated. Since 2010, a patient classification system applying the
logic of homogeneous medical resource groups as in DRGs has
been used. There are about 750 groups called GME (“groupes
médico-économiques”) for services provided in these
institutions. Reference costs for different groups of patients
have been estimated and updated annually by ATIH. The
process of fixing these reference costs is similar to the one for
the DRG tariffs in acute care based on a cost database of a
sample of voluntary hospitals (see section 4.2). Since March
2017 (i.e. seven years after the development of the first
classification and costs in SSR), the funding of rehabilitation
facilities has been mixed: 90% of the funding is calculated by
former modalities (global budget or fixed daily rate), while 10%
is activity-based using GME as reference tariffs.
Long-term residential care for elderly
Older people who need medical attention or help with the

activities of daily living if they cannot live alone at home are
looked after in facilities which are medical nursing homes for
dependent elderly people (Etablissement d’hébergement pour
personnes âgées dépendantes, EHPAD). The public funding of
these facilities comes mainly from SHI concerning the cost of
health care and from local authorities (départements) and the
national fund for autonomy (Caisse nationale de solidarité pour
l’autonomie, CNSA) to finance personal and social care.
The overall amount for residential care funded by SHI is set

annually by a ministerial order. It corresponds to the medico-
social fraction of the national health insurance expenditure
target (ONDAM). This amount was about €9 billion in 2017 for
the long-term care of the elderly. This funding is entrusted to
CNSA, which is responsible for redistributing the funding to the
ARS. The mission of ARS is to regulate the supply (authorization
to open a facility, number of places, etc.), control the quality of
care, and negotiate the health care portion of the funding in
nursing homes.
Historically, the budget was negotiated according to the volume

objectives of facilities and on the basis of past expenditures. In
recent years, there has been a shift from cost-based funding to
payments-based funding on the activity and characteristics of
the care recipients. Today, facilities for dependent older people,
whether private for-profit, private non-profit or public are paid
by a three-part tariff: a care package, a long-term care (or
dependency) bundle and an accommodation fee (Bonne, 2018).
The care package, financed by the SHI fund, is calculated for

each facility according to a synthetic indicator, called the
ISO-weighted care group (GMPS), which corresponds to the
average care needs and dependency level of people living in
the facility. Care needs are measured by the coordinating
doctor of the facility4 using a classification called “pathos”,
which identifies 50 clinical conditions with 12 profiles of care
required by these conditions constituting 238 couples of
“condition-profiles” (CNSA, 2017). For each of these condition-
profiles, eight resource groups were identified (physician,
psychiatrist, nursing, rehabilitation, psychometrics, biology,
imaging and pharmacy), which define the level of care
resources required. For health professionals, this corresponds,
for example, to the time required for patients with a given
profile. The average resource level required for each of the 238
couples was defined by specialists (geriatric physicians) and
reported in terms of points per cost item. For example, for the
couple “heart failure” with the profile “close monitoring”, the
specialists estimated that it requires 13 minutes of geriatrician
time a day, 36 minutes of nurse time, etc. The average pathos
score (PMP) is the sum of the points of care required in eight
resource groups weighted by a coefficient depending on
resource groups expressed on average per individual. The care
bundle is also adjusted by the dependency level, which is
calculated by the AGGIR (Gerontology Autonomy and Iso-
Resource Groups) model, which assesses the autonomy of a
person for carrying essential daily activities (CNAM, 2008). The
dependency score (GIR) is based on 10 variables of physical
4 This evaluation has to be validated by two other external medical doctors appointed by
the local county (département) and the regional health authority.

and mental activities (coherence, orientation, toilet, dressing,
food, etc.) and seven variables of domestic and social activities
(cooking, household, transport, etc.).
The amount of care payment for each facility is the average

GMPS score5 multiplied by the value of the point. The value of
the point is defined by the Ministry of Health (at the national
level) based on ONDAM for medico-social facilities.
The long-term/dependency bundle finances the care provided

to the most dependent residents in helping them with the
activities of daily living (cost of the caregivers). It is calculated
according to the GMP (average GIR score) of the facility and the
value of the departmental GIR point fixed by the county council
(Conseil départemental). The value of the departmental GIR
point, that is, the level of funding by the département, varies
greatly between départements, ranging from €5.7 in the Alpes-
Maritimes to €9.4 in the South of Corsica in 2017 as a function
of local policy and income.
Accommodation fees are paid entirely by the residents. The

rates vary depending on the “standing” of the facility (comfort
of the rooms, quality of the cooking, etc.), but also on the
agreement of the facility to receive social/public aid. Only
private for-profit facilities are completely free in setting the
accommodation prices, because the majority of non-profit
facilities, whether private or public, are eligible for public
support and cannot ask for a higher accommodation price than
the one set by the département (based on past declared costs
by the facilities).
For dependent elderly people living at home, medical and

social care services are generally provided and paid separately.
Health care is financed on the basis of prices fixed by the SHI
fund with a fee for visits, procedures and medical devices with
the possibility of balance billing. The personal and social care
services (help with daily living, meals, etc.) are offered by the
public, private or associative sectors. Prices are not regulated
and vary according to supply and demand. There is, however, a
reference tariff used by départements to calculate the amount
of the financial aid (APA) for dependent older people (not mean
tested, but depending on the “need” evaluated by the
département using the grid GIR assessing autonomy). These
reference rates vary from one département to another from €13
to €24 per hour. The nursing care at home is mostly provided
by self-employed FFS nurses who are paid based on prices set
by the SHI fund.
5 The GMPS score of a facility is the average pathos score (PMP) plus the average GIR score
of all residents.

Annex 1
Indicators taken into account for bundled
payments to physicians
Section 1: organization Availability of a software certified by the

of office practice national health authority to help with
prescriptions and compatible with shared
electronic medical records
Availability of a secure health messaging

service
Display of practice hours in the health directory
Availability of the latest version of software

(Sesam-Vitale) for billing electronically
Rate of electronic transfers superior or equal to

2/3 of all consultation/prescription forms
issued
Section 2: involvement Capacity to code medical data

in services for patients
within the office Involvement in coordinated care pathways
practice
Specific services offered to patients
Management and training of medical students
Rate of dematerialization reached on a number

of teleservices

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Case study
Germany
University of Hamburg
Germany
89
Germany
Abbreviations91
Abstract92
1 Introduction 94
2 Governance of the health care sector 98
3 Price setting and budgeting by the

health care sector 100
The inpatient sector 100

Primary care and outpatient specialist services 109
Reimbursing outpatient services:
Statutory Health Insurance 111
Contents Reimbursing outpatient services:
Private Health Insurance 118
3 Conclusions 125
References 129

Abbreviation German original (if English translation
applicable)
BÄK Bundesärztekammer German Medical

Association
DKG Deutsche German Hospital
Krankenhausgesellschaft Federation
DRG Fallpauschale Diagnosis-related group
FFS - Fee-for-service
gkv- Spitzenverband Bund der National Association of

Spitzenverband Krankenkassen Statutory Health
Insurance Funds
GP Hausarzt General Practitioner
(Family Physician)
InEK Institut für die Institute for Hospital
Entgeldvergütung im Reimbursement
Krankenhaus
Abbreviations KBV Kassenärztliche National Association of
Bundesvereinigung Statutory Health
Insurance Physicians
KHSG Krankenhausstrukturgesetz Hospital Structure Reform
Act
KV Kassenärztliche Association of Statutory
Vereinigung Health Insurance
Physicians
LTC - Long-term care
PKV-Verband Verband der Privaten Association of Private

Kranakenkassen Health Insurance Funds
PHI Private Private Health Insurance
Krankenkversicherung
P4P - Pay for Performance
SHI Gesetzliche Statutory Health

Krankenversicherung Insurance

The German healthcare system features high levels of provision
of care and a rigorous price-setting process which limits
expenditure increases. The three investigated sectors (inpatient
and outpatient sectors and long-term care), however, feature
substantively different characteristics. The budgeting of health
services, for example, ranges from no budgeting at all (private
health insurance (PHI) outpatient sector) via budgeting on an
individual level (inpatient sector) to budgeting on a state level
(statutory health insurance (SHI) outpatient sector). This makes
Germany an interesting, but fragmented and complex case
study.
Germany pairs generous levels of supply of providers with

reimbursement systems that set incentives on high volumes
and low waiting times, and low prices compared to other OECD
countries. This achieves low waiting times and high service
volumes at the expense of overprovision and wasteful
spending. Germany features far higher densities of providers
Abstract per inhabitants than other OECD countries with twice as many
hospital beds per 100 000 inhabitants than the OECD average.
It ranks in the upper third of OECD countries in terms of
physician and nursing home densities per 100 000 inhabitants.
The country reimburses inpatient providers almost exclusively
on the basis of DRGs, outpatient specialists largely on the basis
of fee-for-service (FFS), outpatient general practitioners by a
combination of FFS, budgets and other modes of
reimbursement, and nursing homes on a per-diem basis.
The healthcare system is largely governed by associations of

payers and providers on the federal, state and regional level. In
selected sectors, however, competencies are assumed by or
shared with the legislature. The planning, budgeting and
reimbursement of the inpatient and outpatient sectors and
long-term care are strictly separated. Furthermore, Germany
features an SHI system, which insures roughly 90% of the
population and a PHI system, which covers the remainder.
The price-setting in the inpatient sector and the SHI‘s

outpatient sector follows the federal structure of this country.
In both sectors, prices are calculated by a joint institute of
payer and provider associations on the federal level. States can
deviate from federal prices within a predefined range. In the
long-term care sector, prices of nursing homes are negotiated
on an individual level and benchmarked with the price-level of
their neighbouring homes.
Services in the inpatient sector are budgeted on an individual

level between a hospital and sickness funds which insure more
than 5% of the hospital’s patients. Services in the SHI’s
outpatient sector are budgeted on the state level and broken
down to the individual physician. In contrast, services in the
PHI’s outpatient sector are not budgeted.

Germany still enjoys a positive GDP growth rate and solid
finances. As a result, financial sustainability and cost
containment have been and still are less of a concern than in
other OECD countries. Attempts to reduce the number of
providers, most notably of hospitals, have fallen short. As of
today, the country joins other OECD member states in its quest
for integrated care and quality of care. Several reforms are
under way. In 2016, the country has introduced a
comprehensive reform of the inpatient sector to improve
quality of care, to reduce hospital volumes and to redistribute
financial flows in a more adequate way. This reform makes an
attempt to reorganize the governance structure by subtly
shifting competencies to the federal level in exchange for a
large financial benefit package. Discussions on harmonizing the
SHI and PHI outpatient reimbursements and on improving the
integration of the inpatient and outpatient sector systems have
been started.

1
Introduction
In 2017, health care expenditures amounted to €374.2 billion
(OECD, 2018a). This represented 11.3% of the country’s GDP.
Over the past two decades, expenditures have increased by
80% from about 200 billion in 2000 (see Figure 1) (OECD,
2018a). The annual increase has ranged between -0.3% and
5.3% with an average annual growth rate of 4% over the past
decade (Figure 2). Over the same time, the GDP share has
increased by 1.5 percentage points from 9.8% in 2000.
Despite high variability in the first decade of the 21st century,
the GDP share has stabilized at an annual growth rate of about
1% since 2012.
Figure 1
Total health expenditures in current prices and price-indexed
(2000=100) from 2000-2017
400 200
350
300 150
250
Percentages
€ billions
200 100
150
100 50
50
0 0
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
Total health expenditures (in billion, current prices)

Total health expenditures (indexed)
Source: OECD, 2018a.

Figure 2
Changes in total expenditure, per capita expenditure and GDP
share (2001-2017)
10
4
Changes in %
-2
-4
2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
Change in per capita expenditure (current prices)

Change in total expenditure (current prices)
Change in % of GDP
Source: OECD, 2018a.
Germany is split into a SHI and a PHI system
Germany’s health system is split into a statutory health

insurance (SHI) system, which enrols 90% of the population
(72.81 million), and a private health insurance (PHI) system,
which insures the remainder (8.77 million). PHI provides full
coverage to employees whose income ranges above a pre-
defined threshold (in 2019, annual gross income of €60 750
or greater) and the self-employed. In addition, it partially
insures civil servants with a residual PHI ranging between
20% and 50%.
In 2017, the SHI system spent €233.89 billion on health care.

This represented approximately 62% of the country’s total
health expenditures, which translated into expenditures of
€3190 per capita (BMG, 2018a). From 2000 to 2017, SHI
expenditures increased by 70%. Over the past two decades,
the growth rate of SHI has ranged between 1.5% and 6%, with
a pronounced exception of -4% in 2004 (Figure 3). In 2017, the
PHI system spent €31.63 billion on health care (GBE, 2018),
equalling approximately 8.5% of Germany’s total health
expenditures. From 2000 to 2017, PHI expenditures have
increased by 80% from formerly €17.49 billion in 2000.
Over the same period, the growth rate of PHI has ranged
between 0.6% and 5.6% with a slightly downward sloping
trend (Figure 3).

Figure 3
Total SHI and PHI expenditures in current prices and change
rates from 2000 to 2017 (or latest year available)
250,000 7
200,000 5
3
150,000
2
1
100,000
0
-1
50,000 -2
-3
0 -4
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
Total PHI expenditures (current prices) Change in total PHI expenditures

Total SHI expenditures (current prices) Change in total SHI expenditures
Source: GBE, 2018.
A high density of providers, volume-incentivising

remuneration systems and moderate price levels contribute
to high utilization rates
Compared to its neighbouring countries, Germany maintains a

high density of providers, high utilization rates and low to
moderate prices. It employs reimbursement systems, which set
incentives on good access to care and low waiting times at the
expense of volume growth and an oversupply of care.
Germany’s density of physicians ranks considerably above the
OECD average (4.2 physicians per 1000 inhabitants against an
OECD average of 3.4) (OECD, 2018b). It features the third
highest density of hospital beds, with 8.1 beds per 1000
inhabitants, after Japan (13.1 per 1000) and Korea (12 per
1000), which is almost double the OECD average of 4.7 beds
per 1000 inhabitants (OECD, 2018b). The number of beds in
long-term care (LTC) facilities and nursing homes ranges in the
upper half of OECD countries and is in line with Germany’s
neighbouring OECD countries (OECD, 2018c).
Germany’s reimbursement systems set maximum incentives at

service provision, but prices per service are low to moderate
(Koechlin, Lorenzoni and Schreyer, 2010; Lorenzoni and
Koechlin, 2017). Virtually all inpatient services are reimbursed
on the basis of diagnosis-related groups (DRGs). As a result,
waiting times in the inpatient sector are non-existent and
lengths of stay have declined over the past two decades, while
hospital volumes have increased (Statistisches Bundesamt,
2018). Similarly, outpatient services are reimbursed by a
fee-for-service (FFS) system and a system of lump-sum

payments. The FFS component again leads to low waiting times
but sets strong incentives to increase the number of services
provided to patients.
The low-price level paired with high rates of provider densities

and reimbursement systems, which reward volume growth,
incentivized Germany’s high utilisation rates of healthcare
services. It ranks among the countries with the highest number
of doctor consultations per capita and tops the list of hospital
discharges per 100,000 inhabitants (OECD, 2018d). Germany
also is among the countries which lead the list of surgical
procedures per inhabitant (Kumar and Schoenstein, 2013;
OECD, 2018d). Reimbursement systems have been subject to
various policy interventions to limit expenditure growth, but
they have been of mixed success.
Prices shall reimburse the average cost of providers
The provision of health care services in the SHI system follows

an efficiency principle (Wirtschaftlichkeitsgebot). Health
services shall be sufficient, appropriate and efficient, and not
range beyond what is deemed medically necessary. Such a
restriction does not apply to the PHI system. Price setting
intends to allocate resources among providers based on their
contribution to the health care system and to reimburse
average market costs of providers. Germany has made several
attempts to increase the transparency, efficiency and
accountability of health care providers by harmonizing prices
on the national level.
There is no overall health care budget comparable to the

English National Health Service (NHS). Instead, total
expenditures are an aggregate of expenditures in different
sectors and insurance systems. There is a strict separation
between the sectors. Inpatient services, outpatient services
(including specialist and primary care), and LTC are paid from
three different budgets, and prices are set differently.
Interaction between these sectors is low (Milstein and Blankart,
2016; Amelung, Hildebrandt and Wolf, 2012).
Thus far, cost containment has been less important in Germany

than in other OECD countries. As of 2018, Germany still
benefits from a positive GDP growth rate and solid finances,
and SHI funds enjoy financial surpluses. In past years, Germany
has experimented with various ways to reduce the high volume
of service provision. These, however, have had limited effects
so far. For example, the country operates with deductions to
limit provider incentives that increase service provision and has
increased the share of bundled payments at the expense of FFS
reimbursement in the outpatient sector and for general
practitioners (GPs), in particular. In the inpatient sector,
Germany has introduced price deductions on services which
are subject to economies of scale. However, the effect of these
policies on cost containment and service volumes is disputed
and has resulted in complex reimbursement systems which are
hard to navigate for both payers and providers.

2
Governance of the health care sector
Payers and providers are responsible for organising the

delivery of care
The German healthcare system is governed by the so-called

Selbstverwaltung (self-governance of the healthcare sector). The
government has mandated payer and provider associations to
organized the delivery of care. This structure dates to 1881. In
the SHI system, payers and providers have formed collective
agreements. SHI funds are obliged to contract all providers
which have been licensed by the state or the provider
association in accordance with national and state guidelines.
The German Federal Ministry of Health assumes a supervisory
function and can intervene in selected instances. Theoretically,
it could revoke the entire mandate.
SHI funds are represented by the Spitzenverband Bund der

Krankenkassen (GKV-Spitzenverband, National Association of
Statutory Health Insurance Funds) at the federal level, and by
state associations at the state level. In line with this
organization, PHI funds are represented by the Verband der
Privaten Krankenkassen (PKV-Verband, Association of PHI funds)
with its respective state associations. The Deutsche
Krankenhausgesellschaft (DKG, German Hospital Federation)
and its 16 state federations represent the interests of inpatient
providers. The Bundesärztekammer (BÄK, German Medical
Association) represents all physicians who are licensed to
practice. Outpatient physicians, who want to provide services
to SHI patients and be reimbursed by the SHI, must obtain a
licensure by one of the 17 Kassenärztliche Vereinigungen (KV,
Associations of SHI physicians). At the federal level, they unite
in the Kassenärztliche Bundesvereinigung (KBV, National
Association of SHI Physicians).
Price setting and budgeting reflect Germany’s federal

structure
In the inpatient sector, state associations of SHI that have

closed an agreement with a state contract all hospitals in the
state. These hospitals can apply for funding for investment
costs from the state and are reimbursed by SHI funds. In return,
they must adhere to the state’s hospital plan including the
amount of beds, medical units and selected quality criteria. In
the PHI system, patients can access all hospitals and claim
reimbursement from their PHI fund. Hospitals are reimbursed
almost exclusively on the basis of DRGs. Prices are mostly
calculated at the federal level. States can deviate from the
overall price level within a predefined range. The budget of a
hospital is negotiated between an individual hospital and SHI
and PHI funds.

In the outpatient sector, state associations of SHI funds have
closed collective agreements with their state’s KV and
consequently contract all physicians who hold a licensure with
the KV. Physicians are reimbursed by the SHI funds and must
adhere to location restrictions by their KV. Physicians are
reimbursed by a mixture of FFS and lump-sum payments.
Similar to the inpatient sector, prices are largely set on the
federal level and tailored to specificities at the state level. In
contrast to the inpatient sector, services are budgeted. SHI
funds pay an aggregate budget to their state’s KV. It is up to the
KV to distribute the budget among its SHI physicians. Services
to PHI patients are reimbursed differently, albeit by a FFS
system. Patients can receive services from all physicians who
hold a medical licensure to practice and claim reimbursement
from the PHI fund depending on their health plan. As opposed
to the SHI system, services are not budgeted.
In LTC, state associations of LTC funds (both public and private)

and state associations of nursing home providers have formed
an agreement on the provision of nursing care in a given state.
The provision of care is supervised by the respective state
authority (generally, Ministry of Social Affairs or Ministry of
Health). Nursing homes, which want to provide care within this
agreement and be reimbursed accordingly, close a contract
with sickness funds on the provision of nursing care to their
enrollees. This holds true for both SHI and PHI funds. In return,
nursing homes must adhere to quality criteria, such as staffing
ratios. Prices are negotiated individually between a nursing
home and LTC funds. They are split into a per diem nursing care
charge, which is covered by a lump-sum payment of the LTC
funds, and a copayment, costs for housing and meals,
infrastructure, training and additional services, which are paid
by the patient.

3
Price setting and budgeting by the health
care sector
The inpatient sector
In 2016 and 2017, SHI expenditures for inpatient services

amounted to €72.95 billion and €74.14 billion, respectively. In
2016, the PHI spent €7.59 billion on inpatient services (2017
data was not available). This is a 70% increase compared to
2000 (Figure 4). Over the past two decades, expenditures by
both SHI and the PHI have increased at a similar pace (Figure 5).
The increase in PHI expenditures was steeper in the first half of
the past decade (2003-2008) but was overtaken by the SHI in
the following years. In the past two years, growth rates in both
SHI and PHI have declined.
Figure 4
SHI and PHI inpatient expenditures in current prices and
price-indexed (2000=100) from 2000 to 2017 (or latest year
available)
80 180
170
70
160
60
150
50
140
Percentages
Billion Euros
40 130
120
30
110
20
100
10 90
0 80
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
SHI expenditures (in billions, current prices) SHI expenditures (indexed)

PHI expenditures (in billions, current prices) PHI expenditures (indexed)
Sources: BMG, 2018a; PKV-Verband, 2017. Note: PHI expenditure data for
2017 is not available.

Figure 5
Growth rates of SHI and PHI inpatient expenditures from
2001-2017 (or latest year available)
4
Percentage
2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
SHI expenditures growth rate

PHI expenditures growth rate
2017 is not available.
The distribution of hospitals is regulated at the state level
In 2017, Germany had 1942 hospitals totalling 497 182 beds,

which translates into 6 beds per 1000 inhabitants (Statistisches
Bundesamt, 2018). 37% (720) of all hospitals are private
for-profit hospitals, followed by 34% private not-for-profit
hospitals (662), and the remainder being public hospitals (560).
With regards to hospital beds, however, the public hospitals
provide the largest share with 48% of all beds (238 748),
followed by private non-for-profit hospitals with 33% (165 245
beds), and private for-profit hospitals with 19% (93 189). In
2017, Germany had 35 university hospitals, and close to a
quarter of all beds are concentrated in about 100 hospitals
(Figure 6).
Figure 6
Number of hospitals and total beds by bed category (2017)
Bedsize 0 1-49 50-99 100-149 150-199 200-299 300-399 400-499 500-599 600-799 800+
No. of hospitals 65 365 236 252 187 243 185 129 105 78 97
Total Beds - 7374 17 063 30 894 32 452 60 141 63 209 57 165 57 148 53 729 118 007
Source: Statistisches Bundesamt, 2018.

The distribution of hospitals is regulated at the state level by
the respective State Ministry of Health in accordance with the
hospital association, the SHI and PHI associations at the state
level, and additional partners that are deemed necessary by the
respective state. Hospitals which conclude a contract with the
state (so-called Plankrankenhäuser) are eligible for financial
support from the state for their infrastructure, and SHI funds
are obliged to reimburse services they provide. In return,
hospitals can be mandated to provide certain services, run
specific units, and to increase or decrease their number of
beds. Roughly 98% of all hospitals have concluded a contract
with the state.
The planning varies greatly between the 16 states. Historically,

states have planned the distribution of hospital beds and have
largely relied on the Hill-Burton formula to set target
occupancy rates depending on the unit type leading to status
quo maintenance. In the past few years, states have started to
deviate from and begun to include quality criteria, such as
staffing ratios, infrastructural prerequisites for specialized units,
and minimum volumes (DKG, 2018).
Services are reimbursed almost exclusively on the basis of

DRGs
The running costs of hospitals are reimbursed almost

exclusively on the basis of DRGs and mirror the real
expenditures hospitals incur. Patients are allocated to a specific
DRG based on their major diagnosis, co-diagnoses, procedures,
length of stay, ventilation hours (if applicable), age, gender,
weight (for newborns), medical unit, and type of discharge, such
as “discharged as fully recovered” or “death”. The
reimbursement that hospitals receive covers medical treatment,
nursing care, the provision of pharmaceuticals and therapeutic
appliances, board, and accommodation.
The German system is modelled on the Australian DRG system.

In 2018, the German DRG system included 1292 DRGs and 205
add-on payments for patients with particularly high demand for
nursing care or for the provision of additional services and
pharmaceuticals which are not included in the DRG system yet.
Each DRG can be split into up to five subcategories depending
on the patient’s severity. The DRG system is revised annually to
accommodate cost changes. DRGs are split into a cost weight
(relative weight) and a base rate. The base rate defines the
overall price level, whereas cost weights represent the severity
of a diagnosis and its accompanying procedures vis-à-vis all
other diagnosis. Accordingly, an increase in the base rate
augments the prices of all DRGs, whereas an increase in the
cost weight augments the price of one DRG compared to all
others. Further, the base rate differs between all 16 states,
whereas the cost weight is the same across the country. Both
parts are calculated separately from one another as described
below (Figure 7).

There is no difference between private, private not-for-profit,
and public hospitals: DRG prices are the same for all hospitals
contracted by the state. SHI is obliged to reimburse services
hospitals provide. In return, hospitals can be mandated to
provide certain services, run specific units, and to increase or
decrease their number of beds.
The German DRG system was introduced in 2003 and

implemented nationwide in 2005, replacing per diem
payments. DRGs were introduced to increase transparency and
efficiency in the health care sector and to decrease the average
length of stay in hospitals. In contrast to other OECD countries,
attempts to reduce costs did not motivate the introduction of
DRGs.
Since the introduction of DRGs, the average length of stay has

decreased by 17%, the number of cases has increased by 18%,
and the number of nursing days has remained rather stable
with a 1% decrease (Statistisches Bundesamt, 2018). This has
been part of a longer trend. Since 1990, the average length of
stay has halved, and the number of cases has increased by
30%. The number of nursing days had decreased by 30% up to
the mid-2000s and has remained constant ever since
(Statistisches Bundesamt, 2018). Prior to the introduction of
DRGs, Germany had already experimented with mixtures of per
diem payments and case-based remuneration systems.
Figure 7
From price to budget calculation in the inpatient sector
Federal Arbitration board? Arbitration board?
Federal base rate: Cost weights:

Negotiated by hospitals and Calculation of average costs
sickness funds at federal level based on real cost data from
based on calculations by InEK. approx. 300 hospitals by InEK.
State Arbitration board?
State base rate:

Federal base rate – 1.02% / + 2.5%
Corridor calculated by InEK.
Negotiations between sickness funds
and hospitals at state level.
DRG
Local Arbitration board?
Budget negotiations:
Budget generally based on last year’s budget plus 1-2% increase.
Negotiations between individual hospital and all sickness funds whose
enrollees contribute to at least 5% of bed occupancy rate.
Source: authors.

Cost weights are calculated by averaging cost data from a
sample of hospitals.
Cost weights are calculated annually by the Institut für das

Entgeldsystem im Krankenhaus (InEK, institute for hospital
reimbursement), a joint institute by the DKG, the GKV-
Spitzenverband, and the PKV-Verband. Cost weights reflect the
average expenditures of a sample of hospitals.
To calculate the weights, the institute collects data from roughly

300 hospitals that participate on a voluntary basis. These data
include patient-level data on the major diagnosis and other
diagnoses, clinical interventions (such as medical procedures),
patient characteristics (age, gender, and weight of newborn
children), cause of hospital admission and discharge, as well as
accompanying cost data, such as workforce and technical
resources and pharmaceuticals. Based on that information, the
InEK groups patients into DRGs and assigns cost weights to each
of the DRGs. In a first step, diagnoses are clustered into 23
Major Disease Categories. The cost weight of the specific DRG in
question is determined by the procedures, comorbidities, and
clinical severity. Following that, the InEK averages the
contributing cost data of each and every DRG to determine the
cost weights. In conjunction, it also determines the average
length of stay and its accompanying range. If a patient stays
below the lower or above the upper limit of what is deemed an
appropriate length of stay for his DRG (known as “outlier”), the
hospital receives a depreciation on a per diem basis.
The InEK can mandate hospitals to submit cost data and select
hospitals randomly. Hospitals can sue the InEK at the
administrative court and some have made use of that option. In
2017, the InEK mandated 120 hospitals to submit data; 28
hospitals did not submit data, and 13 hospitals filed lawsuits
against the InEK. However, the first court ruling on that matter
has dismissed the case.
The catalogue of cost weights is approved annually by the DKG,

the GKV-Spitzenverband, and the PKV-Verband. These three
parties also define the overall framework and methodology to
determine relative weights to which the InEK has to adhere. If
the parties fail to come to an agreement, the federal arbitration
board decides. It consists of 21 members, with one non-
partisan chair being among them, two additional non-partisan
members, nine representatives of the DKG, eight
representatives of the GKV-Spitzenverband, and one
representative of the PKV-Verband. The non-partisan members
are appointed by a joint decision of hospitals and sickness
funds. If they fail to come to an agreement, the President of the
Federal Social Security Court appoints three members.
Decisions of the arbitration board are intended to be binding.
In very few cases has one of the negotiating parties filed a
lawsuit against the arbitration board at the Superior State
Social Court. The entire procedure is supervised by the German
Federal Ministry of Health. If negotiations between the DKG,
the GKV-Spitzenverband, and the PKV-Verband fail, the Ministry

can also intervene and overrule the parties by decree. This was
the case in 2003 when the negotiating parties failed to agree
on the reimbursement of semi-inpatient services.
The federal base rate is adjusted annually to reflect changes

in hospital costs and contributions to SHI funds
The growth rate of the federal base rate is negotiated annually

by the DKG, the GKV-Spitzenverband, and the PKV-Verband. In
2018, the federal base rate was set at €3467.30. The three
negotiating parties are obliged to mandate the InEK to calculate
the federal base rate. These calculations are based on the state
base rates, the total expenditures and the case mix of the
preceding year. The growth rate of the federal base rate is
based on two parameters: the average change rate of
contributions by SHI enrollees (Grundlohn-Veränderungsrate)
and the average change rate of hospital costs
(Orientierungswert). The latter is calculated annually by the
German Federal Statistical Office. If the change rate in
contributions is higher than the cost increase, this rate is
chosen automatically. If costs increase at a higher rate, the DKG,
GKV-Spitzenverband, and the PKV-Verband negotiate on an
increased rate, which has to range between both rates. If the
parties fail to come to an agreement, the aforementioned
federal arbitration board decides.
This regulation, however, has been subject to frequent

interventions and changes by the legislature. In the past, the
change rate of the federal base rate has ranged between 2.5%
and 3%.
The growth and cost rates have been criticized. Changes in

contributions by SHI enrollees are not related to changes in the
hospitals’ costs and revenues. Changes in hospital costs, on the
other hand, do not take expenditures and cost reductions into
account, for example, due to technical innovation. Finally,
regulations on how to determine the change rate have been
modified on a frequent basis, but several exceptions apply
(GKV-Spitzenverband, 2018a; 2018b).
States can deviate from the federal base rate within a

predefined range
Once the federal base rate has been defined, each of the 16
states define their state base rates. They can deviate from the
federal base rate by -1.02% to +2.5% (€3431.93 or €3553.98).
In practice, the states increase their state base rate by the
growth factor of the federal base rate. The so-called “corridor”
within which states can deviate from the federal base rate is
also calculated by the InEK and negotiated between the DKG,
the GKV-Spitzenverband, and the PKV-Verband. It forms part of
the negotiations on the federal base rate.
Negotiations on the state base rate take place between the

state’s hospital association, the state associations of SHI funds,
and the state association of PHI funds, and should be finalized
by 30 November of the given year. The decision has to be

approved by the respective State Ministry of Health. If the
parties fail to reach an agreement, the dispute is handed over
to an arbitration board. The latter is composed of a neutral chair
and representatives of hospitals and sickness funds in equal
representation. It is supervised by the State Ministry of Health.
About two out of 16 states appeal to their arbitration board per
year (Vdek, 2018a). Arbitration boards should finalize their
decision by 1 January of the given year, but often take until
April. Furthermore, all of the negotiating parties at the state
level can contest the decision of the arbitration board.
However, the legal process is not properly defined. It is not
clear whether the party has to sue the arbitration board or its
opposing party, and which court holds the judicial competence.
Each hospital negotiates its annual budget with sickness

funds
Once both the state base rate and cost weights are defined,
each hospital negotiates with sickness funds, which enrol at
least 5% of the cases of the hospital’s patients, on the
hospital’s annual budget. The budget has to be approved by the
State Ministry of Health. If the parties fail to reach an
agreement, an arbitration board decides on the budget. As in
the preceding steps, parties can sue one another or the
arbitration board. In theory, budget negotiations should be
concluded prospectively for the following year. In practice,
however, this is seldom the case and negotiations tend to be
finalized between March and September of the given year. By
and large, the prospective budget equals the budget of the year
before plus 1-2%.
SHI funds can mandate the medical service of SHI funds to

investigate whether hospitals have coded and billed diagnoses
and treatments correctly. If not, the hospital has to repay the
difference between what it has received and what it should
have correctly received to the SHI fund. If the SHI fund has
erred, it has to pay a compensation to the hospital. Furthermore,
both parties can sue one another at the Social Court.
Additional reimbursements supplement the DRG

reimbursement
In addition to the DRG reimbursement, hospitals can receive

additional payments or may be subject to deductions and
penalties as a disciplinary measure. In 2018, there were 29
different add-on payments and deductions or penalties (GKV-
Spitzenverband, 2018c). In the majority of cases, these are
negotiated individually as part of the annual budget
negotiations of the respective hospital. In selected cases, they
are decided at the state or federal level. They can either be
negotiated between provider and payer associations at the
state or federal level, or be set by the Joint Federal Committee,
Germany’s highest decision-making body of the
Selbstverwaltung. Add-on payments and deductions are used to
impact the behavior of hospitals via financial incentives and to
compensate for deficiencies in the DRG system.

First, add-on payments compensate for the provision of specific
hospital structures and services that are not appropriately
reflected in the DRG system. Among them are additional
payments for medical education, specialized units and medical
centres or the delivery of care to medically demanding
patients. In line with that, hospitals enjoy add-on payments if
they are located in financially unattractive regions but are vital
to provide medical services to the region.
Second, deductions are used to incentivize hospitals not to

deviate from the negotiated budget. If a hospital performs
more services than agreed upon, it receives only 35% of the
reimbursement it would normally receive for this service
(Mehrerlösausgleich [surplus compensation]). If a hospital
performs fewer services than negotiated, it receives a
reimbursement of 20% for the services it should have
theoretically performed (Mindererlösausgleich [deficiency
compensation]). These deductions are not adjusted based on
hospital characteristics, such as size and provider status.
Third, hospitals face penalties as a disciplinary measure. For

example, they receive a deduction if they refuse to participate
in the provision of emergency delivery of care (€60 per case) if
they fail to submit requested data or if the data are of
insufficient quality. However, the effect of these deductions is
limited. By and large, it is financially favourable for a hospital to
pay a penalty rather than to entertain an accident and
emergency (A&E) department or to hire additional staff for
submitting data.
In spite of a strict and detailed costing approach to determine

DRGs, some problems in price setting exist
Generally, the German DRG system follows a very detailed,

standardized, strict, and unique costing approach to determine
DRGs. However, there are still some problems in price setting
(Schreyögg, Tiemann and Busse, 2006). For instance, it does not
include any adjustment based on hospital or regional
characteristics, such as the Market Forces Mechanism in England
or the Medicare Wage Index in the United States (Schreyögg et
al., 2006). Hospitals in rural regions have lower infrastructural
and staffing costs but receive the same remuneration as their
counterparts in urban regions of the same state. For the time
being, there are 16 different price levels resulting from 16
different state base rates, but these follow historic
developments and cannot be explained by patient or hospital
structures or different wage levels (RWI, 2013). Germany still
aims to align state base rates to one uniform price level with the
federal base rate. The transition phase has been expanded to
2021. The introduction of a Market Forces Factor or a similar
adjustment mechanism has not been presented as a potentially
successful policy proposal yet. Thus, the council of experts on
Germany health care recently proposed the introduction of a
regionalization factor considering the hospital-specific price
level of a respective region, such as county level (Advisory
Council on Health Care, 2018).

One further problem is that the sample of hospitals, which
submit their cost data to the InEK and/or their case-mix
changes annually, is not representative of the country’s hospital
structure (SVR Gesundheit, 2018). To improve the latter, the
DKG, GKV-Spitzenverband, and PKV-Verband have authorized
the institute to oblige hospitals to submit data, but this option
has only been introduced in 2016 and results in lengthy legal
disputes with hospitals. It is not clear yet whether this
authorization will finally make the sample more representative.
Finally, under the German DRG system, each hospital receives

the same reimbursement per case irrespective of the level of
care provided by a hospital. For instance, academic medical
centres receive the same DRG payment for a given patient as a
community hospital on the countryside, even though the
facilities provided by the hospitals may differ especially at the
cost level. The council of experts therefore recommends that
the DRG system evolve to consider the variation of hospital
costs per case at the different levels of care provision (such as
acute care, specialized care, or highly specialized care), for
instance, by using multipliers on the relative weights (Advisory
Council on Health Care, 2018).
Germany still lacks instruments to control inpatient care

volumes
As already mentioned, Germany has experienced steady

increases in volumes of inpatient care, while many other OECD
countries have observed declining inpatient volumes in recent
years. The expansion of volumes is particularly high among
patients with lengths of stay of 1-3 days (approx. +50% over
the past decade) or without overnight stay (roughly +20% over
the past decade) but attempts to treat these patients in
outpatient settings have failed thus far. Current reimbursement
incentive systems for hospitals to substitute inpatient care with
outpatient care are low. Additionally, the country faces a
structural overprovision of hospitals and hospital beds. At the
same time, it maintains a DRG system with a large number of
DRGs (1292), with half of them being driven by at least one
medical procedure, which sets strong incentives on volume
growth and surgical interventions. In addition, states only partly
fulfil their financial obligations to cover infrastructural costs.
This exerts financial pressure on hospitals. As a result, hospitals
expand volumes beyond what is medically necessary to cross-
finance infrastructural costs. Sickness funds argue that they find
themselves in a disadvantageous situation to exert budget
control. As they still enjoy financial surpluses, they have limited
power to reasonably call for cost containment.
As part of the Hospital Structure Reform Act, or

Krankenhausstrukturgesetz (KHSG) from 2015, policy-makers
have developed an instrument to address the problem of rising
inpatient volumes. Since 2017, hospitals have received a
so-called “deduction for the cost digression of fixed costs”
(Fixkostendegressionsabschlag) of 35% on DRGs that feature
economies of scale. This deduction only applies to additionally

negotiated services, meaning a share of the additional 1-2%
negotiated between the individual hospital and its sickness
funds. This instrument is in place to disincentivize hospitals to
ask for ever-growing budget increases, particularly on
interventions that are subject to economies of scale, such as
hip and knee replacements. This instrument was introduced in
2016 and replaced the former “deduction on additional
services” (Mehrleistungsabschlag), which operated in a similar
way, but occurred at irregular intervals and with varying rates.
Originally, the DKG, the GKV-Spitzenverband, and the PKV-
Verband were set to negotiate individual deductions for all
DRGs that feature economies of scale. Because the parties
failed to close agreements and because negotiations ended at
arbitration boards on a recurring basis, the legislature
intervened and set a digression of 35% for all DRGs that are
subject to economies of scale. In addition, a second opinion
procedure has been introduced for selected procedures that
underwent sharp increases in volumes in the past. Although, in
2017, volumes reduced slightly, it is still unclear if this is the
start of a new development or just a short break in the trend of
rising inpatient volumes.
The KHSG has also introduced broader reforms of the German

DRG system. It has made a first attempt to improve quality of
care in the inpatient sector. It introduces structural quality
indicators for selected hospital units, allows selective
contracting on the grounds of quality, and introduces pay-for-
performance (P4P). The design of the latter, however, is still in
process; P4P should have been introduced by the end of 2017
already.
The 2018 Nursing Workforce Strengthening Act

(Pflegepersonalstärkungsgesetz) represents a notable change to
the DRG system. Thus far, the DRG system has set incentives to
increase the number of physicians who directly contribute to
hospital volumes, while keeping constant the number of
nurses. According to nurse representatives, this has led to a
significant deterioration of working conditions of the nursing
workforce. A policy report (Schreyögg and Milstein, 2016)
indeed found that in several hundred hospitals, nursing ratios
largely deviated from the median of nursing ratios in German
hospitals. The report also confirmed for Germany that low
nursing ratios are associated with low quality of care. In 2016,
the legislature has introduced minimum nurse staffing ratios,
which will come into effect on 1 January 2019. This was
deemed insufficient by nursing unions and left-wing parts of
the government. As a result, the legislature has decided to
exclude nursing costs from the DRG system. The latter will
effectively come into force in 2020.
Primary care and outpatient specialist services
In 2016 and 2017, expenditures for outpatient services in the

SHI system amounted to €36.53 and €38.09 billion,
respectively. In 2016, the PHI system spent €4.59 billion on
outpatient services (2017 data was not available) (Figure 8).
From 2000 to 2017, PHI expenditures have almost doubled. SHI
expenditures have increased by 80% over the same time. Up to
2012, expenditure growth in the SHI system had been
significantly lower than in the PHI system (Figure 9). Since
2012, however, the growth rate of the SHI system started to
overtake the growth rate of the PHI system.
Figure 8
SHI and PHI outpatient expenditures in current prices and
price-indexed (2000=100) from 2000 to 2017 (or latest year
available)
40 200
190
180
30 170
160
150
Percentages
Billion Euros
20 140
130
120
10 110
100
90
0 80
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
SHI expenditures (in billions, current prices) PHI expenditures (indexed)

PHI expenditures (in billions, current prices) SHI expenditures (indexed)
2017 was not available.

Figure 9
Growth rates of SHI and PHI outpatient expenditures from
2001-2017 (or latest year available)
12
10
6
Percentage
-2
-4
-6
-8
2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
SHI expenditures growth rate

PHI expenditures growth rate
2017 was not available.
In contrast to the inpatient sector, the reimbursement of

outpatient services provided to SHI patients differs from the
services to PHI patients. Both systems use a different fee
schedule. Services in the SHI system are limited by budget
restrictions, but not in the PHI system. Within both systems, the
reimbursement of primary and outpatient specialist care
follows the same structure. This section first reports on the SHI
system and next on the PHI system.
Reimbursing outpatient services: Statutory Health Insurance
In Germany, the KBV and the GKV-Spitzenverband have formed

a nationwide collective agreement: all SHI funds annually and
prospectively pay an aggregate lump-sum to the KV for all
enrollees which they insure in that given state. The aggregate
budget is roughly based on the volume of all services of the
preceding year. In return, the KV guarantees the provision of
outpatient services to all SHI enrollees. KVs distribute the
aggregate budget among their SHI physicians in quarterly
intervals. This chapter first reports how prices in the SHI system
are calculated. Then, it guides through the stepwise approach
from the determination of the aggregate budget to the
individual reimbursement physicians receive for providing
services to SHI patients.

The distribution of physicians is regulated at the KV level
In 2017, there were 147 350 outpatient physicians practicing

in the SHI system. A bit more than a third of them practiced as
GPs (37%, or 54 741) (KBV, 2017). The distribution of
physicians is regulated by the KV in accordance with the
national planning guideline to ensure sufficient and equal
access to SHI physicians (Bedarfsplanungsrichtlinie). The
planning differs between GPs and specialist physicians. To plan
the distribution of GPs, the country is divided into roughly 950
planning regions. A region is designed as “100% served” if a
ratio of 1 GP to 1671 inhabitants times a demographic weight
is met (GBA, 2018). A region is designated as a looming
shortage area and a shortage area if the quota falls below 90%
and 75%, respectively. KVen employ a range of measures to
attract physicians to those areas, such as scholarships for
medical students in exchange for a return-of-service obligation
or financial support for practice openings in those areas. If the
density exceeds 110%, no additional licensures to practice are
granted. In 2016, there were 86 planning areas with a
percentage share of less than 90% and eight areas with less
than 75% in contrast to 384 areas with a coverage of 110%
and more (Klose and Rehbein, 2017). For specialists, the ratio
and the size of the geographic planning entity varies
depending on the specialty in question. KVen can deviate from
this regulation in selected instances if necessary.
Physicians are reimbursed by the SHI medical fee schedule
Physicians are predominantly reimbursed on a combination of

FFS and global budgets. They bill their services at the patient’s
SHI fund based on the nationwide medical fee schedule of the
SHI system (Einheitlicher Bewertungsmaßstab) (Figure 10). Prices
in the SHI schedule are similar to DRGs, albeit for procedures
rather than for diagnoses. The prices are composed of points,
which reflect the intensity of a service (similar to cost/relative
weights for DRGs) and a base rate, which is expressed in euros
(corresponds to the base rate for DRGs). An increase in the
number of points for a selected service increases the intensity
of that service compared to other ones. An increase in the base
rate increases the reimbursement of all services. In 2018, one
point equalled €0.106543. The SHI medical fee schedule was
introduced in 1978 to harmonize different fee schedules. Prior
to that, SHI funds had negotiated their own schedules with the
KBV and the KVen.

Figure 10
Simplified excerpt of the physicians’ fee schedule
Number Service Points Euros
01102 Consultation of SHI physician on 101 10.76

Saturdays between 07:00 and 14:00 h.
03000 Flat rate for general treatment of patients 122 13.00
aged 19-54. Coordination of medical
treatment. Data collection and
diagnostics. Has to include personal
contact. GP-only.
03220 Add-on to No. 3000 if patient suffers from 130 13.85
at least one clearly identified chronic
disease. Treatment of chronic disease in
accordance with medical guidelines.
Support of treatment of chronic disease.
Revision of pharmaceutical plan, if
necessary. GP-only.
Source: KBV, 2018.
There are three types of services in the schedule. First, there

are services which can be billed by all physicians irrespective
of their medical specialty. Second, there are services which can
only be billed by physicians with the corresponding specialty.
This section is subdivided into primary care and 23 specialties
and covers the vast majority of services. Third, there are
services which can be provided by all physicians, but require
additional approval by the KV, such as additional education and
training, and specific structural prerequisites in the medical
practice.
Prices shall reflect real prices physicians incur
The services in the SHI medical fee schedule, their definition

and interpretation, and their corresponding points and base
rate are defined at the federal level by an assessment board
(Bewertungsausschuss), which is a joint decision-making body
of the KBV and the GKV-Spitzenverband (Figure 11). Points are
defined by working groups of the assessment board. For this
purpose, the board collects claims and cost data to determine
the resource intensity of services. Medical associations can
submit proposals to the working groups. Working groups invite
external experts to support their work. The base rate was
introduced in 2009 based on cost data from the two preceding
years. The annual change rate of the base rate is determined
based on the cost data of SHI physicians. It reflects increases in
investment and operating costs while taking into account
inefficiencies and economies of scale. It is determined by a
working group as well.
The assessment board consists of three representatives from

the KBV and three representatives from the GKV-
Spitzenverband. Decisions have to be made unanimously and
should be finalized by 31 August of the given year. If the board
fails to reach an agreement, decisions are handed over to the
extended assessment board (erweiterter Bewertungsausschuss),
which adds three non-partisan members – one at the decision
of the KBV, one at the decision of the GKV-Spitzenverband, and
a chair, which is determined in a joint decision of the KBV and
the GKV-Spitzenverband. The entire process is supervised by
the German Federal Ministry of Health. The extended
assessment board can file a complaint or entirely revoke the
mandate. The KBV and the GKV-Spitzenverband can file a suit
against interventions by the Ministry at the Superior State
Social Court. Vice versa, the KBV and GKV-Spitzenverband can
also sue the assessment board at that Court. Both have taken
place on a recurring basis in the past.
Figure 11
From aggregate price setting to the individual physician’s
reimbursement in the SHI system
Element Actors
Federal Arbitration board? Arbitration board?
Definition and interpretation of SHI’s uniform fee schedule. Assessment board of KBV
Calculation of change rate in morbidity (based on sum of and GKV-Spitzenverband.
points in preceding years, ICD codes, age and gender) and Ministry can intervene.
in investment and operating costs (Orientierungswert)
State Collective contract Arbitration board?
Morbidity-based aggregate Extra- Selective Negotiations between KV

budget. Sum of points of budgetary contracts and associations of SHI
preceding year multiplied by services funds at the state level.
base rate. Adjusted by two
change rates (see above).
Laboratory services
Emergency services
Primary care Specialist

services services
Depreciation if necessary
Individual
Source: Adapted by the authors based on KVRLP, 2017, and KVT, 2017.

SHI funds pay aggregate budgets to the KVs based on the
preceding year
Every KV annually receives an aggregate budget from SHI funds

for all enrollees who live in that given KV. The aggregate budget
consists of a morbidity-adjusted part and extra-budgetary
services. The morbidity-adjusted part represents about 70% of
all services. It is based on the sum of all points of services
which have been provided to SHI patients in the preceding year
(similar to the case mix), multiplied by the base rate. This
budget changes annually based on two factors: the sum of
points is adjusted to accommodate changes in age, gender and
morbidity composition of enrollees in a given KV; the base rate
is adjusted annually to reflect changes in investment and
operating costs.
The change rates are proposed by the aforementioned

assessment board, which calculates the KV-specific changes in
morbidity for every KV separately, as well as the federal change
rate of the base rate (see section above). Following from that, KV
negotiates with all state associations of SHI funds on the
aggregate budget of their KV. They define their regional base
rate based on the change rates proposed by the assessment
board. They can deviate from the board’s calculations and
decide on how to weight both change rates or choose entirely
different rates. Furthermore, the parties can add additional
services to the medical fee schedule, which only apply to their
KV, and negotiate add-on payments to services and service
providers, which are understood to need additional financial
support. Negotiations on a state level should be finalized by 31
October of the given year. If the negotiating parties fail to reach
an agreement, an arbitration board, which consists of
representatives of the KV and state associations of SHI funds on
equal terms, decides. All parties can sue the arbitration board’s
decision at the respective state’s Superior State Social Court.
The remaining 30% of services are not morbidity-adjusted and

not subject to budget constraints. This part includes, among
others, outpatient surgeries, prevention, pain therapy,
rheumatology, or selected anaesthetics. Additionally, it covers
additional services which result from agreements on a federal
or state level, for example, vaccinations or the provision of
outpatient services to cancer patients.
The KV breaks down the aggregate budget to the individual

physician
Following from the agreement on the aggregate budget, the KV

distributes the morbidity-adjusted part among its physicians on
a quarterly basis. This follows a step-wise approach.
In the first step, services are split into four subgroups, namely
laboratory, emergency, primary care, and specialist services.
Primary care services are subdivided into GP services and
paediatrics, whereas specialist services are subdivided into 14
medical speciality groups. The financial volume of these groups
is distributed separately from one another. There is no financial

redistribution from one subgroup to another, such as from GPs
to specialists. This shall guarantee that expenditure increases in
one subgroup do not take place at the expense of another one.
Financial deductions shall disincentivize volume growth
In a second step, the KV determines the quarterly service

volume (so-called standard service volume
(Regelleistungsvolumen)) for every SHI physician. All SHI
physicians have their own financial budget, which is dependent
on the average number of cases physicians from that medical
specialty treat. This budget is reassessed in quarterly intervals.
To determine the standard service volume, the amount of cases

of the individual physician of the preceding quarter is
multiplied by the case value of the specialty and a
demographic weight to reflect the age composition of the
physician’s patient cohort. To calculate the case value, the
financial volume of all standard service volumes of a specialty
is divided by the number of patients. If a physician outperforms
his colleagues within his specialty by more than
150%/170%/200% of the average number of cases, the
service volume of these additional services receives a
deduction of 25%, 50%, and 75%, respectively. As such, the
deduction is roughly comparable to deductions on additionally
negotiated cases in the inpatient sector. This intends to reduce
incentives of SHI physicians to augment the number of services
beyond the average volume of their peers. At the same time, as
the overall budget for all physicians of that specialty is fixed, an
increase in the total number of patients treated leads to a
reduction of the financial amount a physician receives per
patient. Due to that, physicians are dependent on the notion
that their colleagues do not excessively increase their number
of patients. The thresholds of the stepwise depreciation apply
to all KVen. However, selected KVen have decided to suspend
the depreciation for selected specialties, and GPs and/or
physicians who practice in medical shortage areas.
If physicians exceed their quarterly service volume, the

reimbursement of services beyond that is depreciated as well.
It follows a stepwise depreciation as described in the step
above. Each KV determines the steps for each group
individually. As the number of physicians changes quarterly,
the steps change accordingly. The reimbursement of services
which exceed the individual service volume can also be
entirely suspended. This penalty shall incentivise physicians to
remain within their predefined volume.
In addition to their reimbursement stemming from the

morbidity-based aggregate budget, SHI physicians separately
receive reimbursement for extra-budgetary services. In general,
these services are not budgeted. However, in the past, this has
been subject to change. For example, in 2011 and 2012, the
total financial volume growth rate of extra-budgetary services
was limited to 0.75% following larger growth rates in the years
before. As a result, selected KVen introduced cost-containment
measures on extra-budgetary services. Furthermore, they
receive financial contributions from selective contracting
agreements. The specificities of these reimbursements are
based on the individual arrangements in these contracts. By
and large, they are similar to the reimbursement for extra-
budgetary services.
KVen only have to inform SHI funds on how they distribute

their aggregate budget. KVen and SHI funds inspect whether
physicians bill their services correctly. Individual physicians
can sue their KV for reimbursement at the Social Court and do
so on a recurring basis.
The German reimbursement system is overly complex and

fragmented
The current reimbursement system is extremely complex and

bureaucratic. Attempts to improve the SHI’s outpatient system
have increased its complexity and led to diverging incentives.
Since 2005, the reimbursement of SHI services has moved from
a pure FFS-system to a combination of FFS, budgets, and
bundled payments. Since then, physicians receive a lump-sum
payment per patient, which they can bill on a quarterly basis.
The share of lump-sums was increased considerably in 2008
and 2013. For GPs, it ranges around 60% and is generally lower
for specialists (KVRLP, 2017; KVSH, 2013).
Since the early 2000s, the legislature introduced various

modes of selective contracting to increase competition in the
SHI system that bypass the collective agreement (Milstein and
Blankart, 2016). For example, since 2000, SHI funds and
physicians can close integrated care contracts to experiment
with innovative forms of delivery of care. There are more than
6400 integrated care contracts, but this number has not been
updated since 2012 (Milstein and Blankart, 2016). In 2004,
Germany attempted to introduce a gatekeeping system by
introducing GP contracts. Enrollees enjoy slightly lower
premiums but have to use gatekeeping services. In 2017, there
were at least 1200 GP contracts in Germany (BVA, 2018).
KVen have to disentangle services provided in selective

contracting arrangements from those under the collective
agreement, have to reimburse neighbouring KVen if patients
have accessed medical services there, and subtract various
exceptions from the individual physician’s standard service
volume. This poses a significant bureaucratic burden on KVen.
The low financial volume of many of these contracts raises the
questions whether the bureaucratic burden might be worth
disentangling costs.
Budget control performs below potential
The GKV-Spitzenverband criticizes the lack of cost containment.

According to the association, physicians provide an increasing
number of extra-budgetary services as a loophole to escape
budget constraints. In the past 5 years, the share of services
which are not subject to budgeting has increased from 25% to
33%. In addition, KVen suspend budget restrictions for

selected groups of physicians, such as GPs and physicians who
practice in underserved areas. Finally, physicians exceed their
individual budgets despite financial deductions.
Price negotiations between the KBV and the GKV-

Spitzenverband lead to severe disputes on an annual basis
despite having established a joint institute for the calculation
of the different price components. The GKV-Spitzenverband
argues that the reimbursement of physicians has increased at a
much steeper rate than expenditures (GKV-Spitzenverband,
2018d). In return, the KBV argues that increases in the
reimbursement do not keep up with increases in investment
and operating costs.
The KBV and its corresponding organisations on a state level

are also confronted with disagreement from within the medical
community and find themselves in a difficult situation. On the
one hand, they represent the interests of SHI physicians vis-à-
vis the GKV-Spitzenverband and other interest groups, but on
the other hand, they have to enforce budget restrictions,
control medical bills, and revoke medical licensures of their
own members. The split of the aggregate budget by medical
specialty and the prices for selected services within the SHI
medical fee schedule are much contested. For example, over
the past years, GPs have called for an increase in
reimbursements for home visits and higher lump-sum
payments for the provision of basic services.
Reimbursing outpatient services: Private Health Insurance
Similar to the SHI system, PHI physicians are also reimbursed

on a FFS basis. Physicians use a medical fee schedule to
translate their services into points. This schedule is also used
for services which are not provided by SHI and paid on an
out-of-pocket basis by the patients themselves. In contrast to
the SHI system, where the benefit-in-kind principle is applied,
PHI uses the cost-reimbursement principle. Thus, patients
insured under PHI pay their physicians directly. Following from
that, they hand in their bills to their respective PHI fund to
claim the refund of their medical expenditures. Because
physicians are paid directly by PHI patients, they can sue
patients for payment. Patients, in return, can sue their PHI fund
to refund their payments. There is no budget ceiling in place.
For civil servants, the state uses the same reimbursement
mechanism as the PHI.
The medical fee schedule for PHI services is set by the German
Federal Government and has to be approved by the Bundesrat.
In 2018, one point equals €0.0582873. This value dates back
to 2001, when prices in Deutsche Mark had to be converted
into euros. It has not been adjusted since then. The PHI medical
fee schedule consists of roughly 2000 services and more than
900 add-ons for the provision of services to children, during
out-of-office hours, additional diagnostic services, and use of
additional technologies. It functions like the SHI medical fee
schedule.

Figure 12
Thresholds of weighting factors for PHI prices
Physician Technical Laboratory

services services services
Simple factor 1.0 1.0 1.0
Standard maximum 2.3 1.8 1.15
(threshold) factor
Maximum factor 3.5 2.5 1.3
Source: PKV-Verband, 2008.
Physicians can weigh the points for the provision of medical

services with a factor of up to 3.5 (maximum factor) depending
on the medical complexity and time needed to provide the
service (Figure 12). The weighting factors are defined in the fee
schedule as well. For physician services such as personal
consultations, physicians can weight their services with a factor
of up to 2.3 (standard maximum/ threshold factor) without
explanation. Weighting factors beyond this threshold have to
be explained in a written note to the patient and agreed
between both parties. The same applies to technical and
laboratory services, with the thresholds being set at 1.8 and
1.15, respectively. If physicians exceed the maximum factor of
3.5 (2.5 for technical services and 1.3 for lab services) and if
patients want to claim refund for these expenditures,
physicians need written consent from the patient. The patient
has to negotiate with his PHI to confirm whether the PHI covers
the higher medical costs. In 2016, 77.43% of physicians used
the standard maximum threshold factor, 4.18% as a lower one
and the remainder a higher one (PKV-Verband, 2017). The
simple and threshold factor for physician and technical services
were defined in 1982 and have not been changed since. The
maximum factor and factors for lab services were added in
1995 and have not been modified since.
Disputes on how to interpret the PHI medical fee schedule are

resolved by the “central commission on questions concerning
the medical fee schedule” of the BÄK. This commission consists
of four representatives from the BÄK, one member of the
German Federal Ministry of Health, one member of the German
Federal Ministry of the Interior, and one member of the PKV-
Verband. It is headed by a physician who has been appointed
by the board of the BÄK. Next to the interpretation of the
medical fee schedule, this commission is mandated to add
further items as so-called analogue services. These are listed in
a separate list and allow physicians to bill services which are
not officially listed in the PHI medical fee schedule. To some
extent, these items have been proposed by the BÄK and agreed
upon by the German Federal Ministry of Health, the German
Federal Ministry of the Interior, and the PKV-Verband.

The PHI medical fee schedule is outdated, and reforms are
stuck
The current medical fee schedule of the PHI is outdated. It dates

back to 1982, and the latest proper revision of parts of the
medical fee schedule took place in 1995. As a result, many new
procedures, such as minimally invasive surgical interventions,
are not included. Physicians criticize the medical fee schedule
because the value of a point has not been increased since 2001,
and the weighting factors originate from 1982 and 1995.
The BÄK and the PKV-Verband officially began revising the fee
schedule in 2013. This reform attempts to update the schedule
to the latest state of medical innovation. It shall make the
billing of services more transparent, less disputable, and easier
to understand. Furthermore, it is expected to properly reflect
expenditures physicians incur without putting a necessary
financial burden on patients. In a first step the BÄK, the PKV-
Verband, and state representatives (on behalf of civil servants)
agree on a draft proposal which is then reviewed by the Federal
Ministry of Health. All partners have to agree on one joint
proposal, with the German Federal Ministry of Health having
the final decision-making power on the proposal. Upon
approval by that Ministry, the German Government and the
German Bundesrat jointly adopt the new medical fee schedule.
Thus far, 137 medical associations have revised the fee
schedule in working groups and commented on proposals. The
latest proposal adds 2444 new services, increasing the number
of services from 2916 to 5360 (Rheinhardt, 2018). In late 2017,
negotiations on the schedule concluded.
Negotiations on how to price services are still in process. New

prices shall reimburse real costs physicians incur. The
weighting of services will be composed of the labour intensity
of the physician and other staff, technical resources, and
overheads (Rheinhardt, 2018). Each of the four categories will
be composed of a time and a severity factor. The commission
investigates claims data from physicians as well as data on
physician characteristics from the physicians’ registry, the PHI’s
supervising authority, and the Federal Statistical Office, among
organizations. The entire process is accompanied by roughly
300 representatives from medical associations who disentangle
cost data and services from one another. The new schedule will
not include a weighting factor at the physician’s disposal
anymore. Instead, there will be a uniform pricing system which
will be equal to the former prices times a cost weight of 2.3.
To date, it is not clear how comparable prices in the SHI system

are to those in the PHI system. PHI prices which are not
weighted are understood to be roughly similar to SHI prices.
Due to weighting factors in practice, however, expenditures for
PHI services are about two to three times higher than for
comparable services within the SHI sector (Niehaus, 2009).
Besides different price levels, services within the SHI service
are subject to a budget ceiling. This is not the case in the PHI
system, where budgets restrictions do not apply.

PHI funds have little means for cost containment. The PHI
system relies on a reasonable consumption behavior by
patients, which is a very optimistic assumption. Patients are
responsible for controlling their medical bills and to object
when they question selected items, such as the provision of a
service or its weighting factor. PHI funds can close contracts,
which include cost-containing elements with their enrollees.
For example, PHI funds can decide to refund only 80-90% of
the expenditures enrollees incur, and/or only beyond a
predefined deductible, or to only reimburse specialist services
if patients have consulted a GP before.
The dualist system is contested
The dualist structure of prices is highly contested by policy-

makers, patients, physicians, and sickness funds alike; thus,
there have been attempts to change it. The status quo has led
to a heavily distorted outpatient system with preferential
treatment of PHI patients at the expense of SHI patients.
Physicians enjoy considerably higher reimbursements for

services to PHI patients compared to SHI patients for roughly
the same services, and the provision of services is not limited
by budget controls. As a result, PHI patients enjoy lower waiting
times than SHI patients (Roll, Stargardt and Schreyögg, 2011).
Physicians reduce their services to SHI patients at the end of
each billing quarter, such that patients can face difficulties
scheduling appointments with a physician if the physician’s
budget has been exhausted (Himmel and Schneider, 2017).
Thus far, providers and payers have rejected attempts to merge
both systems or to harmonize the reimbursement structure. The
GKV-Spitzenverband fears higher prices and a cost increase for
their enrollees without any substantial gains. The PKV-Verband
fears losing its competitive advantage of low waiting times and
additional services, but at the same time aims to limit its
expenditure growth. The KBV desires to suspend the budgeting
of services. Their position to a joint medical fee schedule
remains unclear. The BÄK has been very outspoken in rejecting
a joint schedule. It fears an overall decrease in the
reimbursement of services, increased supervision, and
interference by the legislature.
The German Federal Ministry of Health has established an

expert commission (KOM-V), which has been mandated to draft
a proposal on how to reform the reimbursement of outpatient
services. A federal reform is earmarked for 2021.
Nursing homes and long-term care
In Germany, LTC forms a separate sector with its own insurance

system. LTC insurance is compulsory for everybody. Those who
are enrolled in the SHI system are automatically enrolled in the
SHI’s LTC insurance as well. Those who are enrolled in a PHI
fund choose among private LTC insurance providers. By and
large, both SHI and PHI funds have to follow the same rules and
regulations. LTC insurance was introduced in 1995. In 2017, 3.5
million inhabitants enjoyed contributions from LTC insurance,

out of which 3.3 million were covered by SHI and the remainder
by PHI (BMG, 2018b). Of all cases, 2.7 million received
contributions to outpatient services, whereas 0.8 million
profited from support for inpatient facilities (BMG, 2018b). As
of 2017, Germany had 14 480 nursing homes. Nursing homes
form a contract with LTC funds at the state level in accordance
with the respective regional authority of social services in
which the nursing home is located (generally, counties). Nursing
homes have to meet infrastructural and staffing prerequisites,
which are set on a federal and state level to be eligible to close
an agreement. Upon successful closing, nursing homes can bill
the SHI’s LTC funds and enrollees. In return, they have to adhere
to federal and state regulations and are subject to quality
inspections by the medical service of the SHI and its
counterpart of the PHI. The following section focuses on
inpatient services in the SHI system.
In contrast to SHI funds, which still enjoy financial surpluses,

LTC insurance incurs losses and has had difficulties to keeping
up with cost increases due to the ageing population. Since its
introduction, the number of people who are dependent on
outpatient facilities in the SHI’s LTC has more than doubled,
from 1 million in 1995 to 2.5 million in 2017. Furthermore, the
amount of people receiving inpatient support doubled from 0.4
million in 1996 to 0.8 million in 2017. In line with these
changes, expenditures have more than tripled from €10.25 in
1996 to €35.54 in 2017 and more than doubled since 2000
(€15.86 billion) (BMG, 2018b).
Financial contributions by LTC insurance are limited depending

on the enrollee’s need for nursing care. If enrollees want to
receive contributions from their LTC insurance, they have to
apply to their insurance and must have contributed to the
insurance for at least two years to be eligible. If so, the medical
service of the SHI assesses the patient’s need and allocates the
patient to one of five levels based on the physical, medical,
cognitive, and psychological assessments, and the ratings of the
patient’s ability to live independently as well as the patient’s
social interactions. Patients are graded on a scale from 0 to 100
and allocated to one of the levels, accordingly. All patients who
receive care in an outpatient setting receive monthly lump-sum
contributions of €125 for short-term inpatient care, semi-
inpatient services at night, or for services which support
relatives (Figure 12). In addition, they receive a monthly
contribution of €316 to €901 if services are entirely provided
by the family and relatives at home, €689 to €1995 for
professional outpatient services, and €700 to €2005 for
inpatient services.

Figure 13
Monthly contributions to LTC services depending on the care
level in euros
Care level Short-term Care Professional Professional

care provision by outpatient inpatient
(outpatient) relatives services services
Level 1 125 - - -
Level 2 125 316 689 700
Level 3 125 545 1298 1262
Level 4 125 728 1612 1775
Level 5 125 901 1995 2005
Source: BMG, 2018c.
Nursing care charges are negotiated between LTC funds and

individual nursing homes
LTC funds cover nursing and medical care up to the monthly

limit displayed in table 4. Prices are calculated on a per diem
basis, and nursing homes are generally reimbursed monthly
with one month counting as 30.42 days. Prices differ between
levels and mostly reflect the staffing costs of the nursing
workforce, additional personnel, and medical devices and other
material costs. If the monthly sum of nursing care charges is
higher than the monthly lump-sum payment (Figure 13), a
patient has to pay the average difference irrespective of his
level (see section below). Furthermore, the medical service of
SHI funds investigates whether nursing homes bill the services
correctly.
Nursing care charges are negotiated individually between a

nursing home, welfare organisations, and LTC funds whose
enrollees contribute to at least 5% of the nursing home’s
nursing days. These negotiations are subject to state rules and
regulations. Nursing homes can apply for negotiations on their
nursing care charges whenever they deem it necessary. Nursing
homes submit all cost data to the opposing parties including
among others, staffing costs, aggregate patient data, and
infrastructural and material costs. To date, it is not clear which
data nursing homes have to submit. Thus far, only few states
have implemented state-wide regulations on the matter.
By and large, negotiations follow a two-step approach. In the

first step, nursing homes explain why higher nursing care
charges have become necessary and are appropriate, for
example, due to tariff increases, additional personnel, and
increases in material costs (“plausibility check”). If approved,
nursing home cost data is benchmarked with other nursing
homes of similar size in the same county (“external
comparison”). Nursing homes with costs in the lower third are
deemed cost-efficient. Nursing homes above that benchmark
are further investigated.

Negotiations on nursing care charges are limited to six weeks. If
the parties fail to reach an agreement, an arbitration board
decides as the second step. The board is composed of
representatives of nursing insurance funds (both public and
private) and the nursing home on equal terms, a non-partisan
chair, and two non-partisan members. The non-partisan
members are appointed by the decision of the two parties and
drawn by lot if necessary. If they fail to reach an agreement, the
State Ministry of Health appoints. It also supervises the
arbitration board and defines its rules of operation. Both parties
can sue the decision of the arbitration board at the Superior
State Social Court.
Patients contribute to nursing care charges, cover housing

and utilities, education and infrastructural costs
Patients in nursing homes contribute to nursing home costs in

five different ways. First, they contribute to nursing care
charges with a nursing-home-specific copayment. It is the same
for all patients within the nursing home irrespective of their
severity and reflects the average difference of the sum of
nursing care charges minus the sum of lump-sum contributions
by LTC funds. More precisely, nursing homes and LTC funds take
the sum of all nursing care charges at a given date and multiply
it by 30.42 to receive the monthly rate. Then, they deduct all
monthly financial contributions by LTC funds in relation to the
patients’ care levels. Finally, they divide the remainder by the
number of inhabitants.
Copayments have only been harmonized since 2017 to

improve the price transparency and comparability of nursing
homes. Prior to that, copayments increased by level of care. As
a result, patients refrained from applying for level upgrades
despite a deterioration of their health status. Copayments
remain contested, because patients in less expensive care
levels cross-finance more expensive patients. Furthermore, LTC
funds expect a severe cost increase on top of their already
problematic financial situation (Vdek, 2018b). Second, patients
cover costs for housing, including utilities, and meal plans. The
nursing home-specific copayment and costs for housing and
utilities are negotiated between every nursing home on the one
side and LTC funds on the other. As a result, prices vary
between nursing homes. However, they do not vary between
patients within a nursing home, or between a nursing home and
different LTC insurances. If the parties fail to reach an
agreement, an arbitration board decides. Third, patients cover
investment costs of nursing homes including costs for the
building, equipment, and maintenance. In contrast to nursing
home-specific copayments and costs for housing and meal
plans, investment costs are not negotiated, but calculated by
the nursing home in accordance with state law and requires
approval by the relevant authority. The nursing home can sue
the state at the Social Court. Fourth, patients pay a training levy.
This levy varies among states and nursing homes, and the
precise details are set by the state. For example, in selected
states, the training levy only applies to nursing homes which

train nurses, whereas in other states, all nursing homes pay into
a training fund. Fifth, nursing homes can charge patients for
additional costs, such as wellness services, superior housing,
and individual meal plans.
Prices are very heterogeneous
Because prices are negotiated individually and because rules

and regulations are generally often defined at the state level,
prices are extremely heterogeneous. In January 2018, average
prices per stage varied between €1082 in Saxony-Anhalt and
€2331 in North Rhine-Westfalia, excluding training levies
(Vdek, 2018b). Average copayments ranged from €214 in
Thuringa to €841 in Berlin, housing and meal plan costs from
€531 in Saxony-Anhalt to €1004 in North Rhine-Westfalia, and
infrastructural costs from €280 in Saxony-Anhalt to €636 in
North Rhine-Westfalia.
The LTC system was subject to comprehensive reforms in 2016

and 2017. The criteria to quality nursing care have been
widened and loosened. Stages were subdivided from a three-
level scale to a five-level scale to better reflect differences in
care needs. The legislature considerably increased
contributions by LTC funds and added new services to and
stricter regulations on nursing homes, for example, staffing
ratios. As a result, more enrollees have qualified for LTC
contributions, and LTC funds face a much higher financial
burden. Following these reforms, in 2018, calls to increase the
financial contributions by enrollees to LTC funds have emerged.
Different modes on how to distribute the burden have been put
on the table.
4
Conclusions
Thus far, Germany has given preference to high volumes and low
waiting times over cost containment and potential overprovision
of care. It entertains a high density of providers, comparatively
low prices, and reimbursement systems that support high
turnover of patients. This combination has ensured that the
country’s targets are met. This approach works well if countries
want to explore the full potential of the service provision of
their health care providers, but less so if cost containment is a
higher priority.
For the time being, the growth rate of the health care sector and
its subsectors is not anchored to the federal level as it is in the
case of England, France, or the Dutch inpatient sector. Instead,
the growth rates of the inpatient and outpatient sectors are an
aggregate of budget negotiations at lower levels. Germany
records three different ways of negotiating its healthcare
budgets. Budget negotiations in the inpatient sector and nursing
homes take place at the individual level between the respective
hospital or nursing home and the sickness funds or LTF care
funds that cover their residents or patients and are largely based

on the preceding year. Budget negotiations in the PHI’s
outpatient sector are non-existent. Budget negotiations in the
SHI’s outpatient sector take place between the KV and the SHI
funds at the state level and are largely based on the preceding
year plus an increase calculated by a third party. Subsequently,
the KV is tasked with distributing resources among its physicians.
This puts the KV into a delicate position. On the one side, it
represents its SHI physicians and negotiates in their favour. On
the other hand, it has to organize the distribution of financial
resources, making it vulnerable to fights between specialists and
GPs and between specialists. Given that the budget growth
factor is largely calculated at the federal level, the KV is limited
in its potential to succeed in budget negotiations and reduces
the risk that budget negotiations are misused for political
purposes. This dualist role shifts the responsibility for mediating
conflicts among physicians from the government level to the
physicians themselves. It also, however, requires a clear
framework within which the KVen operates. Compared to other
OECD countries, if budget constraints are the overarching
priority, setting a national cap on budget growth rates might be a
more powerful tool than negotiations at lower levels.
In the inpatient sector and the SHI’s outpatient sector, Germany

entertains sophisticated price-setting mechanisms, which are
largely based on real costs providers incur. The calculation of
both the price level and cost weights are executed by a third
party within a defined framework, which reduces the influence
of providers and sickness funds on price setting. These
processes lead to generous data collection that can be used to
monitor and compare the behavior of providers. It is worth
noting that Germany’s inpatient data is the result of the DRG
introduction rather than a prerequisite. To date, Germany could
improve considerably on a more representative sampling of
providers who submit their data. This is particularly apparent in
the inpatient sector. The legislature has responded to this issue
and equipped the InEK with the competency to mandate
hospitals to submit data, but it is not clear yet whether this will
make the price calculation sufficiently representative. In
contrast to other OECD countries, the inpatient reimbursement
is not adjusted based on hospital and environmental
characteristics, such as a Market Forces Mechanism or a wage
index or an adjustment for hospital size. This leads to a
significant distortion in the inpatient sector, and add-on
payments have not sufficiently succeeded in softening it.
The price calculation is accommodated by a complex system to

resolve conflicts. The parties involved can invoke for arbitration
boards at virtually every step of price setting and budgeting.
This may lead to lengthy and cumbersome price setting but
originates from Germany’s historic experience of the partial
suspension of a functioning and objective legislative.
Henceforth, limiting the role of arbitration courts will not take
place. Price setting the PHI’s outpatient sector is largely
outdated and rather opaque in the nursing home sector. In the
PHI sector, however, reforms to update the fee schedule are
being undertaken.
Germany has a chequered history with policy attempts to
contain hospital costs and volumes. Because the country is still
financially sound, policies to reduce budget growth have
difficulties to find a majority. In the inpatient sector, attempts to
reduce the high density of beds, to anchor hospital volumes, or
to limit growth rates have performed below potential. Hospitals
have generally found a way to bypass budget restrictions, but
reductions in hospital beds are countered by severe political
pressure. From a financial point of view, the introduction of
DRGs has gone unnoticed. Attempts to shift surgeries to
ambulatory care settings have resulted in an increase in
outpatient surgeries and inpatient stays because hospitals could
use the increased capacities from the newly opened beds for
additional inpatient stays. Based on Germany’s experience, if
cost containment is the preceding policy goal, singular policies
to target selected parts of the health care budget should be
viewed with caution. England, France, and the Netherlands have
a much more successful experience with setting global budget
growth targets at the federal level, but these have to be broken
down among providers.
In the past, the quality of care has not been understood to be an

integral part of price setting but is an integral part of other
health policy areas. In the inpatient sector, hospitals are obliged
to annually and publicly report their quality results. These
“structured quality reports” have improved quality of care, albeit
not due to changed patient preferences or flows, but thanks to
increased comparisons and benchmarking of hospitals with
their competitors. However, these efforts have been deemed
insufficient. In response, the KHSG has introduced three federal
policies to improve inpatient quality of care: quality contracts,
quality criteria for hospital planning, and P4P. As of March 2019,
the design of a P4P programme is still under discussion.
In the SHI’s outpatient sector, KVen are responsible for ensuring

the quality of care of their physicians. Physicians are subject to
a rigorous quality assessment. All physicians have to participate
in continuous education or face penalties ranging from financial
deductions to the total revocation of licensures to practice.
Physicians who offer additional services, for example, diagnostic
procedures such as ultrasound, long-term ECG, and MRI, or
perform additional treatments and procedures, such as disease-
management programmes and surgeries, have to apply for
additional licensure to bill these services and have to undergo
additional training and meet infrastructural requirements.
Furthermore, they can be subject to annual quality checks,
which can include inspections of the practice and its
infrastructure, or the investigation of patient data and footage of
the procedures. Sanctions range from written notifications to
the entire revocation of the license to practice. In contrast to the
inpatient sector, the results of individual physicians or practices
are not published. In the PHI’s outpatient sector, there is no
quality control. In the past, price setting in the SHI’s outpatient
setting has been used to harmonize the delivery of care and first
attempts to enhance a more comprehensive understanding of

service provision have been made. This, however, has led to a
confusing mixture of different reimbursement schemes with
diverging policy goals. For example, the introduction of lump-
sum payments to SHI physicians has coincided with a perceived
increase in waiting times. As a result, the Ministry of Health now
discusses and experiments with policy options to lower waiting
times.
For the time being, Germany’s healthcare sectors remain strictly

separated and are financed from entirely different budgets. To
improve transparency and continuity of care, the Ministry of
Health has installed a commission to reaffirm the
reimbursement of outpatient SHI and PHI and a working group
of federal and state governments to foster the integration of the
different healthcare sectors (Bund-Länder-Arbeitsgruppe zur
sektorenübergreifenden Versorgung). The first results are
expected in 2020. If countries are serious about the integration
of health services, they should upfront consider harmonising
the different healthcare budgets.
In summary, Germany’s price setting ensures that the budget

increase in health care costs is limited due to limited price
growth rates. Germany has built a sophisticated and rigorous
way to determine prices in the inpatient and SHI’s outpatient
sector, albeit with much room for improvement. However,
because Germany still enjoys a financially sound situation and
has not set cost containment as its overriding policy goal, it
does not operate with caps on aggregate budget growth rates.
The introduction of quality of care and integration as
components of price setting are relatively new and thus still
under construction.

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Development; 2019.

Case study
Japan
Professor Naoki Ikegami
St. Luke’s International University,
School of Public Health
Professor Emeritus, Keio University
Japan
133
Japan
Abstract 135
1 Historical development 137
Before and after Western influence 137

Development of the Fee Schedule 137
2 General structure of the payment system 140
Present health service delivery context 140

Key role of the Fee Schedule 140
Restricting extra billing and balance billing 142
Nationally uniform fees 143
Contents Defining items and the conditions of billing 144
Classification of the service items 145
Reflecting advances in technology 146
3 Pharmaceuticals and medical devices 147
Setting the price of a new pharmaceutical 147

Revising pharmaceutical prices 147
Medical devices 148
4 Revising the Fee Schedule 149
Setting the global revision rate 149

Setting item-by-item revisions 151
Lobbying by provider organizations 153
Monitoring compliance to regulations 154
5 Focused analysis 155
Primary care and specialist services 155

Acute inpatient care 155
Chronic inpatient care 157
Post-acute care and sub-acute care 158
Long-term care insurance services 158
6 Possible lessons for other countries 160
References 162

The following aspects should be noted when reforming the
payment system. First, services are determined not only by the
patient’s needs, but also on how the needs are interpreted by
the physician. As Fig. 1 shows, the definition of “appropriate”
differs according to the physician’s education and training, the
resources available (big urban hospital or rural clinic), and the
method of payment (fee-for-service or fixed salaries). Thus, it
would be difficult to define an “appropriate” package of
services that meets the needs of every patient.
Figure 1
Defining appropriate treatment
Abstract
Always
appropriate
Sometimes
appropriate
Inappropriate
“Appropriate” depends not only on the patient, but also on:

1 Each physician’s experience, including education, training, and
encounters with patients. This tends to be idiosyncratic.
2 Where the physician practices, whether in a rural clinic or a big
urban hospital.
3 How the physician is paid, whether FFS (leading to expansion of
need) or more inclusive payment leading to a contraction of need.
Source: author.
Second, even if there is agreement on the services and the

amount of time required, there is no consensus on how much
physicians should be paid relative to the average worker for
delivering the services. Should their income be twice or ten
times that of the average worker? There are big differences in
this ratio even among high-income countries (Conover, 2013).
The labour costs of nurses and other allied health care workers,
and the extent of task-shifting, also vary across and within each
country. The national average is often used, but whether the
current levels should be maintained is disputed from those
within and outside the health care sector.
The above implies that payment reform should focus less on

economic theory and data from cost studies, and more on
negotiations with physicians and hospital organizations. Japan
once tried to radically redesign its payment system. A huge cost
study was made in 1950, in which truck-loads of data were
collected. However, it was not possible to set fees according to
the standard cost of each service item, because costs varied
greatly across hospitals (Matsuura and Oomura, 1983).
Moreover, the government and the Japan Medical Association
(JMA) had very different ideas on how much physicians should
be paid on an hourly basis when compared with average
workers. Since then, the government has relied mainly on
structured negotiations with the JMA and other provider
organizations in setting and revising fees.
The two major goals pursued by the government have been

containing costs and nudging providers towards policy goals,
such as decreasing the lengths of hospital stays and promoting
home and community care. Whether costs have been contained
is debatable. Total health expenditures to the GDP are 10.7%,
the sixth highest ratio in the world (OECD, 2018). However, the
fact that Japan has the highest percentage of elders 65 and
over in the world (27.7%) and that expenditures for long-term
care (LTC) are relatively high (Campbell et al., 2016) should be
taken into consideration.1 The lengths of hospital stays are still
long, but many “hospitals” in Japan are de facto nursing homes.
Regarding quality, the macro indices of health are excellent,
and the outcomes for specific clinical conditions are the same
or better than those reported for other countries (Hashimoto et
al., 2011). This report will explain how the payment system
functions to provide possible lessons to other countries.
1 The percentage of total health expenditures (THE) to GDP jumped from 9.2% in 2010 to
10.6% in 2011. This occurred only in Japan and is probably due to the fact that virtually
all LTC insurance expenditures were first included in THE from 2011 (IHEP, 2016).

1
Historical development
Before and after Western influence
Payment reform should take a historical perspective because

the physician’s behaviour and values have been rooted in the
past. In Japan, private practitioners were well established by
the middle of the 18th century. At that time, physicians were
paid for the medication they dispensed and not for the services
they provided. It was professionally and legally not appropriate
for physicians to demand payment for services, because
treating patients was a humanitarian act. However, payment for
medication was appropriate, because physicians must earn
their living and the ingredients had to be purchased (Fuse,
1979). At that time, prescribing and dispensing were intricately
linked; physicians were also referred to as “kusushi”
(apothecaries). Dispensing continued to be a major source of
the physicians’ income until well after the end of the Second
World War. At its peak in 1980, payment for pharmaceuticals,
which would include the profits providers made from
dispensing, composed 38.7% of national medical expenditures
(Kenkou Hoken Kumiai Rengoukai, 2017).
The development of hospitals was also different. In Western

countries, hospitals began as charity institutions for the poor. In
Japan, hospitals were built by the government from the latter
half of the 19th century as part of the general policy to
Westernize the country. The objectives lay in the following:
treating soldiers, educating medical students, and isolating
patients who had communicable diseases. However, these
government hospitals remained few. Most hospitals were built
by physicians adjacent to their clinics for patients who were
able to pay. As a result, there was no clear distinction between
clinics and hospitals. In general, hospitals did not provide
nursing care. Patients were cared by their families, and nurses
were trained to assist physicians. It was only after the reforms
made by the occupying forces after Japan was defeated in
World War II that patient care was legally defined as a nurse’s
responsibility (Ikegami, 2014).
Development of the Fee Schedule
When Social Health Insurance (SHI) was implemented in 1927,

the government became the insurer for the Government-
managed Health Insurance (GMHI), which covered manual
workers employed in small companies with less than 300
employees. At that time, the services were overwhelmingly
delivered by private practitioners who were paid on a fee-for-
service basis for the services and the medications they
dispensed. Thus, in the GMHI’s Fee Schedule, the basic unit
(“point”) was for a consultation that included one day’s dosage
of a basic pharmaceutical (such as bicarbonate of soda)
dispensed by the physician (Aoyagi, 1996). Other fees were set

relative to this basic unit and expressed in points. The Fee
Schedule was very simple and is said to have been designed
overnight by the JMA President (Fuse, 1979).
The conversion rate of the “point” to yen was negotiated

between the JMA President and the Director of the Social
Affairs Bureau in the Ministry of Interior, who was responsible
for the GMHI. The rate was set below the customary level. The
JMA agreed to this rate, partly because GMHI-enrolled patients
composed only a fraction of their patients (other patients
would continue to pay in full) and partly because physicians
would no long be at risk of not being paid. Funding came from
premiums, half of which were levied on GMHI enrollees and
half on their employers, plus another 10% from general
revenues. This subsidy was justified because SHI would make
workers more productive, and thus increase the nation’s wealth
(Shimazaki, 2011). Averting the risk of a socialist revolution was
also an objective. The conversion rate varied in each prefecture:
if the physicians in the prefecture billed more “points” per
GMHI enrollee than the national average, then the conversion
rate would be lower.
The GMHI Fee Schedule was adopted by Society-managed

Health Insurance (SMHI) plans, which enrolled employees of
large companies, and the Mutual Aid Associations (MAA) plans
for public-sector employees in 1943, thus unifying the fee
schedules of all employment-based health insurance (EHI)
plans. In that year, the conversion factor of the “point” to yen
became fixed irrespective of the volume of services. The
war-time inflation and general shortage of supplies had made it
difficult to set the conversion rate based on the volume of
services delivered.
For those not formally employed, Community-based Health

Insurance (CHI) plans were legislated in 1938. CHI was focused
on improving the health of the rural population, which
composed more than half of the total population at that time.
The army needed to draft more men because of the escalating
war with China. Strong pressure was put on municipalities to
establish CHI plans. To pay providers, each plan could set its
own way of payment and individually contract with providers.
In rural areas, the facility established and operated by the CHI
was de facto the only provider of services. Few CHI plans
contracted with providers outside of their prefecture.

In 1956, the government formally announced the
implementation of Universal Health Coverage (UHC) in order to
establish a welfare state. By that year, the country’s GDP had
recovered to the level before the Second World War had
started. UHC was achieved not by restructuring the SHI system,
but by expanding CHI. The CHI New Act legislated in 1958 had
the following mandates:
1. All municipalities must establish a CHI plan for their

residents
2. Everyone residing in the municipality not enrolled in an EHI

plan must enroll in the municipality’s CHI plan
3. All CHI plans must adopt the Fee Schedule of the EHI
The first mandate forced big cities, such as metropolitan Tokyo,

to establish CHI plans. The second mandate forced everyone to
enroll in a SHI plan. The two mandates led to the whole
population becoming covered in 1961. The third mandate led
to both services covered and payment to providers becoming
the same for all SHI enrollees.2 In order to finance the
expansions of benefits, the national government increased its
subsidies to CHI. Subsidies to GMHI had to be also increased
because the income level of their enrollees who were
employed in small companies was lower than that of SMHI
enrollees. These subsidies from general revenues now compose
a quarter of SHI expenditures, amounting to a tenth of the
national government’s general expenditures budget and twice
that for defense (Ikegami et al, 2011). As a result, the revision of
the Fee Schedule has become an integral part of the budgeting
process, as will be explained later.
2 Those on public assistance are not enrolled in SHI. However, they are entitled to the same
benefits, and the providers are paid according to the fees set in the Fee Schedule.

2
General structure of the payment system
Present health service delivery context
The number of physicians per 1,000 population is relatively

low at 2.43 (OECD, 2018). Some 32% practice in clinics, and
63% in hospitals. Among clinics, the greater majority are
proprietary-owned solo practices (MHLW, 2018a). Physicians
based in clinics do not have access to hospital facilities, and the
majority focuses on primary care services. Among hospitals,
virtually all physicians are employed by the hospital, and their
wages are generally set based on their seniority and do not
reflect the revenue they generate for the hospital.
The number of hospital beds per 1,000 population is high at

13.1 (OECD, 2018). Of these beds, 57% are general beds for
acute and post-acute care. Among hospitals, 69% have less
than 200 beds (MHLW, 2018c), and 81% are in the private
sector, which in many cases are owned by the physicians’
family. In general, high-tech care tends to be provided by
public or quasi-public sector (such as the Red Cross) hospitals,
and post-acute care and chronic care by the private sector.
Investor-owned for-profit organizations are not allowed to open
hospitals. The hospital director must be a physician who
usually continues to practice.
Key role of the Fee Schedule
Although the delivery system is fragmented, it is effectively

controlled by the Fee Schedule. As Fig. 2 shows, the Fee
Schedule simultaneously sets the benefits for enrollees of all
SHI plans, and the service fees and the prices of
pharmaceuticals and devices for virtually all providers in Japan.
Both physician fees and hospital fees are listed in one Fee
Schedule. In principle, payment is made to the facility and not
to individual physicians. From this revenue, providers pay
wages, purchase pharmaceuticals and other material, and retain
profits so that investment can be made to meet future needs.
This system may seem at odds with the fact that the Fee
Schedule was originally designed to pay for the services of
private practitioners. However, at that time, services were
overwhelmingly delivered by solo-practice clinics, so that
paying the clinic meant paying the physician.

Figure 2
Role of the Fee Schedule in Japan
Plans: Multiple Single payment Providers: Private

sector dominated
– Employment-based
plans (1,500 plans) – Hospitals (80%)
Fee Schedule
– Community-based – Physician offices
plans (1,800 plans) (95%)
Defines benefits
Sets price and
conditions for
billing
90%+ of providers’ revenue from
services delivered at prices set by
Fee Schedule
Source: author.
The fees are officially set by the Ministry of Health, Labour and
Welfare (MHLW) and are revised every two years based on the
decisions made by the Central Social Insurance Medical Council
of the MHLW.3 This Council is composed of seven members
from payers (SHI plans, business and labour groups), seven
members from providers, and six members who represent
public interests (academics), plus ten specialist members
(representing nurses, pharmaceutical and device industries,
etc.). However, council members do not vote. Indeed, the six
members representing public interest are not allowed to speak
unless asked by the chair (Morita, 2016). The Council exists to
authorize negotiations that the MHLW officials in the Medical
Affairs Division of the Health Insurance Bureau have made with
provider organizations, such as the JMA, hospital associations,
and specialist groups.
People in the Medical Affairs Division number 84 in total,

including 20 physicians, 2 dentists, 2 pharmacists 2 nurses, and
12 career bureaucrats, with the rest being administrative staff.
None have received formal training on the Fee Schedule, and
except for the administrative staff, they are rotated every two to
three years to different positions within the MHLW. However,
they are responsible for all the work needed to revise and
manage the Fee Schedule. The only exceptions are ad hoc
studies contracted out to private companies on a tender basis.
3 Services not listed in the Fee Schedule include normal delivery (when SHI was first
legislated, the enrollees were manual workers and male) and preventive services such as
health screening. Services covered by accident insurance and other publicly funded
programs use the fee schedule.

Restricting extra billing and balance billing
The percentage of providers’ revenue not controlled by the Fee

Schedule is about 10% on average from the data available
(MHLW, 2017b).4 The services that hospitals can set prices and
directly charge patients are very limited. Extra billing, that is the
billing of services and pharmaceuticals not listed in the Fee
Schedule together with those listed, is mainly limited to new
technology being developed by the hospital. Before being
allowed to extra-bill the patient, the hospital must submit a
request to the MHLW. If approved, the hospital conducts
clinical trials to collect data on the service’s efficacy and safety.
If the results are positive, then the procedure would be
approved and listed in the Fee Schedule, with its fee reduced
from the amount that had previously been extra-billed. This
was how heart transplants came to be listed in 2006 (Japan
Organ Transplant Network, 2006).
Balance billing, that is billing the patient for the balance

between the fee set by the Fee Schedule and the fee set by the
hospital, is mainly limited to beds with better amenities.
Hospitals may only balance bill if the bed meets amenity
standards set by the MHLW and the proportion of the extra
charge for beds in the hospital is less than 50% of the total for
private sector hospitals and less than 30% for public hospitals.
Note that physicians are not allowed to balance bill no matter
how renowned they may be. “Gifts” (money packets) used to be
given, but this is now much less prevalent.
Other than the above exceptions, if the patient wants to receive

services or pharmaceuticals not covered by SHI, then he or she
must pay for all costs out of pocket and not just the extra- or
balance-billed amount. If a hospital was later found to have
extra-billed or balance-billed patients for services not
permitted, it must return the entire amount that they had billed
the insurance plan for the services covered by SHI. Because of
the benefit-in-kind principle, the bill cannot be divided into
covered and uncovered services (except for those explicitly
allowed). This strict interpretation has been attacked by pro-
market economists as restricting the patient’s choice (Ikegami,
2006). However, only minor concessions have been introduced,
such as increasing the number of healthcare facilities that can
extra bill non-approved pharmaceuticals mainly for cancer.
Because of these restrictions, complimentary private health

insurance has not developed. The MHLW has maintained that
all services and pharmaceuticals which have been evaluated
for their efficacy and safety will be listed in the Fee Schedule.
Substitution private health insurance plans do not exist in
Japan because all residents in Japan are legally required to
enroll in SHI plans. Thus, although 88.5% of households are
enrolled in private health insurance plans (Seimei Hoken Bunka
4 The revenue from extra-charge beds and from preventive screening services are 1% each.
8% comes from non-health care activities. This ratio is 16% in local government
hospitals because of subsidies, but is only 2% in private hospitals (earnings from
investments). Disease-specific hospitals (such as for psychiatry) and hospitals that derive
2% or more of their revenue from LTC Insurance services are excluded from these data
(MHLW, 2017b).

Center, 2018), they have not played a role in the setting or
negotiating of prices in Japan. The greater majority offer cash
benefits, irrespective of the out-of-pocket amount, for the days
hospitalized or the visits made, or as a lump sum, when
diagnosed and treated for cancer or other serious diseases.
The basis of these strict rules on extra billing and balance

billing lies in the fact that SHI benefits are in kind (services) and
not in cash (as would be the case for an indemnity insurance
that reimburses part of the costs incurred by the enrollee). This
principle dates to days when SHI was first implemented. At that
time, there were no coinsurance, and the SHI plan paid
providers directly for the services delivered to their enrollees.
This benefit-in-kind principle has been maintained even after
coinsurance was levied on dependents when they were
covered in 1938 and later in 1984, when coinsurance came to
be levied on the employees themselves.
Nationally uniform fees
The same fee is set for the same service throughout Japan. As
previously explained, when the Fee Schedule was first
introduced, the conversion rate of the points to yen differed
according to the volume of services that had been delivered in
each prefecture. However, the conversion rate became fixed in
1943 regardless of the volume. At that time, there were three
rates reflecting urban-rural differences in the cost of living. This
was reduced to two rates in 1948 and became one rate in 1963.
The fact that fees are nationally uniform may have contributed
to a more equitable distribution of physicians and nurses. All
facilities receive the same fee for delivering the same service.
Out of this revenue, big city hospitals can recruit physicians at
relatively low wages because they offer non-monetary rewards,
such as allowing them to focus on their sub-specialty and to
use high-tech equipment. However, they must pay nurses
higher wages because the cost of living is higher. In rural
hospitals, the reverse is true: there are higher wages for
physicians and lower wages for nurses. Supporting data are
available from public hospitals. In hospitals established by big
cities (over 700 000 inhabitants), the annual wages were 13.6
million yen for physicians and 5.1 million yen for nurses. In
hospitals that are established by towns and villages (less than
30 000 inhabitants), the wages were 17.9 million yen for
physicians and 4.6 million yen for nurses (MIAC, 2017).
Although there are no data for private sector hospitals, the
differences are likely to be greater because their wages tend to
be less seniority based.
The extent to which paying the same fee for the same service
item has contributed to a more equitable geographical
distribution of physicians and nurses is difficult to evaluate.
However, as a method, it is simpler than setting fees to reflect
the cost of living and then paying a bonus to physicians who
work in rural hospitals. Currently, the age-adjusted per capita

medical expenditures differ by a quarter between the highest
and lowest of the 47 prefectures (MHLW, 2017a).
Defining items and the conditions of billing
Providers are basically paid on a fee-for-service basis for the

service items they have delivered. Each item is precisely
defined. As an example, the fees for physician consultations are
divided into the fee for an “initial” visit and a fee for a “repeat”
visit. The fee for the former is four times that of the latter,
reflecting the fact that the time and effort required for an initial
consultation are much greater than that required for a repeat
consultation. In the Fee Schedule, an “initial visit” is defined as
a visit made 29 days or more from the previous visit and
without having the physician ask the patient to make the next
visit 29 days or more after the previous visit.
Conditions of billing effectively control the volume of each

item. They have been set to contain costs and assure quality.
For example, to bill for rehabilitation therapy, the hospital must
employ more than the defined minimum number of
experienced physicians and therapists, have a therapy room
with a floor space of 150 m2 or more, and so forth. To target
resources and contain costs, patients must have had a stroke
within 180 days, an injury within 150 days, and so forth.5 For
positron emission tomography (PET) scans, the hospital must
meet facility standards such as having an experienced
radiologist on site, and patient standards such as those who
have a confirmed diagnosis of cancer (so that it cannot be
billed for screening purposes). To bill for the bonus of
managing the dietary needs of inpatients, the physician and
staff must have attended designated seminars.
The most complex conditions have been set for basic

hospitalization fees. The general rule has been higher fees for
higher nurse staffing levels. This was introduced in 1951 as an
incentive for hospitals to hire more nurses and not depend on
the family for the care of the patient. Since then, the Japan
Nursing Association (JNA) has lobbied to increase the staffing
ratio to improve labour conditions and enhance their
professional status. In addition to the staffing level, night duty
must be less than 72 hours per month, and the proportion of
registered nurses (as opposed to licensed practical nurses) in
the hospital must be 70% or more. Work intensity was initially
only measured by the hospital’s average length of stay: 18 days
or less for the billing of higher staffing levels. However, from
2006, more specific conditions, such as the proportion of
patients in the unit who have had a major surgery or have
cognitive problems and so forth have been added and have
since been made more detailed.
5 The period is extended to patients who have designated diseases. Maintenance

rehabilitation is provided by the long-term care insurance.

These definitions and conditions of billing have made the Fee
Schedule very complex. In 1960, the manual had only about
100 pages. The 2018 version has more than 1700 pages in fine
print, with about 4000 items and conditions of billing listed. In
addition, there are separate manuals for the DPC (Diagnosis
and Procedure Combination; the Japanese version of the
Diagnosis-related groups [DRGs]) grouping book, for
pharmaceuticals and devices.
Classification of the service items
Physician and hospital service items are classified as below. In

each section, items are identified by a three- or four-digit code.
For many items, the patient’s and facility’s conditions for billing
are set. Note that Section F, Prescribing and dispensing, and
Section G, Injections, are independent sections despite the fact
they compose only two pages each, reflecting their historical
importance. Section C, Home care services, became a separate
section in 1988 in recognition of its expanding role.
__ A. Basic outpatient consultation and inpatient fees
__ B. Specific outpatient consultation and inpatient fees
__ C. Home care services
__ D. Tests (laboratory and physiological)
__ E. Imaging
__ F. Prescribing and dispensing
__ G. Injections
__ H. Rehabilitation
__ I. Psychiatric treatment
__ J. Procedures (of eyes, ears, etc.)
__ K. Surgical operations
__ M. Anesthesia
__ L. Radiation therapy
__ M. Pathological diagnosis
__ Medical procedures performed in LTCI health facilities for

elders

Reflecting advances in technology
New items will be listed in the Fee Schedule if they are

clinically distinct from existing ones and have significantly
higher costs. For example, laparoscopic surgery was listed when
it came to be widely used. Their fees are set 10% to 70%
higher than that of an open surgery to compensate for the cost
of the laparoscope and the skills needed to perform the
procedure. The physicians’ specialist associations submit a
request, which is reviewed by the MHLW. If justified, the item
will be listed in the Fee Schedule at the time of the biennial
revision.
For equipment, fees are based more on their efficacy and less
on costs. When magnetic resonance imaging (MRI) was first
listed in 1982, its fee was set at twice that of computed
tomography (CT) scans. At that time, the price of purchasing a
MRI equipment was more than ten times that of purchasing a
CT scanner (Hisashige, 1994). However, despite the low fee,
providers purchased MRI equipment because it attracted more
physicians and patients to the hospital. Meanwhile, the
manufacturers gradually lowered the price of MRI equipment,
which led to more hospitals purchasing the equipment. Thus,
market forces have worked even when fees were regulated, and
probably worked better because they were regulated.
Note that there is no government or quasi-government agency

that is officially responsible for systematically conducting
technology assessments. However, there is an expert committee
within the MHLW that evaluates requests for new technology to
be delivered as an extra-billed item, assesses efficacy based on
the data collected, and recommends listing in the Fee Schedule.
The division in charge of the Fee Schedule serves as the
secretariat. Pharmaceuticals and devices are evaluated for
efficacy and safety, but their costs are independently
calculated. This will be described in the next section.

3
Pharmaceuticals and medical devices
Setting the price of a new pharmaceutical
Pharmaceutical companies must conduct clinical trials

according to the guidelines set by the Pharmaceuticals and
Medical Devices Agency (PMDA), an independent government
agency. The PMDA evaluates the product’s reliability based on
ethical and scientific standards, and its efficacy and safety
based on effectiveness standards. The Agency then gives a
recommendation to the Pharmaceuticals Affairs and Food
Safety Council of the MHLW to list the product in the National
Formulary. When doing so, the dosage and the clinical
conditions for on-label use will be specified in detail.
After approval, the Pharmaceutical Price Organization of the

Central Social Insurance Medical Council evaluates the
product’s innovativeness, efficacy and safety, based on which it
recommends the price. If the new product has a comparator, the
price will be based on the comparator, with mark-ups for
innovativeness, efficacy and safety. If there is no comparator, it
is set by calculating the costs of research and development
(R&D) and production based on the method set by the MHLW.
The product’s sales volume as estimated by the manufacturer
will also be a key factor. If the volume is predicted to be small,
then a high price will be set to allow the company to recover its
R&D costs. The list prices in the USA, UK, Germany and France
are also used to set the Fee Schedule price; the price must be
set less than 1.25 times and more than 0.75 times the average
price of these countries.
The government officially started to use pharmaco-economic

analysis from 2019. The analysis is performed by the
manufacturer, and the results are evaluated by the MHLW. The
results will not be used to decide whether the product should
be listed in the Fee Schedule but are used to provide additional
data for setting the price. However, since the price of the new
product is determined by many factors, the impact of the
pharmaco-economic analysis results on the price are not clear.
Parenthetically, the use of willingness-to-pay studies has been
tabled because of the difficulties in conducting and
interpreting the results (MHLW, 2018b).
Revising pharmaceutical prices
Pharmacies, hospitals and clinics purchase pharmaceuticals

from wholesalers at prices which are usually lower than that set
by the Fee Schedule.6 They may retain the balance. To contain
6 For this reason, dispensing used to be done by hospitals and clinics. However, the profit
margin has decreased, while the fee that physicians can bill if they dispense to a
free-standing pharmacy has increased. The ratio of prescriptions dispensed within
hospitals and clinics has declined to 30% of the outpatients’ prescriptions (Federation of
Social Insurance Associations). However, many of the pharmacies have strong ties with the
hospitals and clinics that write the prescriptions. To discourage this trend, dispensing fees
are reduced if the proportion of prescriptions from one hospital or clinic is more than
70% of the total number.

costs and the profits providers derive from dispensing
pharmaceuticals, the MHLW conducts a survey of the
wholesalers’ and providers’ books to calculate the volume
weighted market price of every pharmaceutical product listed
in the Fee Schedule. Based on these data, the MHLW revises the
Fee Schedule price so that it will be just 2% higher than its
volume weighted market price.7 This rule applies for both
brands and generics (generic products are “branded generic” in
which each has its specific Fee Schedule price).
In addition to the above mechanism, prices will be reduced for

new products that have sales greater than had been predicted
by the manufacturer. The government justifies this reduction
on the grounds that the manufacturer would be able to recoup
the investments made for research and development from
increased sales. For example, the price of OPDIVO was halved
in 2017 following the expansion in the clinical conditions of
its use.
Medical devices
Expenditures for devices are about one tenth that of

pharmaceuticals. They have many characteristics in common,
such as being produced by for-profit companies. However, the
price of devices is set by the functional group into which the
device is categorized. A new functional group will be set only
when the new device differs significantly from an established
group. For example, coronary stents are categorized only into a
drug-eluding functional group and a non-drug-eluding
functional group. There are now 212 functional groups for
devices. The hospitals will only be reimbursed at the functional
group price. The hospital might have to pay more than this
price for a stent made by a manufacturer, but it is not allowed
to balance bill the patient.
The price of a functional group is revised using basically the

same method used for pharmaceuticals, but with the volume
weighted market prices of the device by each manufacturer
aggregated at the functional group level. For example, if the
market price of a drug-eluding stent made by Manufacturer X
having a 20% market share in volume is found to be 10%
lower than its Fee Schedule functional group price, then the
price of the functional group is reduced by 2%.
7 The method for revising pharmaceutical Fee Schedule prices has changed. When the
survey-based method was first introduced in 1967, it was set at the 90th percentile from
the lowest price; it became the 81st percentile in 1983 and, from 1987, was based on the
volume-weighted average. The allowable margin (the “reasonable” zone concept) was
introduced in 1994 in response to demands from the United States to make the
transaction process more transparent as part of the Market Oriented Sector Selective
negotiations. The “reasonable” zone was initially set at 15% but has since been gradually
decreased to the present 2% from 2000.

4
Revising the Fee Schedule
Revisions of the Fee Schedule are made every two years for
service fees and every year for the price of pharmaceuticals
and devices (CAO, 2017).8 The process is composed of the
following three steps: first, setting the global revision rate;
second, revising pharmaceutical and device prices, and third,
revising service fees on an item-by-item basis. The global
revision rate sets a de facto global budget for health
expenditures within which the prices of pharmaceuticals and
devices and the fees of service items are revised. Although the
revisions may not be publicized in this order, and the global
rate might have to be finely adjusted to reflect the terms
negotiated in the second and third steps, the process is easier
to understand if explained in the order below.
Setting the global revision rate
The first step is deciding the global revision rate, which sets a
de facto global budget for all SHI and public expenditures in
the next fiscal year. Next year’s expenditures are determined by
the equation below:
This year’s expenditures Ú[1 + (the
increase rate from population ageing
Next year’s expenditures =
+ the increase rate from “other”
factors) ± (global revision rate)]
The impact of population aging is calculated from changes in

the population for each five-year age group. As Fig. 3 shows,
expenditures vary greatly by age group. For example, the per
capita expenditures of the 75-79 age group are ten times more
than that of the 35-39 age group so that the increase in the
75-79 population will have much greater impact on
expenditures than the decrease in the 35-39 population. It is
assumed that per capita differences in health expenditures
across age groups will remain the same.
8 Pharmaceutical and device prices will be revised annually from 2018 so that any
decreases in market price are reflected more quickly in the Fee Schedule. The first
revision in which they are revised independently from service fees will be made in 2019.

Figure 3. Per capita health care expenditures by five-year age
group in Japan (2013)
100~
95-99
90-94
85-89
80-84
75-79
70-74
65-69
60-64
55-59
50-54
45-49
40-44
35-39
30-34
25-29
20-24
15-19
10-14
5-9
0-4
0 20 40 60 80 100 120
(in 10,000 Yen)
Source: MHLW, 2018b.
Increases not due to aging (i.e., residuals) are referred to as

“other factors.” This is calculated by subtracting the annual rate
of increase for aging from the increase rate of health
expenditures, and then averaging the rates of the past three
years. Population aging and “other factors” combined have
increased health expenditures by about 2 to 3% every year.
Thus, if the global revision were set at -4 to -6%, then
healthcare expenditures will remain the same because this
would cancel out the increases due to population aging and
“other factors” in the next two years. This is why the Ministry of
Finance (MOF) would like to set the global revision rate at -6%.9
As has been noted, the national government’s allocation to
health care is one of the largest items in the budget, composing
about one tenth of the total. This proportion has been relatively
stable because the national government’s contributions to SHI
plans are statutory defined and the national budget has
increased at about the same pace as that of SHI expenditures.
However, a -6% global revision rate would be vigorously

opposed by providers. They would protest that a decrease of
this magnitude would bankrupt them, thus denying access to
patients. To arrive at a middle ground, the revision process
begins with the two ministers of the MOF and MHLW, together
9 The greatest decrease so far was in 2006. The -3.16% revision rate was blamed for the
closing of hospitals, resulting in newspaper headlines such as the “collapse of the
healthcare system.” Decreases of this magnitude would be politically difficult to make in
the future.

with their top civil servants, discussing possible options. The
final decision is made by the prime minister based on his
evaluation of the political and economic situation. This decision
will be made in mid-December annually, so that the national
budget can be set before the country shuts down at the end of
the calendar year (which will allow the new fiscal year to start
smoothly from April).
In making this decision, the following two factors play key roles.
One is the market survey of pharmaceutical prices. If the survey
shows that the cumulative volume weighted market price of
pharmaceuticals is 8% below the Fee Schedule price, then
after allowing for the 2% margin, cumulative prices will be
reduced by 6%. This 6% reduction will increase the global
budget for medical services by 1.5%, because pharmaceuticals
compose about one quarter of medical expenditures. In
addition, there will be further savings by reducing the prices of
new products that have sold more than the amount estimated
by the manufacturer. These savings have been used to negate
or soften the impact of decreases in the global revision rate.
However, in the 2020 Fee Schedule revision, they would have
less impact because pharmaceutical prices would already have
been revised in 2019 to reflect the results of the 2019 market
price survey.10
The second factor is data on the financial conditions of

healthcare facilities from the Health Economic Survey (MHLW,
2017b). This survey is conducted in the year preceding the Fee
Schedule revision, and the results should show that the facility
expenditures are balanced by the facility revenues.11 If the
results show that the deficit has increased, it would be difficult
for the MOF to argue for a negative revision rate. On the other
hand, if conditions have improved, it will be difficult for the
MHLW to argue for a positive revision rate. However, the results
tend to differ by the type of provider. Thus, the Health
Economic Survey tends to have more impact on how resources
will be allocated among the various types of providers in the
item-by-item revisions.
Setting item-by-item revisions
The global health care budget is appropriated to the medical,

dental and dispensing services based on the relative share of
each. About 80% of the total service budget is appropriated for
medical services. Next, within the global budget, item-by-item
revisions are made based on the equation below:
∑ (Fee of each item revised ) Ú
Global budget for (Volume of each item increased or decreased
medical services = by loosening or tightening the conditions of
billing)
10 Service fees will be revised together with pharmaceutical prices in October 2019,
because of the introduction of the consumer tax. This tax is not levied on health care
services so that fees and prices listed in the fee schedule must be increased to pay for the
additional costs incurred by the providers.
11 With the exception of local government hospitals (as noted in reference 4), the proportion
of subsidies is small. National hospitals have not received subsidies after they were
reorganized into the National Hospital Organization in 2004 (Ikegami, 2014).

The left and right sides of the equation must be equal. That is,
the cumulative effect of revising each item fee and its
conditions of billing must be equal to the amount that has been
set by the global rate and the increase rate from the “natural”
increase and the savings that have been made from reducing
pharmaceutical prices. The adjustments are made in a huge
spreadsheet, in which item fees are individually revised so that
the cumulative amount would be equal to the global budget.
The volume of every item is available from the National Claims
Database (NDB), which is compiled from the claims submitted
by providers. Although the effect of tightening or loosening the
conditions of billing on the volume cannot be predicted
exactly, if the volume were to increase sharply, then the
conditions of billing could be tightened in the next Fee
Schedule revision or revised by ad hoc directorates from the
MHLW if more immediate actions are needed.
Note that even small changes would have a big impact on costs
if the volume is large (such as repeat consultations), while big
changes would have little impact if the volume is small (such as
complicated surgical procedures). Revisions could be targeted
on specific items. For example, MRI fees have generally been
decreased because their volume has increased rapidly, and
because the price of purchasing a MRI equipment had been
driven down as manufacturers competed to sell their products.
The MHLW reported that increases in expenditures were
blunted when fees were reduced by 30% in 2006 (MHLW,
2018c). Reductions of this magnitude had to be made to
contain expenditures to the amount set by the global revision
rate of -3.16%. Since then, fees have been increased for MRI
equipment that have higher density in their imaging. These
increases have been offset by reducing the fees of MRI
equipment that have low density.
In general, fees have been revised to achieve the following

policy objectives:
1. To contain expenditure increases by lowering the fees of

items that have had rapid increases in volume and/or can be
delivered at lower costs by providers.
2. To maintain appropriate profit levels across all hospital types

so that they can continue to deliver services and make
investments for future needs.
3. To provide incentives to physicians to deliver services in line

with policy goals such as providing end-of-life care at the
patient’s home.
If providers do not deliver services in line with policy goals,

then the conditions of billing could be rewritten in the next
revision. Thus, item-by-item revisions could be regarded as a
pay-for-performance (P4P) payment implemented at the
national level.

Lobbying by provider organizations
The above does by no means suggest that providers have been

passive in the Fee Schedule revisions. On the contrary, they
have vigorously lobbied for an increase in the global revision
rate. However, once the global revision rate is set, then the
item-by-item revisions divide providers into those who gain
and those who lose, which can facilitate negotiations for the
government. Moreover, the JMA, which is the best organization
among providers, has focused on increasing payment for
primary care services, because their most powerful constituents
are private practitioners. For example, the JMA lobbied for a
new fee that physicians can bill for giving directions on
improving lifestyle to patients with diabetes, hypertension or
hyperlipidemia. This fee was introduced in the 2002 Fee
Schedule revision. Billing of this item has been restricted to
clinics and hospitals having less than 200 beds.
The Association of Surgical Specialties for Social Insurance

succeeded in increasing surgical operation fees by 30% in the
2010 Fee Schedule revision. This revision was based on the
results of their 2007 report (Gaihoren, 2007). The Association
had conducted its first cost study in 1982. However, the
increase owes much more to the change in the ruling party
which brought in a surgeon as the vice minister. The
Association’s success prompted the Association of Internal
Medicine Specialties for Social Insurance to conduct similar
studies, but these have not had a similar impact.
The JNA has been lobbying for increases in basic

hospitalization fees. As noted, to bill for higher basic
hospitalization rates, the hospital must not only have to meet
nurse staffing levels, but also the percentage of registered
nurses must be 70% or more, and the night duty hours be less
than 72 hours per month. When a higher level was introduced
in the 2006 Fee Schedule revision, hospitals rushed to meet
the required level because the increase in their revenue would
more than offset the cost of hiring more registered nurses.
However, in the 2018 revision, the JNA suffered a set-back
when the higher fees were made more dependent on the
patient’s acuity level.
As the above examples illustrate, revisions of the Fee Schedule

tend to be determined by politics. Perhaps for this reason,
hospitals have not conducted cost studies that drill costs down
to the level of each item. Instead, they have focused on the
revenue and expenditure of clinical departments to decide
which departments should be expanded or reduced. Studies
have shown that the clinical departments that are more
weighted to inpatient care, such as surgery, orthopedics and so
forth tend to have bigger profit margins than those weighted to
outpatient care such as dermatology (IHEP, 2008). This is
because the Fee Schedule is structured to discourage hospitals,
especially big hospitals, from delivering primary care services.
Note that the lobbying continues to the last minute so that the
precise details of the conditions of billing may not be finalized
until the middle of March annually, just before the revision is
implemented in April 1, when the new fiscal year begins. This
means that software vendors of claims data must work day and
night to reprogram their claims software. Hospital directors
must estimate their revenue in the revised Fee Schedule, which
may change the method of billing or how services are
delivered.
Monitoring compliance to regulations
Compliance with the Fee Schedule regulations is first checked

by the quasi-government organizations established in Japan’s
47 prefectures. The main role of these organizations is to sort
claims and bill the SHI plans for the services that have been
delivered to their enrollees. However, they have a panel of
renowned physicians in the community who review the claims
and deny payment for items that are not appropriate. These
physicians perform their task about five afternoons per month
for which they are paid about US$ 1500. “Appropriateness” is
evaluated by cross-checking the services and pharmaceuticals
billed with the patient’s diagnosis written in the claims form. If
evaluated as being inappropriate, payment will be denied for
that item. The amount denied composes only 0.3% of the total
billed, but it has had a signal effect of alerting providers on
what is permitted. Both payers (SHI plans) and providers can
contest the decision. The panel will vote in favor of the
contested cases in about one-third of the cases.
The second line check is by on-site “guidance”, which is

conducted by the regional office of the MHLW. “Guidance” is
given to the facility every three to eight years: facilities that had
more problems cited previously will be visited more frequently.
The team, headed by a physician, comes with 20 to 30 claims
forms that had been filed by the facility about six months
before the visit. They will examine the medical records and
closely question the physicians and other staff about the items
billed. Should the documentation and responses be judged as
being inadequate, then that item will be deemed as having
been inappropriately billed. The facility will then be asked to
retrospectively go through the claims filed in the past six
months and return the amount that had been inappropriately
billed. If the amount returned is judged to be too little, then the
audit team will return and go through the records themselves.
The third line check is by “audit”. Should the “guidance” reveal

that the health care facility had intentionally and/or
systematically submitted inappropriate claims, the “guidance”
becomes an audit. The audit may lead to a temporary or
permanent cancelling of the health facility’s contract with SHI,
which would effectively mean shutting down the facility. From
2005 to 2015, only 11 to 54 facilities each year have had their
contracts cancelled, but the threat has served as an effective
deterrent (Kenkou Hoken Kumiai Rengoukai, 2017).

5
Focused analysis
Primary care and specialist services
Primary care and specialist services are not differentiated in

Japan. Most physicians have been trained as specialists.
However, when they go into private practice, most focus on
primary care because they will not be able to use hospital
facilities to perform surgical operations and other complicated
procedures. In contrast, hospital physicians can focus more on
their specialties. However, many of their patients come without
referral, and the physicians tend to continue treating their
patients in the outpatient department after they have been
discharged.
The government has long tried to functionally differentiate

hospitals from clinics by the payment system. Fees have been
set for physicians to write referrals (referred to as “information
provision fees”) from clinics to hospitals and from hospitals to
clinics. However, the functions of hospitals, especially small
ones, overlap with clinics. To take into account subtle
differences reflecting the hospital’s size, some outpatient
service fees differ by the number of beds: 99 beds or less, 100
to 199, 200 to 399, and 400 and above. Incentives have also
been introduced on the patients’ side: if patients visit hospitals
that have 400 or more beds without a referral, they must pay an
additional amount.
Acute inpatient care
A DRG type of payment, the DPC-PDPS (Diagnosis Procedure

Combination – Per Diem Payment System) for the main 80
university hospitals and 2 national centres, was introduced in
2003.12 However, surgical procedures, endoscopic
examinations, rehabilitation therapy, devices, and
pharmaceuticals given on the day of surgery are paid as fee-
for-service. The inclusive part of the payment has the following
characteristics.
Payment is on a per-diem basis and not on a per case basis. The

per diem rate differs according to the four hospitalization
periods which are specifically set for each DPC group. The
periods are revised to reflect the lengths of stay as reported for
each DPC group (Fig. 4).
12 Because service fees and pharmaceuticals are combined in DPC, the global revision rate is
used for revising the DPC base rate.

Figure 4
Diagnosis procedure combination per diem rate for four
periods of hospitalization in Japan
Per diem rate
A } 15% A=B
B
15% or the average input amount of medical
} resources per day for hospitalization period III,

whichever is lower
Hospitalization period I Hospitalization period II Hospitalization period III Hospitalization period IV

25 percentile
50 percentile
Fee-for-service
Average length ALOS + two or more standard

of stay (ALOS) deviations from average
rounded to 30 day periods
Note: DPC: Diagnosis Procedural Combination.

ALOS: Average Length of Stay.
Source: author.
The amount paid by the DPC is weighted by Hospital Specific

Coefficients. For example, the “efficiency coefficient” rewards
hospitals that have shorter lengths of stay after adjusting for
the hospital’s case-mix, and the “complexity coefficient”
rewards hospitals that have more complex patients (higher
volume weighted case-mix index).13
DPC fees were set to be budget neutral. If the hospital had

continued to deliver the same services as it had under fee-for-
service and the patient’s length of stay had remained the same,
then the hospital would receive the same amount of payment.14
However, after adopting DPC, hospitals transferred services such
as MRI to the outpatient department, where they could be billed
as fee-for-service, and discharged patients earlier so that they
would receive higher per-diem payment. This would increase
hospital revenue, which was why the number of hospitals paid
by DPC-PDPS has increased from 82 to 1,730, composing 54%
of all hospital general beds in 2017 (MHLW, 2018c).
However, because patients have come to be discharged earlier,

bed occupancy rates decreased, which may have led to a net
decrease in hospital revenue. On the other hand, quality may
have improved, because services have become more
13 Higher fees for hospitals with higher nurse staffing ratios are determined by another set
of hospital functional coefficients.
14 When DPC was first introduced, there was a hospital-specific conversion coefficient that
compensated for the difference between the fee-for-service payment and the DPC
payment. This coefficient was gradually decreased from the 2012 Fee Schedule revision
and dropped in the 2018 revision.

standardized when payment was standardized. Clinical
pathways have come to be extensively adopted. Physicians no
longer order the drip infusion of antibiotics every day while the
patient is hospitalized. DPC has also led to the development of
an extensive database of the hospital’s case-mix, which can be
used for regional health planning and hospital marketing
purposes.
Chronic inpatient care
Hospitals began to provide chronic inpatient care when

medical care for persons 70 years and older was made free (no
copayment) in 1973. At that time, there was no other form of
payment aside from fee-for-service, which led to over-
medication and the excessive ordering of diagnostic tests in
chronic care units. There were also not enough nurses because
patients in chronic care hospitals faced long stays, that did not
meet the conditions of billing that would allow chronic care
hospitals to bill higher basic hospitalization fees. Care was
delivered by private attendants who were hired by the patients
to provide care 24/7. The presence of these attendants
exacerbated crowding in the units: at that time, the floor space
per patient was only 4.3 m2 (this standard was set by the
government in 1948, reflecting the housing conditions at
that time).
In response, a new type of facility, the health facilities for

elders (HFE), was established in 1986. Payment was a flat
inclusive per diem amount. The HFE had to meet staffing levels,
to have a floor space of more than 8 m2 per bed and were
forbidden to hire private attendants. Hospitals providing
chronic care were encouraged to convert to HFE. However,
because it was difficult to meet the minimum floor space
standards, very few hospitals actually did so. For this reason,
the government introduced a new form of payment for LTC
hospitals in 1990, similar to the HFE, but with no floor space
requirements. In the 1992 revision, a bonus payment was
added if the hospital unit met the condition of “convalescent
beds:” a floor space of more than 6.4 m2 per bed, a dining room,
and so forth. Because these standards were easier to comply
than the standards for HFE, nearly all chronic care hospitals and
units converted to convalescent beds so that by 2003, it
became the de facto standard.
However, the flat per diem payment led to the perverse

incentive of not admitting patients with high medical needs. To
rectify this situation, case-mix-based payment was introduced
in 2006 that was based on the patient’s medical acuity and the
activities in daily living (ADL) level (Ikegami, 2009). The fees for
patients with the lowest medical acuity level were set below
costs. The MHLW thought that hospitals would discharge these
patients and close some of their chronic care units. However, a
survey made one year after the introduction revealed that
hospitals had not done so. They appear to have reclassified
patients to higher medical acuity levels. Problems in the quality
of care and data were also revealed: in one hospital, over 80%
of patients had been checked for urinary infection, which
grouped the patients into a high medical acuity level. Some of
these issues may have been rectified by on-site “guidance”, but
quality has not been systematically pursued by the MHLW.
Post-acute care and sub-acute care
Post-acute rehabilitation units were introduced in the 2000 Fee

Schedule revision. The policy objective lay in shortening the
length of stay in acute units by transferring the patients
needing rehabilitation therapy to post-acute rehabilitation
units, and in decreasing the need for chronic care beds by
improving their functional status. Except for rehabilitation
therapy, payment is bundled. The conditions of billing include
the number of therapists per bed, the percentage of patients in
the unit who have had a stroke or injury within the prescribed
number of days, and for the patient to be admitted within 150
days of stroke or 60 days of accident. P4P was introduced in
2012. In the 2016 Fee Schedule revision, the performance
indicator was revised. The unit’s daily average improvement
rate as measured by the patients’ FIM (Functional
Independence Measure) score became the indicator.
Sub-acute units were introduced in the 2004 Fee Schedule

revision. The policy goal lay in creating a unit to which patients
in the acute unit could be transferred and to which patients in
the community not requiring the level of care delivered in the
acute unit could be admitted. However, the latter function has
not developed, because the bundled payment would put the
hospital at risk of admitting patients who need more resources
than would be paid by the Fee Schedule. Sub-acute units were
renamed “comprehensive community care beds” in 2016, but
with basically the same functions. In the 2018 Fee Schedule
revision, to incentivize hospitals to admit patients directly from
the community, higher fees were introduced if 10% or more of
patients in these units had been admitted from the community
and had not been transferred from acute units.15
Long-term care insurance services
LTC insurance (LTCI) was implemented in 2000 to meet the

needs of the ageing society (Ikegami, 2007). It is compulsory
that all people 40 years and over are enrolled. LTCI unified LTC
services that had been provided by SHI, such as HFE, some
hospital chronic care units, and visiting nurse services, such as
those provided by social services, such as nursing homes, day
care and home-helpers. Benefits are restricted to services (no
cash benefits). The maximum cash equivalent amount of
services that beneficiaries are entitled to is determined by the
seven eligibility levels. The levels are based on functional
capacity and range from about US$ 500 to US$ 3500 per
month. Beneficiaries must pay a coinsurance, ranging from
10% to 30% based on the household income level.
15 Only hospitals that have less than 200 beds may bill these higher fees. Small hospitals
had insisted sub-acute and post-acute care should be reserved for them and not for units
in big hospitals.

The LTCI Fee Schedule has basically the same structure as that
of the health insurance. The fees and conditions of billing have
been revised to pursue policy goals and to respond to demands
from providers. For example, a bonus payment for the home
care agency to employ more experienced care workers was
introduced in 2009. The policy objective lay in retaining these
workers into the LTC workforce and improving the quality of
care. To incentivize nursing homes and HFE to deliver end-of-
life care within the facility and not transfer residents to
hospitals, bonus payments were introduced in 2006. These
bonuses and the conditions of billing have made the LTCI Fee
Schedule as complex as that of health insurance. When first
published in 2000, the schedule had only 100 pages, but the
2018 edition has 1000 pages.
However, the LTCI Fee Schedule differs from the health

insurance Fee Schedule in three aspects. First, the rules
restricting extra billing and balance billing are more relaxed
because equity is less of an issue in LTC. Second, it is revised
every three years, not two. Third, the conversion rates differ
according to the eight levels in which each municipality is
grouped: the rate for metropolitan Tokyo is highest at 11.4%
above the base rate. Unlike healthcare, the higher wages of
nurses and aides in urban settings cannot be compensated by
the lower wages of physicians.
As LTCI services have developed, the boundary between

institutional care and community care has become blurred. For
example, special housing for elders that has a day care facility
and a community care agency in the same building are de facto
institutions. However, the following differences remain. First, in
“housing”, rent and food must be paid by the resident, but in an
“institution”, it would be mostly covered by LTCI if the resident
is of low income and/or has few assets. Second, in an
“institution”, the facility is responsible for providing care 24/7,
but, in “housing”, the resident or the family is responsible. Thus,
for those with behavioural problems requiring supervision, an
“institution” may be the only option. For these reasons, there
are long waiting lists to be admitted to nursing homes that do
not balance-bill.

6
Possible lessons for other countries
As noted in the introduction, Japan’s health care system
appears to be functioning relatively efficiently, given the fact
that the older persons as a share of the total population is the
highest in the world, and the LTC system is well developed.
These results may seem to be even more remarkable because
they have been achieved within a basically fee-for-service form
of payment. The key lies in the government controlling payment
to all providers through the Fee Schedule. The following
aspects should be noted.
First, all services and pharmaceuticals that have been evaluated

as being effective are covered and listed in the Fee Schedule.
Direct payment by patients in the form of extra billing and
balance billing is strictly regulated. Without these regulations,
patients, as consumers, would assume that they will get better
services if they paid more. However, patients are not in a
position to bargain with physicians on the price and quality of
services.16 Therefore, it could be said that policy-makers have
been successful in managing the expectations of both the
physician and the patient so that both parties are basically
satisfied with the level of services that is covered by the
publicly financed system.17
Second, fees have not been focused on the “costs” incurred by

providers, but on the providers’ revenue and expenditures. If
providers respond to the incentives set by the Fee Schedule
and manage themselves efficiently, physicians should be able
earn comfortable incomes and hospitals could derive enough
profits that would make it possible to invest in future needs.
Revisions of the fees and the conditions of billing have been
negotiated with the associations of physicians and hospitals
based on this implicit understanding. The negotiations are
structured, routinized, and in depth. Any unresolved issues
could be postponed to the next revision after seeing how
providers react.
While there is no perfect payment method, fee-for-service

should not be dismissed as being intrinsically inflationary and
reflecting only the providers’ interests. Although fee-for-service
would be difficult to introduce in countries that are dominated
by big public hospitals, it should be noted that a DRG type of
inclusive payment would also be difficult. Coding patients into
clinically and economically homogenous groups requires the
standardization of diagnosis, procedures, and recordings. There
must be an appropriate monitoring system to minimize up-
coding. There are also caveats in introducing capitation,
16 The situation would be the same for the payment made in free-standing pharmacies. In
low- and middle-income countries where hospitals are financed by line-item budgets,
physicians may instruct their patients to purchase pharmaceuticals from outside
pharmacies because the hospital’s supply is insufficient. This could develop into
kickbacks from the pharmacies to the physicians. The same practice could expand to
laboratory tests performed in free-standing facilities.
17 One area where balance billing could be allowed in the future is for services provided by
renowned physicians, because their main value lies in their scarcity as positional goods.
Differences in outcome would be very difficult to validate.

because without measuring and rewarding performance, it
would be another form of paying fixed wages.
Thus, payment reform should start by developing a

classification system of the services that are currently being
delivered. Professional associations must be organized and
co-opted into this process. This classification system would be
the basis for establishing a payment system regardless of the
method chosen, for negotiating with providers, and for
conducting surveys. It would also facilitate the integration of
the payment systems that are being currently used in the
public and private sectors in the future.

Aoyagi S. History of the Fee Schedule. Shibunkaku Shuppan.
Tokyo; 1996.
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keizai-shimon/kaigi/special/reform/wg1/291128/sankou1-8.
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theapothecary/2013/05/28/are-u-s-doctors-paid-too-
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Babazono A, et al. 2011. Universal Health Coverage at 50 years:
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Ikegami N, 2014. Universal health coverage for inclusive and
sustainable development: lessons from Japan (English). World
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html, Accessed 12 March 2019).
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Illustrated. Gyosei. Tokyo; 2017.
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the Fee Schedule. Gendai Shakaihoken- January Issue. 1983;8-9.
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regional differences in health care costs in 2017; 2017a.
(https://www.mhlw.go.jp/file/06-Seisakujouhou-12400000-
Hokenkyoku/h27iryohi.pdf, Accessed 12 March 2019).
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hospitals and beds. Central Social Health Insurance Council;
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Development; 2019.

Case study
Malaysia
Chiu-Wan Ng
Centre for Epidemiology and Evidence Based
Practice
Department of Social and Preventive Medicine
Faculty of Medicine
University of Malaya
Malaysia
165
Malaysia
Abbreviations 167
Abstract 168
1 Introduction 169
2 Malaysian healthcare system 170
Malaysian health care delivery system 170

Value system underlying delivery of
health care in Malaysia 172
Achievement of Universal Health Coverage 174
Contents 3 Setting medical fees in the private sector 176
Estimating the cost of providing services

in MoH facilities 176
Legislating medical fees for MoH facilities 177
Mechanism to set fees for MoH facilities 179
Collection of user fees in MoH facilities 181
Setting medical fees for public
teaching hospitals 182
Use of medical fees for the remuneration of
public sector doctors 182
4 Setting medical fees in the private sector 184
Regulating private healthcare facilities 184

Mechanism to set private medical fees 185
Bundled payments in private facilities 187
Relationship between official fees and
actual prices paid for private care 187
Mechanisms to monitor provider behaviour
in the private sector 188
Use of medical fees in the remuneration of
private sector doctors 188
5 Conclusions 192
References 193

Abbreviation Term
B40 Bottom 40
BUPA British United Provident Association
DRGs Diagnosis-related Groups
FPP Full Paying Patient
GDP Gross Domestic Product
GLC Government-linked Companies
GoM Government of Malaysia
GPs General Practitioners
HIC Health Insurance Committee
Abbreviations MARA Majlis Amanah Rakyat, or Peoples’ Trust Council
MAS Micro Accounting System
MCO Manage Care Organisation
MHI Medical and Health Insurance
MMA Malaysian Medical Association
MNHA Malaysia National Health Accounts
MoH Ministry of Health
MPC Malaysia Productivity Corporation
NHSF National Health Security Fund
OOPP Out-of-pocket payment
PHFSA Private Healthcare Facilities and Services Act
RM Ringgit Malaysia
RVS Relative Value Scales
T&CM Traditional and Complementary Medicine
THE Total Health Expenditures
UHC Universal Health Coverage
UM University of Malaya
UMMC University of Malaya Medical Centre
UMSC University of Malaya Specialist Centre
WHO World Health Organization

Malaysia is an upper-middle income country of 32 million
inhabitants. The Malaysian health system is composed of
parallel public and private sectors where the public can choose
to purchase care from either sector. The Government of
Malaysia (GoM) has thus far not used pricing as a tool to
negotiate with public providers for improvement in the quality
or efficiency of care. However, the GoM regulates user fees for
public care, and fees have been set to balance the policy goal
of affordability against that of cost recovery. The GoM also sets
and regulates pricing in the private sector in response to public
demands for affordable private care. High private sector prices
are translated to high user fees in the Malaysian private system,
which predominantly depends on patients paying out-of-
pocket to receive care.
Health care in the public sector is subsidized by the GoM using

funds from general taxation. The application of user fees in the
public sector has enabled cost sharing to be progressively
Abstract increased over time, although to date, such fees are still much
lower than needed for cost recovery. This is in line with GoM’s
stated welfare objectives of affordable public health care and
that the public health sector needs to be maintained as the
safety net for the poor. The basis for the regulation of user fees
in the private sector, which is predominantly funded through
out-of-pocket payments, was to ensure affordability of care.
However, legislated private medical fees cover only the
professional fees charged by health care professionals. Thus,
only a portion of total bills incurred by patients using private
health care facilities is regulated. It has become apparent that
regulation of private medical fees, as is practiced in Malaysia,
has not been able to contain rising costs of private health care.
Furthermore, high private medical bills are a barrier to private
health care for many.
The practice of medical fee setting is still in its infancy in

Malaysia since a) there is little incentive within its stated
welfare goals for the public sector to set fees, and b) since the
vibrant private health sector today is a relatively recent
development. However, there is increasing public demand for
access to private care through reasonable private fees, and the
government has just recently announced an initiative to
purchase private service to expand health screening services to
the poor. In view of these developments, it is envisaged that
the Ministry of Health would need to invest in building
infrastructure for fee setting. This would include training
dedicated personnel to capture and analyse costs as well as a
system for better collaboration among policy stakeholders both
within and without the ministry.

1
Introduction
Malaysia is an upper-middle income country of 32 million
inhabitants. The Malaysian health system is composed of
parallel public and private sectors, where the public can choose
to purchase care from either sector. The Government of
Malaysia (GoM) has thus far not used pricing as a tool to
negotiate with public providers for improvement in quality or
efficiency of care. However, the GoM regulates user fees for
public care, and fees have been set to balance the policy goal
of affordability against that of cost recovery. The GoM also sets
and regulates pricing in the private sector in response to public
demands for affordable private care. High private sector prices
are translated to high user fees in the Malaysian private system,
which predominantly depends on patients paying out-of-
pocket to receive care.
By and large, fees are set by the Ministry of Health (MoH), and
the fees are enforced through legislations. Health care in the
public sector is subsidized by the GoM using general taxation
(Ministry of Health, 2017b). Such public funding is substantial
and over the past two decades has paid for more than half of
the annual total health expenditures (THE) of the country. The
application of user fees in the public sector has enabled cost
sharing to be progressively increased over time, although to
date, such fees are still much lower than needed for cost
recovery.1 This is in line with GoM’s stated welfare objectives of
affordable public care and the need to maintain the public
sector as the safety net for the poor (Rohaizat, 2004). The basis
for the regulation of user fees in the private sector, which is
predominantly funded through out-of-pocket payments
(OOPPs), was to ensure the affordability of care. However,
legislated private medical fees cover only the professional
fees2 charged by health care professionals. Thus, only a portion
of total bills incurred by patients using private health care
facilities is regulated. It has become apparent that the
regulation of private medical fees as practiced in Malaysia has
not been able to contain rising costs of private health care and
that high private medical bills are a barrier to private health
care for many (The Edge Financial Daily, 2017).
This case study describes the rationales, processes, and effects

of setting and regulating user fees in the Malaysian healthcare
system. The work to develop this report took place between
August and October 2018 and involved the identification and
consolidation of information using the question guide provided
by the World Health Organization (WHO) Kobe Centre,
1 For example, the fee for a general outpatient clinic visit obtained from a public clinic was
just RM (Ringgit Malaysia) 1, or approximately US$ 0.23, in 2017. Payment of this fee
would entitle the patient to a medical consultation, simple laboratory investigations and
medication for two weeks.
2 Fees paid to health care professionals, predominantly doctors and dentists for the
conduct of medical consultations or procedures, including the interpretation of radiology
and laboratory tests. Professional fees exclude that portion of hospital bills for hotel
services such as for food and accommodation and fees for the use of equipment and
facilities such as operating rooms and drugs.

supplemented by a wider literature review relating to medical
fees in Malaysia, and interviews with key informants with
knowledge of past and current medical fees setting practices in
the country.
This report begins with a description of the Malaysian

healthcare system to understand the context in which medical
fees are applied, followed by descriptions of the processes of
fee setting in the public and private health sector, respectively.
The report concludes with a discussion on the overall effect of
medical fees on the healthcare system in Malaysia.
2
Malaysian healthcare system
Malaysian health care delivery system
Malaysia, a sovereign nation formed in 1963, is a federation

made up of 13 states; 11 in the Malay Peninsula, and two,
Sabah and Sarawak, in the northern part of the island of
Borneo.3 These two land masses are separated by the South
China Sea. Malaysia practices a constitutional monarchy system
in which the nine4 hereditary state rulers elect among
themselves a Yang di-Pertuan Agung, or King, who will rule the
country for a five-year term. In 2017, the country was home to
an estimated 31.6 million people, of which 3.3 million, or
10.2% were non-citizens (Department of Statistics Malaysia,
2017). Of the remaining 28.3 million people, 68.6% were
Bumiputeras,5 23.4% Chinese, 7.0% Indians and 1.0% people
from other ethnic groups.
Health is a federal government responsibility, and the main

federal agency regulating the health sector is the MoH.
However, health care in Malaysia is delivered through a parallel
public-private delivery system. The MoH is the largest provider
of public care, and in 2016 it owned 144 hospitals and special
medical institutions, with nearly 42 000 beds, as well as over
3000 static or mobile clinics distributed throughout the land
(Ministry of Health Malaysia, 2017a). There were an additional
four teaching hospitals owned by the Ministry of Education,
each of which is affiliated with the public medical schools of
the University of Malaya (UM), National University of Malaysia,
Science University of Malaysia and MARA6 University of
Technology, as well as five military hospitals owned by the
Ministry of Defence to provide care to military personnel and
their dependents. These nine non-MoH public hospitals
3 All 13 states were former British colonies. In 1957, the 11 states in the Malay Peninsula
achieved independence from British rule and formed the Federation of Malaya. Malaysia
was formed in 1963 when Sabah, Sarawak and Singapore joined the federation. In 1965,
Singapore left the federation.
4 The other four states are ruled by Governors who are appointed by the Yang di-Pertuan
Agung.
5 Bumiputera, a Malay term meaning ‘prince of the earth’, refers to the combined grouping
of the orang asli and people from the Malay ethnic group. The term orang asli refers to
diverse groupings of indigenous tribes residing in the Malay Peninsula as well as in the
states of Sabah and Sarawak.
6 Majlis Amanah Rakyat (MARA), or People’s Trust Council, is a government agency set up to
aid, train and guide bumiputeras in the areas of business and industry.

contribute another 3700 hospital beds. Several local
authorities and town councils, which are under the purview of
the Ministry of Local Government and Housing, also provide
some health care services, mainly in areas of sanitation, food
quality control and vector control services in larger towns.
Although public sector health facilities are mainly restricted to

hospitals and clinics, the range of private sector facilities is
more diverse. In 2016, there were 187 private hospitals with a
combined bed complement of nearly 14 000 beds, over 7000
private medical clinics and nearly 2000 private dental clinics as
well as 423 private haemodialysis centres, 73 private
ambulatory care centres, 17 private nursing homes, 10 private
maternity homes, four private blood banks, two private
hospices, one private community mental health centre and two
private facilities combining haemodialysis as well as
ambulatory care services (Ministry of Health Malaysia, 2017a).
In Malaysia, the classification of health care facilities to public

or private sectors is based not on ownership but rather on the
business model adopted by the management of the health
facilities. Private health care facilities are those which operate
on a commercial for-profit basis (Chan, 2014). This is especially
relevant in the private hospital sector where many private
hospitals are fully or partially owned by government-linked
companies7 (GLCs) but operate as commercial for-profit
enterprises (Chan, 2014). Currently, the proportion of private
hospital beds owned by GLCs exceeds 50% of total private
hospital beds in the country8 (figure 1).
Figure 1
Distribution of hospitals and doctors working in the public and
private sectors in Malaysia, 2016
Public Sector Private Sector
MoH Non-MoH GLC-linked1 Others

No. of hospitals 144 9 45 142
No. of hospital 41995 3683 74012 6,556

beds
No. of doctors 36403 na 136843
Source: Ministry of Health Malaysia, 2017a, and information obtained

from the websites of GLC hospitals. Notes: GLCs are defined as companies
that have a primary commercial objective and in which the GoM has a
direct controlling stake and not just percentage ownership; 1: hospitals
owned by Khazanah National Berhad, Ramsay Sime Darby, the Terengganu
and Malacca state governments; 2: Estimated from information obtained
from the websites of GLC hospitals; 3: Published information refers to all
doctors practicing in the private sector; na: Not available.
7 GLCs are defined as companies that have a primary commercial objective and in which the
GoM has a direct controlling stake and not just percentage ownership.
8 These GLCs include IHH Healthcare Berhad, a subsidiary of the Khazanah Nasional Berhad,
the federal government sovereign wealth fund and KPJ Healthcare Berhad, a public-listed
company belonging to the Johor Corporation, the investment arm of the Johor state
government. Other state governments, including the Terengganu and Malacca state
governments, are also involved in providing private health care. Sime Darby, another GLC,
owns hospitals through Ramsay Sime Darby, a joint venture with Ramsay Health Limited,
an Australian company.

Value system underlying delivery of health care in Malaysia
The GoM launched the Privatisation Policy in 1983 (Chee and

Barraclough, 2007). The policy was intended to encourage the
private sector to be the main engine of economic growth and to
allow the government to reduce its presence in the economy,
thus reducing its level and scope of public spending (Abu Bakar,
n.d.). Incentives were provided to enhance development of the
private health sector, which coupled with increasing public
demand for private care, led to a rapid expansion of private
hospitals - from 50 hospitals in 1980 to 219 hospitals in 2003
(Chee and Barraclough, 2007). Operating private hospitals
came to be seen as a lucrative business venture, which in turn
encouraged further participation of private companies and
eventually GLCs (Rasiah et al., 2009; 2011). Despite these
developments in the private sector, welfare sentiments are still
prevalent in the provision of public care.
The then (and current) Prime Minister of Malaysia, Mahathir

Mohamad,9 delivered a speech at the inaugural meeting of the
Malaysia Business Council on 28 February 1991, in which he
outlined nine strategic challenges for the country to achieve
developed nation status by 2020. His aspirations for the
country, as contained in this landmark speech, are now widely
known as Vision 2020.10 In it, the Prime Minister stressed that
the developed Malaysian society should be an “economically
just society” and to obtain this, the country should, amongst
others, “provide enough by way of essential shelter, access to
health facilities and all the basic essentials”(Abu Bakar and
Jegathesan, 2001: p. 12). However, this needs to be understood
against the backdrop of what he had mentioned earlier in the
same speech concerning the strategic challenges in the path
towards national development. In the seventh of these
challenges, Mahathir emphasized the need to establish a fully
caring society, in which “the welfare of the people will revolve
not around the state or the individual but around a strong and
resilient family system” (Abu Bakar and Jegathesan, 2001: p.
12). Taken together, these statements provide a rationale for
the policy directions with regards to the application of medical
fees in Malaysia, especially in the public sector, which
emphasizes the need to provide basic health care for all based
on a shared responsibility between the state and the people.
This sentiment is also reflected in the MoH’s Vision for Health.
Vision 2020 was intended to provide a direction for national

economic growth. After its release, the MoH developed the
Vision for Health to guide development of the health sector
towards the attainment of Vision 2020. The guiding principle of
shared responsibility towards health has been echoed in the
Vision for Health, which states that “Malaysia is to be a nation
of healthy individuals, families and communities, through a
health system that is equitable, affordable, efficient,
9 Mahathir Mohammad first served as the fourth Prime Minister of Malaysia from 1981 to
2003. In May 2018, he was again appointed to the same position as the seventh Prime
Minister of the country.
10 The full speech can be downloaded from http://unpan1.un.org/intradoc/groups/public/
documents/apcity/unpan003223.pdf.

technologically appropriate, environmentally adaptable and
consumer friendly, with emphasis on quality, innovation, health
promotion and respect for human dignity and which promotes
individual responsibility and community participation towards
an enhanced quality of life” (Abu Bakar and Jegathesan, 2001:
p. 12). The mention of an ‘affordable’ health system here could
have easily been thought to refer to medical fees set at a level
which patients can pay and thus afford. However, it has since
been clarified that the ‘affordable’ health system in the Vision
for Health is seen from the more macro perspective of what the
country can afford to provide to the people (Abu Bakar and
Jegathesan, 2001: p. 12).
The MoH had set up the Malaysia National Health Accounts

(MNHA) Project in 2001 to capture details of the national health
care expenditures in Malaysia. To date, MNHA has published
expenditure estimates and trends for years 1997 to 2015
(Ministry of Health Malaysia, 2017b). Throughout this period,
the country’s THE as a percentage of Gross Domestic Product
(GDP) did not exceed five percent, and public sources of
funding, which are predominantly made up of general taxation,
contributed more than half of THE annually (figure 2). Though
accurate estimates of private financing of health care in
Malaysia were not routinely available prior to 1997 and thus
THE were not known, the MoH was aware of the increasing cost
of providing public care and the need to mobilize other sources
of funding for health.
Figure 2
Public and private health financing sources, Malaysia 1997 to
2015
30 5
24 4
Real health expenditures (billion 2010 RM)
Total health expenditures as % of GDP
18 3
12 2
6 1
0 0
1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015
Public sources THE as % of GDP

Private sources
Source: Ministry of Health Malaysia, 2017b.

General socio-economic policies in Malaysia are laid down in a
series of five-year development plans known as Malaysia Plans.
The first Malaysia Plan covered the years 1966 to 1970. This
and the next three Malaysia Plans, covering the years 1971 to
1985, focused mainly on the expansion of health services,
especially to enable better access to care for rural populations
(Government of Malaysia, 1966; 1970; 1976; 1981). However,
from the fifth Malaysia Plan (1986 to 1990) onwards, the
Malaysian public were slowly being sensitized to the growing
financial burden shouldered by the GoM to provide public
health care and subsequently the need for cost sharing. In
particular, there was a specific mention of improvements in
hospital billing systems and efforts to revise user fees in order
to “initiate nominal cost recovery in hospitals and clinics”
(Government of Malaysia, 1990: p. 353). It was also noted that
large numbers of migrants had used public health facilities
and were paying the same fees paid by citizens. In 1994,
medical fees for migrants were increased to encourage them
to use private medical facilities (Government of Malaysia, 1996:
p. 540).
The rapid expansion of private health care since the 1980s has
generally been welcomed. The GoM intends for the private
sector provision to complement the public sector provision of
medical services especially for those who can afford private
care. However, the GoM saw fit to add that legislations should
be reviewed to ensure that the profit motive would not
compromise quality and accessibility to private care.
Subsequently, a new legislation governing the provision of
private medical care, the Private Healthcare Facilities and
Services Act (PHFSA), was enacted in 1998 to “improve access
to health care, correct imbalances in standards and quality of
care as well as to rationalize medical charges in the private
health sector to more affordable levels” (Government of
Malaysia, 1996: p. 549). The GoM also made known its intention
to reform the country’s health care financing system to provide
“consumers with a wider choice in the purchase of health
services from both the public and private sectors” (Government
of Malaysia, 2001: p. 495). However, to date, there has been no
major reforms to the country’s financing system which has
provided public funding to support the public provision of care
and in turn, contributed to the achievement of universal health
coverage (UHC).
Achievement of Universal Health Coverage
Malaysia has claimed to have achieved UHC since the 1980s,

when health services had been provided to over 90% of the
population.11 UHC has mainly been provided by the public
health sector. At that point in time, the focus was on the
expansion of primary care services for rural people who made
up the majority of the population in the country (Jayesuria,
1967). Health clinics remain an important component of the
11 The then Minister of Health, S. Subramaniam, had made this claim in a speech delivered at
the 27th Commonwealth Health Ministers Meeting held in Geneva, Switzerland on 17th
May 2015. The speech can be obtained from www.moh.gov.my/index.php/database_
stores/attach_download/337/679.

MoH primary care delivery system to this day. Clinics vary in
size and complexity, with the smaller ones staffed by a single
community nurse providing basic nursing care and advice.
These community clinics are connected to a network of
progressively larger and more complex clinics. At the top of the
chain are polyclinics, where the public can access the full range
of primary care services from general outpatient consultations
to ante and postnatal care, vaccinations against infectious
diseases, growth monitoring for children, health screening and
health education services as well as dental care. The larger
clinics are also equipped with pharmacies, laboratories and
x-ray machines.
The MoH also established hospitals to provide secondary and

tertiary care. Similar to clinics, the network of MoH hospitals
range from small secondary care hospitals in rural districts to
tertiary referral hospitals in large towns such as Putrajaya, the
administrative capital of the country. A national referral system
has been established to link facilities providing different levels
of care and to enable patients to be referred from the clinics to
the level of care that they require. The public teaching hospitals
are also part of this referral system.12 Thus, the public health
system in Malaysia has been structured to provide
comprehensive health care, from primary to tertiary levels, to
individuals in need.
User fees have long been a feature in the Malaysian healthcare

system. However, such fees in the public sector have often
been waived for the poor (Rohaizat, 2004). A national
household health survey conducted by the MoH in 1988 found
that, “almost all outpatient visits to government clinics were
free, as were 60% of visits to government hospitals.” (Public
Health Institute, 1988: p. 9). An earlier study noted similar
findings, “small personal charges are made to patients, but they
are seldom collected for class III services, which apply to the
majority of the beds” (Westinghouse Health Systems, 1985: p.
107). The same study reported that public hospitals were
provided with government allocations on a quarterly basis and
that a supplemental allocation was provided in the event of a
shortfall of funds. Since these early studies, there has been
several upward revision of fees, but as late as 2015, more than
half of the public hospital admissions and public outpatient
consultations had been free (Institute for Public Health, 2015:
pp. 347-383).
In 2011, it was estimated that on average, each person in

Malaysia had 4.3 outpatient consultations and that there were
111 inpatient discharges per 1000 population in the country
(Health Policy Research Associates et al., 2013: p. 20). The
outpatient consultations were equally distributed between
public and private health care providers. However, inpatient
admissions were predominantly public. Admissions to public
hospitals made up 74% of all admissions. But what is more
interesting to note is that there was no income gradient in the
12 However, the five military hospitals do not normally accept non-military personnel except
in emergencies. These hospitals mainly provide care for military personnel and their
families. Such services are free at the point of delivery.

utilisation of outpatient and inpatient care services in Malaysia.
Whilst outpatient and inpatient utilisation were the same
across income quintiles, there was a distinct pro-rich
distribution to the use of private health care services and,
conversely, a pro-poor distribution for public care (Health
Policy Research Associates et al., 2013: pp. 55-56). It was
argued that this equitable finding can be attributed to
sustained government investments into the public health
sector, not just in terms of development and expansion of
health facilities but also in efforts to keep user fees low to
maintain affordability for the poor.
3
Setting medical fees in the private sector
Estimating the cost of providing services in MoH facilities
Although the MoH has knowledge of the expenditures spent by

its various programmes as well as the number of care episodes
provided by its facilities, this information has not been fully
mined to yield comprehensive information on the costs of
services.
In 1992, the GoM had introduced the Micro Accounting System

(MAS) into the public sector to determine the costs of outputs
produced by public agencies. Such information was to be used
to assist management in the planning, implementation, control
and evaluation processes. The MAS was implemented by the
MoH in phases from 1995 to cover hospitals, clinics and health
management departments within the ministry.13 This system
was designed to produce inpatient and outpatient unit costs of
inpatient and outpatient services provided by MoH facilities.
However, the MAS system is currently no longer in use by the
ministry.
In 1996, the MoH started exploring the use of case-mix systems

for hospital budgeting purposes.14 Initial efforts were hampered
by the high cost of purchasing and maintaining the case-mix
software sourced commercially. In 2010, the ministry
commissioned the design of a system known as the Malaysia
diagnosis-related groups (DRGs) utilising case-mix weights
developed for hospital inpatient care. This system is currently
in use in 59 out of the 144 MoH hospitals nationwide. Thus far,
only costs by DRGs for inpatient care are known. The ministry is
working towards extending the system to include outpatient
and day care services as well as to improve the accuracy of
clinical coding in MoH hospitals. These efforts would be
required if case-mix information is to be used to support the
development of hospital budgets.
13 Information on MAS within the MoH was obtained from a paper entitled, “Micro
Accounting System for Costing of Services” presented by Mr Tan Eng Hock, Secretary of
the Finance Division, MoH at the Conference of Directors, MoH held from 15th to 17th April
1998.
14 Information on the use of case-mix systems was obtained from the MoH.

Prior to 1997, total health expenditures in Malaysia covering
both public and private sources of funding were not routinely
and systematically captured. The MNHA Project established in
2001 was to capture the totality of health expenditure flows
within the health system in Malaysia. As part of the data
capture process, the MNHA conducted cost accounting projects
in selected MoH hospitals to enable disaggregation of hospital
expenditures to inpatient, outpatient and day care costs
(Ministry of Health Malaysia, 2006: p. 5). Conceptually these
exercises have the potential to produce estimates of unit costs
for services in the selected hospitals, but to date such
information, if estimated, has not been made public.
A legacy from the British Colonial administration, the MoH has a

strong and long-standing culture of systematically collecting
health statistics from MoH facilities (Health Informatics Centre,
2013: pp. 8-9). Since the 1960s, there has been a dedicated
unit responsible for the collection and analysis of health
information. This unit has evolved over time, and its role has
expanded to include the development of standards, ensuring
quality of the data collected, analysed and disseminated to
support policy decision-making in the ministry. The current
form of the unit is known as the Health Informatics Centre (HIC),
which was established in 2007 to manage health statistics from
the public as well as the private sector. One of the stated
objectives of the HIC is to provide data support for the conduct
of cost-effectiveness analyses (Health Informatics Centre, 2013:
p. 13). However, the centre does not appear to collect data on
costs of care.
In summary, though the MoH keeps track of the overall

expenditures of the ministry, comprehensive cost information
by services is currently not fully available.
Legislating medical fees for MoH facilities
In the public sector, matters pertaining to fees for services

provided or financial penalties imposed by all public offices
and departments of the GoM are governed by the Fees Act
1951 (Government of Malaysia, 1951). In accordance with
Article 97(1) of the Federal Constitution, all funds collected are
paid into the Federal Consolidated Fund. These funds cannot
be retained by the public agencies that collected them.15
Medical fees collected from MoH patients make up a very small
portion of overall government revenues. In 2014, collected
medical fees totalled RM 269.3 million, or US$ 82.4 million,
which was less than 0.5% of all non-tax government revenues
and less than 0.1% of total government revenues for the year
(Ministry of Health Malaysia, 2015a: p. 36; Ministry of Finance
Malaysia, 2015: p. 4-6).
The fees for MoH medical services are gazetted as regulations

under the Fees Act 1951 and are enforced by the MoH. The
earliest regulation was gazetted in 1957 and later revised in
15 An exception was made for fees collected from the FPP scheme. The Ministry of Finance
has clarified that the portion of fees meant to be paid to attending doctors could be
maintained in a trust fund and eventually be disbursed to the doctors concerned.

1976 and 1982 (Government of Malaysia, 1982). The fees
included in the 1982 regulation were listed in eight schedules
covering inpatient and outpatient care services. Fees for all
inpatient services, such as for treatment, investigations and
operations, differed by class of accommodation. Higher fees
were charged for patients admitted to first and second class
wards compared to third class wards. The regulations also
included fee exemptions for certain groups of people including
members of the royal families, government pensioners and civil
servants. Hospital directors were also permitted to waive fees
for the destitute. In addition, fee exemptions were included for
specified health care services such as ante and postnatal care
for mothers, outpatient treatment for infants and inpatient care
for persons suffering from one of the 24 listed infectious
diseases (including malaria and cholera).
Since 1982, the regulations have been revisited several times.
1. The current version applicable for citizens using MoH

facilities was gazetted in 2017 (Government of Malaysia,
2017) to include a revision of the 1982 fees and the
inclusion of additional surgical procedures and services
such as physiotherapy, occupational therapy, dietetics and
traditional and complementary medicine (T&CM) services16
not provided for in the 1982 regulations.
2. In 2003, a new regulation was gazetted to include medical

fees for non-citizens17 utilising MoH services (Government
of Malaysia, 2003), and these fees were revised in 2014
(Government of Malaysia, 2014).
3. Fees for patients using the Full Paying Patients (FPP) services
18
were gazetted in 2007 (Government of Malaysia, 2007).
A comparison of current medical fees charged for selected

services or procedures for patients obtaining care in MoH
facilities is provided in figure 3.
16 T&CM based on Malay, Chinese, Indian, Orang Asli and complementary medical practices
co-exist with Western allopathic medical practices in Malaysia. T&CM care is mainly
available in the private sector and is mostly paid for using OOPPs. The MoH has provided
a limited range of T&CM services, such as Chinese acupuncture, Malay massage, Indian
ayurvedic therapy, chiropractic and Chinese herbal oncology services in selected
hospitals since 2007. It was only in 2017 that the fees for these services had been
gazetted. Prior to that, the services had been provided for free.
17 All citizens above the age of 12 years are issued a Malaysian Identity Card, known as
MyKad. These cards are used as proof of citizenship during patient registration processes.
Birth certificates are used for the same purpose in the case of children.
18 Patients who choose to use the FPP services in MoH hospitals are provided with
additional services such as being allowed to choose their doctors and staying in better
appointed rooms.

Figure 3
Comparison of selected medical fees for Malaysians, Non-
citizens and FPP obtaining care in MoH facilities
Malaysian Non-Citizens Fully paying

patients (FPPs)
Outpatient Care
Clinica RM 1 RM 40 nab
Specialist Referred by public RM 120 per RM 110 for 1st

Outpatient Clinicc sector doctors – visit visit and RM 60 for
free for 1st visit subsequent visits
and RM 5 for
subsequent visits
Referred by
private sector
doctors – RM 30
for 1st visit and
RM 5 for
subsequent visits
Daily Ward Chargesd

First Class
- Single bed RM 90 RM 320 RM 160
- Two beds RM 60 RM 240 RM 130
- Three or more RM 45 RM 200 RM 80

beds
Second Class RM 25 RM 180 nae
Third Class RM 3 RM 160 nae
Source: Government of Malaysia, 2003; 2007; 2014.

Note: FFP: fully paying patients; a standalone MoH clinics; b not applicable,
since FPP scheme available only in selected MoH hospitals; c specialist
outpatient clinics in MoH hospitals; d fees for food and accommodation;
e
not applicable since second and third class wards are not available under
the FPP scheme. RM: Malaysian ringgit 4.30 = US$ 1 in 2017.
Mechanism to set fees for MoH facilities
It was not possible to obtain information on how fees included

in the three earliest regulations were set. What is known is that
later fee revisions were based on the fees and fee structure of
the 1982 regulations. The frequency of fee revisions is not
stipulated in the law, and the timing of revisions appeared to
be a top-down management decision that could have come
from outside the ministry, perhaps in support of wider public
policy directions of the government. Indeed, this may have
been the case for setting separate fees for non-citizens, which
is in line with government policies of restricting access to social
services, such as subsidized education, for non-citizens.
The mechanism of fee revisions is illustrated using the work

flow of the latest fee revision exercise in 2017. The MoH was
instructed to revise the 1982 fees to incorporate greater

cost-sharing between the government and patients. However,
there was no target set for the levels of cost-sharing. One of the
first tasks was to update the list of medical investigations,
procedures and services. Over the past few decades since the
1982 fee regulation was gazetted, the MoH had started new
services for which fees were not available. Patients who use
such services were not charged for care obtained. One such
service was for T&CM care, which had been provided in
selected hospitals since 2007. MoH officers conducted a small
survey of private T&CM practitioners to obtain the range of fees
for similar services to those provided in MoH hospitals. The
recommended fees for inclusion into the 2017 fee regulations
were generally less than the private fees for the same service.
For other services, MoH officers consulted with the heads of
various medical and surgical disciplines within the ministry
who are senior specialist doctors appointed to take on advisory
roles in matters pertaining to their specialty. They would in turn
consult specialist colleagues within the ministry as well as
specialists who work in the private sector to obtain information
on fees in the private sector before making a recommendation
to the ministry. In certain cases, fee recommendations may be
based on available cost information. This may be more relevant
for laboratory and radiological investigations.
For the 2017 fee revision, a policy decision was made to focus
on revising the fees set for patients in first and second class
wards. Since the precise cost of providing MoH services is not
known, the general principle guiding the exercise had been that
patients should not have to pay higher fees for care in MoH
hospitals compared to private hospitals for the same medical
condition. MoH officers had surveyed fees charged in private
hospitals for a sample of common medical conditions. In 2017,
the fees for services provided to patients opting for first class
wards were eventually raised by 50% and fees for patients in
second class wards were raised by 25% from the fees set in
1982 (figure 4).

Figure 4
Comparison of selected medical fees for Malaysians,
1998 and 2017
1982 2017
Outpatient Care
Clinica RM 1 RM 1
Specialist Outpatient Referred by public Referred by public

Clinicb sector doctors – free sector doctors – free
for 1st visit and RM 5 for 1st visit and RM 5
for subsequent visits for subsequent visits
Referred by private Referred by private
sector doctors – RM 30 sector doctors – RM 30
for 1st visit and RM 5 for 1st visit and RM 5
for subsequent visits for subsequent visits
Daily Ward Chargesc

First Class
- Single bed RM 60 RM 90
- Two beds RM 40 RM 60
- Three or more beds RM 30 RM 45
Second Class RM 20 RM 25
Third Class RM 3 RM 3
Source: Government of Malaysia, 1982; 2017.

Note: a standalone MoH clinics; b specialist outpatient clinics in MoH
hospitals; c fees for food and accommodation; RM: Malaysian Ringgit 4.30
= US$ 1 in 2017.
Collection of user fees in MoH facilities
MoH patients who are not exempted from payment would be

charged fees according to the relevant regulated fees. However,
patients are not charged for services received if the fees for
such services had not been gazetted. This was the case for
T&CM services introduced in 2007 but for which fees were only
gazetted in 2017.
The ministry has faced challenges in collecting due payments

from patients. In 2014, the total medical fees billed to patients
amounted to RM 296.6 million (US$ 90.7 million) or 1.4% of
the ministry’s operating expenditures (Ministry of Health
Malaysia, 2015a: pp. 32-36). Unpaid medical bills amounted to
RM 27.3 million (US$ 8.3 million) or approximately 9.2% of the
total billed, more than half of which came from unpaid bills of
non-citizens.

Setting medical fees for public teaching hospitals
Unlike the case of MoH facilities, the medical fees charged by

the four public teaching hospitals are not legislated, and the
full details of these fees are not routinely made known to the
public. One such hospital is the University of Malaya Medical
Centre (UMMC), the teaching hospital of the University of
Malaya (UM). UMMC is a statutory body established under the
Ministry of Education, Malaysia.19 As a public teaching hospital,
the UMMC is funded by UM through the Ministry of Education.
The UMMC Hospital Board of Management, made up of
representatives from UM, the Ministries of Health, Education
and Finance, as well as two representatives of the public
nominated by the Chancellor of UM, oversee the policy
directions of the hospital. The Board is also responsible for the
financial management of the hospital including approving fees
charged for hospital services. The UMMC conducts micro-cost
accounting exercises, which are used to inform the revisions of
fees. In general, UMMC fees are higher than that for MoH
hospitals, reflecting the higher pressure for public teaching
hospitals under the Ministry of Education to generate revenue
compared to their MoH counterparts.
Use of medical fees for the remuneration of public sector

doctors
Health care professionals, including specialist and non-

specialist doctors, working in public hospitals and clinics are
salaried workers. Their salary scales are determined by their
qualifications and training as well as seniority in service.
However, there have been efforts by the public universities as
well as the MoH to allow senior specialist doctors restricted
private practice20 to stem movement of these doctors to the
private sector. Public specialist doctors who conduct private
practice in this manner are allowed to retain a portion of the
fees collected from patients. The premise behind the move is
that the additional income from private practice will increase
doctors’ satisfaction and thus enhance the retention of these
specialist doctors in public service.
One of the first universities to allow its specialist doctors

restricted private practice was UM. The University of Malaya
Specialist Centre (UMSC) was established in 1998 as a
subsidiary of UM and currently has specialist clinics and a
65-bedded facility located within the grounds of the
university.21 Specialist doctors working in UMSC are salaried
academic staff of UM and are also affiliated to UMMC. Unlike
UMMC, which is a public hospital, UMSC was conceptualized as
a private hospital. Whilst it is the norm for UMMC patients to be
managed by teams of health care professionals, UMSC patients
can choose their specialist doctors and these doctors are held
19 Information on UMMC can be obtained from https://www.ummc.edu.my/introduction.asp.
20 Restricted in the sense that these specialist doctors are not allowed full-time private
practice since they have to fulfil responsibilities to care for public patients as well. Their
places for private practice are also usually stipulated by their employers. In most
instances, public specialist doctors are only allowed to conduct private practice in the
public hospitals they are attached to.
21 Information on UMSC can be obtained from https://umsc.my/?page_id=2843890.

fully responsible for the private patients that they manage. In
return for their services, these doctors are allowed to retain
most of the professional fees paid by patients. The UMSC
charges these doctors an administrative fee, which is calculated
as a percentage of the professional fees that patients pay. The
rest of the fees paid by patients, such as for accommodation
and use of equipment are retained by the UMSC. The
professional fees charged by UMSC specialist doctors are the
same as that charged by doctors working in other private
hospitals in Malaysia.
UMMC and its private counterpart, the UMSC, exist in close

proximity, which could give rise to some ethical concerns for
specialist doctors working in both institutions concurrently. For
one, there is a concern that the specialist doctors would neglect
their public practice obligations in order to spend more time in
their private practice. For another, there may be a concern that
specialist doctors would coerce public patients from UMMC to
seek care in UMSC. In order to prevent such unethical
behaviours, the management of UMSC has set up an ethics
committee made up of senior specialist doctors to ensure that
doctors adhere to an ethical code of conduct.
The MoH has a similar programme in which senior specialist

doctors are allowed to provide clinical care to private patients
admitted to MoH hospitals under the FPP scheme. FPPs are
permitted to choose their attending doctors, a privilege not
extended to other MoH patients, and they stay in better
appointed rooms. The scheme was started in 2007 involving
specialist doctors from two MoH hospitals, but since then the
ministry has expanded the scheme to 35 main MoH hospitals
throughout the country. FPPs are charged fees which
purportedly22 reflect the cost of care provided to them (Ministry
of Health Malaysia, 2015b: p. 1). The categories and quantum of
fees charged for FPP services were gazetted in 2007
(Government of Malaysia, 2007). A portion of the fees collected
by the hospitals is shared with the attending doctors in which
the doctors’ shares are dependent on the category of fees. For
instance, doctors receive all the consultation fees,23 but only
half of the treatment fees24 paid by FPPs (Ministry of Health
Malaysia, 2015b: p. 24). The MoH has developed a set of
guidelines for specialist doctors to ensure that their service to
other public patients is not adversely affected by their
participation in the FPP scheme. Among others, the ministry has
stated that the additional income from the FPP scheme must
not exceed three times the doctors’ gross monthly salary
(Ministry of Health Malaysia, 2015b: p. 26).
22 Since the actual cost of care in MoH hospitals is not fully known.
23 Consultation fees are fees for consultation by a specialist to any patient that may include
examination or comprehensive treatment planning.
24 Treatment fees are fees for any therapeutic service provided to any patient.

4
Setting medical fees in the private sector
Regulating private healthcare facilities
Prior to 1998, the MoH regulated private health facilities using

provisions laid down in the Private Hospitals Act 1971
(Government of Malaysia, 1971). This law imposes basic
physical standards for the licensing of private hospitals, private
maternity homes and private nursing homes in the country (Nik
Rosnah, 2007). The regulation of medical fees was not then
within the ambit of the law. Partially due to the expansion in
the numbers and nature of health care facilities in the country,
a new legislation to regulate all categories of private health
care facilities, the PHFSA, was enacted in 1998 (Government of
Malaysia, 1998). This new law provides regulations for private
hospitals, maternity homes and nursing homes as well as nine
other distinct categories of health care facilities, namely
psychiatric hospitals, ambulatory care centres, psychiatric
nursing homes, blood banks, haemodialysis centres, hospices,
community mental health centres, and medical and dental
clinics.
The PHFSA was enacted primarily to safeguard the interests and

safety of patients who receive private care. In additions to
sections covering areas such as the physical standards for
facilities, qualifications of personnel managing private facilities,
medical practice governance and oversight structures, the law
also made it mandatory for private facilities to make social and
welfare contributions to society and to empower the MoH to
set fees for private health care. Private facilities regulated
under the PHFSA 1998 are also required to submit patient
statistics to the HIC. However, the centre mainly collects patient
use and not cost data. It is assumed that each private health
facility, being commercial based entities, would have internal
accounting mechanisms to track their own cost of services.
There is no legal requirement to share this information with the
MoH.
Fees for services provided by private clinics and hospitals

under the PHFSA 1998 were gazetted in 2006 (Government of
Malaysia, 2006a; 2006b). In 2013, the MoH revised the fees for
private hospitals (Government of Malaysia, 2013). The long
gestation period of eight years between the enactment of the
PHFSA in 1998 and the gazettement of fees in 2006 hints of
the difficulties encountered by the MoH to set fees for private
care in the country. Though the intention of PHFSA 1998,
Section 106, was to regulate fees to ensure affordability of
private care (Malaysia, 1996: p. 549), the eventual regulated
fees covered only professional medical fees for doctors
practicing in private facilities. The fees gazetted under the law
refer to the maximum allowable professional fees that can be
charged by health care professionals. They are permitted to
charge less than the legislated fees if they wish to do so. All

other fees paid by patients receiving care in these facilities,
including fees for laboratory investigations, nursing care, use of
equipment, operation room and drugs, are not regulated due to
the “varying costs in operating and maintaining a private
hospital in different areas of the country”.25 The professional
fees included in the law were based on the fee schedules
developed by the Malaysian Medical Association (MMA).
Mechanism to set private medical fees
Prior to the enactment of the PHFSA in 1998, private medical

fees were mainly determined by the market. The professional
fees charged by private doctors were nominally guided by the
schedules of fees released by the MMA, but doctors were not
legally bound to do so. The MMA is a registered society whose
membership consists of doctors practicing in Malaysia.
Membership is on a voluntary basis, but sufficiently large
enough for the association to claim representation of the
medical fraternity in the country, including public and private
sector doctors working in hospitals or clinics.
The MMA had set up a HIC in the 1980s to develop a fee

schedule as a pre-emptive move in the event that a national
health insurance scheme was to be introduced in the country
(Malaysia Medical Association, 2014: pp. 121-124). During that
time, the GoM had commissioned a study of the Malaysian
health financing system to seek solutions to raising health care
costs and rapid development of the private health sector
(Westinghouse Health Systems, 1985). One of the
recommendations of this report was to introduce a national
health insurance scheme, referred to as the National Health
Security Fund (NHSF). Members of the MMA had felt that the
development of professional fees to be used in such a scheme
should be led by the medical profession itself and thus set up
the HIC to accomplish this.
The first edition of the MMA fee schedule was released in 1987
(Committee on Health Insurance, 1987) and listed professional
fees in four categories outpatient primary care consultations,
outpatient specialist consultations, procedural fees charged by
doctors and miscellaneous services such as the preparation of
medical reports. The second edition of the fee schedule was
released in 1992, the third in 1997, the fourth in 200226 and
the fifth in 2008 (Malaysian Medical Association, 2008).
In the development of the fee schedule, the HIC took into

consideration factors such as complexity of the service/
procedure, time taken and likelihood of complications, which
were factored into the Relative Value Scales (RVC) used. The
first edition of the MMA fee schedule had used the Californian
RVS. The second edition used the RVS developed by the British
25 This explanation was contained in a press release by the then Minister of Health, Dr S.
Subramaniam, in March 2014 to announce the revision of the 13th fees schedule for
private hospitals. The press statement is available from http://www.moh.gov.my/index.
php/database_stores/attach_download/337/485.
26 Information obtained from the article entitled, “Evolution of the MMA Schedule of Fees”,
published online by the Malaysian Society of Anaesthesiologists and the College of
Anaesthesiologists, and Academy of Medicine of Malaysia available from http://www.msa.
net.my/newsmaster.cfm?&menuid=21&action=view&retrieveid=21.

United Provident Association (BUPA). In this 1992 fee schedule,
the HIC decided to give a RVS point the value of RM 2.50 as
opposed to £1.00 used by BUPA at the time, even though the
currency conversion rate then was RM 4.20 to the pound.
Subsequent revisions of the fee schedules used the BUPA RVS
in use at the time of the revisions. Revisions also took into
consideration the rate of inflation in the interim time from the
last schedule. The fees included in the fourth edition was
approximately 10% higher than fees in the third edition.
The fourth edition of the MMA fee schedule was eventually

incorporated by the MoH into the PHFSA as the professional
fees for care obtained from private clinics and hospitals. The
MoH revised the fees for private hospitals in 2013. These
revised fees were on average 14.4% higher to partially cater to
the inflation rate of 23% during the period from 2006 to 2010
when the revision exercise started (The Star, 2014). The highest
increases had been for General Practitioner (GP)27 consultation
fees for which the ministry had explained was due to the
“rental costs in various locations” (The Star, 2014). The ministry
announced that this revision had taken into consideration
feedback from various stakeholders including the MMA. A
comparison of professional fees charged for selected services
in private clinics and hospitals is provided in figure 5.
27 GPs refer to non-specialist doctors who provide private primary care services usually on
outpatient basis.

Figure 5
Comparison of legislated professional fees for selected
services in private clinics and hospitals
Private Clinic Private Hospital Private Hospital

-2006 (2006) (2013)
Outpatient Care
Non-specialist RM 10 – RM 35 RM 10 – RM 35 RM 30 – RM 125
consultation
Specialist RM 60 – RM 180 RM 60 – RM 180 RM 80 – RM 235
consultation
(1st visit) (1st visit) (1st visit)
RM 35 – RM 90 RM 35 – RM 90 RM 40 – RM 105
(follow-up visits) (follow-up visits) (follow-up visits)
Procedures (including anesthetist’s fees)

Appendicectomy RM 1850 RM 2135
Simple RM 1970 RM 2250

mastectomy
including axillary
lymph node
biopsy
Extracapsular RM 3065 RM 3510
extraction of lens
with implant
Caesarean RM 2365 RM 2710
section
Source: Government of Malaysia, 2006a; 2006b; 2013.

Note: RM= Malaysian Ringgit 4.30 = US$ 1 in 2017.
Bundled payments in private facilities
Private hospitals may offer packages of health services for

which a bundled payment is charged. These include obstetric
packages (antenatal, normal vaginal deliveries and postnatal
care) as well as executive health screening packages. However,
bundled payments for these packages are based not just on
legislated professional fees for doctors but also on other
components of hospital fees. Thus, bundled payments may
differ across hospitals even for the same package of care.
Relationship between official fees and actual prices paid for

private care
The fees for private care as detailed in the regulations of the

PHFSA 1998 refer to the maximum professional fees that can
be charged by health care professionals. Under the Act, these
professionals are not permitted to exceed the limits set.
However, since professional fees are but one component of
patient bills, the actual payment made by patients will be
higher than fees charged by doctors.

Mechanisms to monitor provider behaviour in the private
sector
PHFSA 1998, Section 36, requires all licensed private hospitals

in the country to set up a patient grievance mechanism to
handle complaints from patients including those who are not
satisfied with their hospital bills. If the patients are dissatisfied
with the explanations provided by the hospital management,
they can dispute fees with the MoH. However, since total
hospital charges are not regulated under the law, there is little
that the MoH can do to hospitals that purportedly overcharge
patients except to mediate between the patient and the
hospital. The only area that the MoH can act upon is in the
matter of medical professional fees.
Use of medical fees in the remuneration of private sector

doctors
Most specialist doctors working full-time in the private sector

are not employed by the hospitals they practice in. They are
considered independent contractors. These specialist doctors
may admit patients to the private hospitals and use the
hospital equipment and other available facilities such as
laboratories and operation rooms. The doctors will then
stipulate their professional fees for services rendered, and the
hospital concerned will include these fees in the overall
hospital bill given to the patient. In addition to the doctors’
professional fees, these itemized bills will include fees for
other service components received by patients such as ward
fees, fees for investigations and drugs,28 which will be retained
by the hospital concerned. Specialist doctors can expect to
receive the professional fees charged net of payments to the
hospital for the admitting privileges enjoyed by them. The
professional fees charged by doctors working in private
hospitals are regulated via the PHFSA 1998 (Government of
Malaysia, 1998). It is a common practice for private specialist
doctors to have admitting privileges to several hospitals
concurrently. Some doctors have also invested in the hospitals
they practice in. As such, they may receive a portion of the
profits due to them as company shareholders.
Contractual arrangements for private specialist outpatient

services are varied. Some specialist doctors rent or may even
have bought clinic premises within private hospitals or other
locations such as commercial shop lots. They manage these
clinics autonomously, including hiring their own clinic support
staff. In such cases, the doctors may bill patients directly for all
services provided including minor procedures, such as laser
therapy for dermatological conditions, performed in the clinics.
The professional fees charged by doctors working in standalone
private clinics are regulated via the PHFSA 1998. Some
specialist doctors rent sessions from the hospitals where they
provide outpatient consultations in clinics managed by the
hospitals. In such cases, they continue to use most of the
28 In general, profits from the sale of pharmaceuticals are retained by the private hospitals
and not shared with health care professionals.

hospital support staff and facilities, including laboratories and
pharmacies, and charge patients only professional consultation
fees listed in the PHFSA 1998.
GPs are mainly located in residential areas for the convenience

of patients. Whilst most GPs provide primary care services,
some clinics also provide simple laboratory and radiological
examinations. Doctors in Malaysia do not practice the
separation of prescribing and dispensing drugs. Patients who
obtain care from GPs or even specialist doctors practicing in
standalone clinics29 would expect to obtain their medications
in the same premises directly after the consultation with the
doctors unless the drugs are not in stock, in which case the
patients are referred to private pharmacies. Unlike doctors
practicing in private hospitals, GPs generally prescribe generic
medicines, since their patients would also expect that these
medications be included in the consultation fees paid to the
GPs (Malaysian Competition Commission, 2017: p. 62).
Discussion
The practice of medical fee setting is still in its infancy in

Malaysia. Although such fees are a common feature in the
public health sector, cost recovery for public care is not yet
high on the priority list for the GoM. The welfare philosophy
underlying the delivery of public care does not incentivize the
MoH to fine-tune mechanisms or to train and maintain
dedicated personnel to set public fees. However, the need to
develop such resources may become more apparent as years
pass in tandem with increasing public demand for reasonably
priced private health care.
The vibrant private health sector found in Malaysia today is a

relatively new phenomenon. Malaysia experienced rapid
economic growth in the 1980s. Private health care services
have been viewed by many in Malaysia as being of higher
quality compared to care provided by public sector providers.
Unlike the primary care gate-keeping mechanism in operation
in the public sector, patients can access any level of private
health care that they desire and have the means to pay for. The
practice of private health care in the country allows patients to
choose their doctor and to be assured clinical management by
their chosen doctor unlike the less personal practice of clinical
team management in most public health settings. Private health
facilities are better equipped with expensive advanced
technology than most public health facilities, especially those
in rural areas. The ability to obtain higher income in the private
sector has contributed to the movement of public health care
professionals to the private sector, especially senior specialist
doctors (Merican and bin Yon, 2002). Another important reason
for choosing private care appears to be that of a shorter waiting
time. In a 1996 national household survey, more than half of
the respondents did not seek care from the nearest health
facility to their homes, and 61.3% of this more than half
by-passed public health facilities in favour of a private clinic or
29 Doctors who practice in a hospital setting may refer their patients to the hospital
pharmacies to obtain their medications.

private hospital30 (Institute for Public Health, 1997). The most
common reason given for this was because of long waiting
times at the public health facilities.
Armed with higher purchasing power, consumers have become

appreciative of private care, especially the expanding cohort of
middle-income families. Private facilities developed to meet this
demand and are characterized not just in increasing numbers
but also changes in delivery structure. During this time, private
health care providers evolved from single doctor clinics and
small secondary care hospitals to the large networks of clinics
and hospitals in existence, especially in urban areas, today. The
early hospitals were mainly charitable entities owned by
philanthropists or missionary organisations. Later, many doctors
also invested in private hospitals. It has been argued that profit
making was not the raison d’être of the early hospitals. High
hospital bills were not a pressing issue then as they are now.
Over the past decade or so, many doctors have sold their stakes
to private investors or even to GLCs. GLCs may have government
ownership but are managed as commercial for-profit
enterprises. There are anecdotal accounts that high private
hospital bills have prevented access to private care and thus
may have led to poorer health outcomes, but such statistics are
not routinely collected (The Star, ; 2009; 2011; 2012).
Private hospital bills affect not just the patients who pay OOPP
for care, but also health insurers. The most common form of
medical and health insurance (MHI) is hospitalisation and
surgical indemnity insurance policies, which provide for the
reimbursement of medical, surgical and hospitalisation
expenses incurred by those insured. In 2005, about 15% of the
population had some form of health insurance cover (Central
Bank of Malaysia, 2005: p. 58). By 2014, the coverage increased
to 45% of the population, or about 14.7 million people
(Malaysian Productivity Corporation, 2016: p.112). It is
important to note that people in Malaysia buy health insurance
mainly to gain access to private care (Chan, 2014). This is due
to the general perception that private care is of higher quality
compared to care received from public providers. Private
insurers are wary of private hospitals charging insured patients
higher fees for the same level of care compared to those who
do not have insurance coverage (Chan, 2014; Lee et al., 2018).
Thus far, the law has not provided protection from such
practices since legislated professional fees cover only a portion
of total hospital bills. The MoH is aware of the need to close
this loophole in the law, not just to protect third party payers
such as insurers but also the public at large. In 2018, the
previous Minister of Health announced that the ministry is
exploring the option of a ‘bundling system’ for private hospital
fees (Sundaily, 18th January 2018). Such ‘bundles’ would
include all fees, professional or otherwise, for a package of
care. He acknowledged that the task was not easy and involved
consultations with all stakeholders, including the Central
30 The rest mainly by-passed one category of public facilities for another.

Bank,31 private insurers and private hospitals. There has been
no further announcement of developments to date.
Insurers may feel that they have valid reasons to call upon the
MoH to help them control patient bills. On the flip side, some
doctors have also raised concerns that certain insurance
practices place them at a disadvantage resulting in an unfair
reduction of income. This issue relates to their dealings with
Managed Care Organisations (MCOs), which include insurers.
MCOs in Malaysia work on behalf of companies or insurers to
help them contain health care costs of their employees or
those insured. It has been estimated that the market for MCO
services grew from a coverage of 300 000 persons in 1997 to
16.36 million in 2014 (Malaysian Productivity Corporation,
2016: p. 99). The modus operandi of MCOs is to recruit and
appoint private hospitals and clinics as their panel providers to
service their enrollees. In return for the promise of high patient
volume, these companies would negotiate for lower fees, which
invariably affect the professional fees charged by doctors. This
is permitted under the law, as legislated private fees are the
maximum allowed for the service charged. Doctors under
contract to work in private hospitals have no choice but to
accept the lower fees negotiated by the hospital management.
In order to gain a share of the patient pool, GPs have had to
acquiesce to the MCOs’ demand for lower fees as well. GPs
working in standalone clinics are particularly hit hard. GP fees
were legislated in 2006, and the fees for GP consultations were
between RM 10 to RM 25 (Government of Malaysia, 2006b).
Unlike legislated fees for private hospitals, which were revised
in 2013, GP fees have remained unchanged since 2006. It was
claimed that the allowable fees have not kept up with the
increasing clinic maintenance costs (Malaysian Productivity
Corporation, 2016: p.106). To make matters worse, there is now
a discrepancy in GP fees between doctors who work in private
hospitals (RM 35 to RM 125, as stated in the 2013 private
hospital fee revision) and those working in standalone clinics
(RM 10 to RM 35, as per the 2006 private GP regulations). The
MoH has announced that it will look into revising these fees to
assuage discontent among GPs (The Star, 5th October 2018). In
January 2019, the MoH announced a scheme to buy care from
GPs as a move to expand health screening services for the poor.
However, progress has stalled because the GPs rejected the
proposal by the MoH to use the 2006 fees as the basis for
negotiations (The Malay Mail, 2nd February 2019).
31 Bank Negara Malaysia, or the Malaysian Central Bank, is the regulator of all banking and
insurance activities in the country.

5
Conclusions
The Malaysian health care system is changing rapidly to cater to
the more discerning tastes of middle- and high-income
households, while at the same time trying to expand
accessibility of care to the poor. The GoM is making efforts to
set fees for public care, which is apparent in its efforts to
recover the cost of care provided to non-citizens. However, in
the absence of accurate information on costs, these efforts
seem arbitrary in nature. The current focus appears to be on
refining fees for private care. This is in response to public
demand for reasonable fees and also in view of the
government’s expectation for the private sector to shoulder a
greater share of care provision in the country. If the government
is serious in its intentions to control medical fees and to
develop fees acceptable to all stakeholders in the country, then
it needs to invest in building the infrastructure needed for fee
setting. This would include training dedicated personnel to
capture and analyse costs as well as a system for better
collaboration among policy stakeholders both within and
without the ministry.

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Development; 2019.

Case study
Republic
of Korea
Soonman Kwon
Seoul National University
Republic of Korea
197
Republic of Korea
Abstract 199
1 Development of National Health Insurance

and Purchasing Mechanism 200
2 Governance of Price Regulation 201
3 Provider Payment Systems and Pricing 203
Fee-for-Service (FFS) Payment 203

Case-based Payment 204
Pay for Performance 205
Per-diem Payment for Long-Term Care Hospitals 206
Pay for Long-Term Care (by Long-Term
Contents Care Insurance) 206
4 Institutions for Cost Estimation and

Price Setting 207
5 Review and Monitoring of Provider Behaviour 208
6 Performance and Effects of Price Setting 209
7 Key Lessons 214
References 216

The Republic of Korea (henceforth referred to as Korea) uses
price regulation for health care that is based mainly on fee-for-
service (FFS). FFS in Korea has been applied to outpatient and
inpatient care for all levels of providers, from physician clinics
to tertiary care hospitals, since the introduction of mandatory
health insurance system in the late 1970s (which later reached
universal coverage for the population in 1989). The goal of
price regulation was to ensure access to health care and
contain health expenditure by tightly regulating the price of
health care in the context that the majority of health care
providers are private. Initially, private providers were opposed
to the fee scheduling of the national health insurance (NHI)
system, where balance billing is not allowed. However, the
authoritarian government in the late 1970s was able to enforce
a unilateral fee setting for all providers that denied an opt-out
option so that the same fee schedule applied to both public
and private providers.
Abstract Since 2000, the National Health Insurance Service (NHIS) and
each provider association (physicians, hospitals, pharmacists,
etc.) negotiate the fees. When negotiations fail, the tripartite
Health Insurance Policy Deliberation Committee (HIPDC)
decides the fee. Health Insurance Review and Assessment
(HIRA) also plays an important role in costing and analyzing
provider behaviour related to pricing. Pricing for health care is
based predominantly on FFS, with the exception of Diagnosis
Related Group (DRG)-based payment for six disease categories
and per-diem case-based payment for long-term care (LTC)
hospitals as well as the piloting of a mixed payment of DRG,
FFS and per-diem payment. There is no bundled payment
system to cover the services given by the different levels of
providers.

1
Development of National Health Insurance
and Purchasing Mechanism
NHI of Korea has adopted price regulation for health services
since its inception. Although not explicitly stated, keeping
prices low through fee scheduling has been regarded as
essential for the cost containment and financial sustainability
of NHI. Price regulation has long been one of the most
important elements of purchasing in the Korean NHI system. In
the early stage of health insurance development, the
government used price regulation to keep premium
contributions low and expand population coverage rapidly.
Price regulation has been the main target of complaints by
health care providers, which are predominantly private, who
maintain that the low fees fail to compensate for the cost of
service provision (Kwon, 2009a).
When national health insurance was introduced, the

government set the fee schedule lower than customary
charges, although there is no scientific evidence on the extent
that NHI reimbursement covers the cost of provision. The
government was worried that the majority of health care
providers would not contract with NHI when the contract
conditions, such as payment level, were not generous, resulting
in potential access problems for the insured. Consequently, the
government mandated all health care providers to join the NHI
system. In other words, providers were not allowed to decline
treatment to NHI patients. However, the mandatory
participation of providers also means that NHIS does not
selectively contract with providers nor exercise its purchasing
power as a single payer.
More than 300 health insurance funds/societies, covering three

different types, namely, public employees and school teachers,
private sector employees, and the self-employed, were merged
into a single fund in 2000 (Kwon, 2018). Since then, national
(public mandatory) health insurance has two agencies. NHIS
handles premium collection, fund pooling, and reimbursement
to providers. HIRA deals with purchasing, such as claim review
as well as the design of benefits package and provider payment
system. Providers submit medical care claims to HIRA, which
reviews and assesses the claims and sends the information to
NHIS for reimbursement to providers. The launch of a single
purchaser to some extent provided an opportunity for NHI to
strengthen its purchasing capacity, including a more
sophisticated method and process related to price setting.
NHIS sets and collects insurance contributions and manages

the eligibility of the insured, health insurance benefits,
including prevention programs, and reimbursement to
providers. NHIS manages both health insurance and LTC
insurance. HIRA reviews expenses associated with the health
insurance benefits utilized, assesses the appropriateness of the

health care utilized by comparing with guidelines or clinical
decisions of similar providers, and develops standards for
benefits and reimbursements.
Although reimbursement to providers is paid by NHIS, HIRA

plays an important role in the purchasing through claim review
and quality monitoring; guidelines for quality; designing
benefits standard for providers (criteria of reimbursement);
payment system and costing; listing and classification of
procedures, pharmaceuticals and materials for provider
payment and claims; and resource management through the
profiling of providers and high-cost technology/equipment.
HIRA plays the major role in the technical work regarding
collecting and analysing provider activity and cost data.
In terms of governance, the NHIS’s board of directors consists

of 16 members: one president, 14 directors, and one auditor.
The president, auditor, and five directors work full-time. NHIS
has one headquarter (eight bureaus), one research institute, six
regional offices, 178 branch offices, one general hospital, and
one LTC facility (www.nhis.or.kr). NHIS has about 14 000
workers. HIRA has one headquarter (22 departments), one
research institute, and seven regional offices. One of the key
institutions of HIRA is the Healthcare Review and Assessment
Committee, which consists of less than 1050 members and
maximum of 50 full-time members, who play an important role
in the benefits design, and the review and assessment of
claims. HIRA also has various expert committees to support
technical decisions. In total, HIRA has about 2500 workers.
The main responsibility for NHI policy formulation and planning

is on the Ministry of Health and Welfare (MoHW). MoHW plays a
key role in translating health policy goals and service planning
priorities into NHI programs (Kwon, Lee and Kim, 2015). To
implement NHI, NHIS and HIRA monitor and assess claims,
health care utilization, health care cost, etc., and give reports
and recommendations to the MoHW.
2
Governance of Price Regulation
In the single insurer system established after the merger, major
decisions on health insurance, such as contributions and
benefits coverage, became a national agenda and required a
new policy framework (Kwon, 2003a). NHI introduced an annual
price negotiation between the insurer and provider associations,
replacing the unilateral price setting by the insurer and the
MoHW. Initially, NHIS negotiated the annual increase in fee with
the coalition of provider associations, i.e., both medical and
hospital associations. Because it was difficult to get consensus
among all provider associations, these negotiations rarely
succeeded. This condition changed after negotiations were
changed to occur between the NHIS and individual provider
associations. The negotiation is on price only, without
consideration of volume or a sectoral/overall spending cap.
After experiencing a big financial deficit in 2001 as a result of a
fee hike for physicians after their strikes against pharmaceutical
reform (Kwon, 2003b), the health insurance system introduced
HIPDC, which approves major decisions on health insurance,
such as the contribution rate, benefit packages, pricing, etc.
When the annual negotiation on price increase fails between
NHIS and each provider association, e.g., medical, hospital,
dental, traditional medical, pharmaceutical, etc., HIPDC makes
the final decision on fees.
As a tripartite committee, HIPDC consists of 25 members,

including the Vice Minister of Health and Welfare as the Chair,
and representatives of payers, providers, and expert/public
interests. Eight members represent payers (two from labour
unions, two from employer associations, and one from a civic
group, consumer association, farmers association, and self-
employed association, respectively), eight from health care
providers (two from the Korean Medical Association, and one
from the Korean Hospital Association, Korean Traditional
Medical Association, Korean Dental Association, Korean
Pharmaceutical Association, Korean Nurse Association, and
Korean Pharmaceutical Manufacturers Association, respectively),
and eight experts and public agency representatives (one from
MoHW, Ministry of Strategy and Finance, NHIS, and HIRA,
respectively, and four independent experts).
Voting in HIPDC follows a majority rule with a quorum of half of

the members. The chair participates in the voting only when no
majority is reached. Those representing payers and those
representing providers are almost always divided, e.g., payers
are against an increase in contribution and provider fee, while
providers generally support the increase. In many cases, the
eight members representing experts and government/insurer,
especially the four independent experts, play a key role in the
final vote outcome. The four experts vote independently as
individuals.
The decision of HIPDC is final with no mechanism for dispute

resolution. The government nominates the four expert
members, and provider groups criticize that those four experts
are not neutral or independent but often biased against
providers. Provider groups maintain that two out of four experts
should be nominated by providers and two by payers rather
than by the government.
HIPDC is also involved in benefits decisions. A request for a

service to be included in the benefits package can be
submitted by provider associations, consumer groups, NHIS,
etc. The request should be endorsed by HIPDC with crucial
inputs provided by NHIS and HIRA. Pharmaceutical
manufacturers submit a request for medicines to be covered by
NHI, for which HIRA makes a decision on listing based on
economic evaluation and other considerations (budget impact,
severity of disease, etc.). Then, NHIS negotiates the price with
the manufacturer. Pharmaceutical spending accounts for 22.5%
of total health expenditure as of 2017 (OECD, 2018).

Under NHI, the copayment rate for inpatient care is 20%,
except for cancer and cerebrovascular patients (5% copayment
rate). A reduction in the copayment for cancer patients has
improved equity in health care access and payment (Kwon, Lee,
and Kim, 2015). Copayments for outpatient care are 30-60%
depending on the level of providers, i.e., physician clinics,
hospitals, general hospitals, and tertiary care hospitals. There is
a ceiling on total copayment for NHI every six months, with a
higher ceiling applied for higher income groups (total of seven
groups). Patients pay the full price for uninsured services, i.e.,
those not included in the benefits package.
3
Provider Payment Systems and Pricing
Fee for Service (FFS) Payment
FFS is applied to outpatient care and the majority of inpatient

care in acute care hospitals. There is little distinction between
primary and specialist care, e.g., the majority of physician
practitioners working in clinics are board-certified specialists,
and there is a very limited role of gatekeeping and referrals. As
a result, there is a uniform fee schedule for all types of
outpatient care. HIRA classifies services and procedures for fee
scheduling under FFS payment. On the other hand, providers
tend to prefer classification into as large a number of services
as possible. As of 2014, there were 7489 services and
procedures, 18 262 materials, and 15 734 medicines in the
benefits package reimbursed by FFS payment.
The fee schedule is based on a Resource-Based Relative Value

(RBRV) system. Relative value considers physician workload
(time and effort) and overhead cost plus the risk associated
with malpractice, although its amount is very small compared
with the workload and overhead components. One of the key
weaknesses of RBRV is that medical care is valuated based on
the input of providers and its value to patients (e.g.,
contribution to health outcomes) is not considered in the
pricing. In other services, for example, two services with
identical input costs lead to the same price even when the
contribution/benefit of the two services to patient outcomes
are different.
The measurement of physician workload is delegated to

provider associations, and the measurement of the overhead
cost is the responsibility of HIRA. The relative value scale
covers all medical care, and the determination of relative value
includes a lengthy bargaining process among specialties as it
tends to redistribute income among them. For example, the
relative values for surgery, radiology services, and laboratory
tests are still regarded as over-valued compared with
consultation services in Korea. As a result, the relative value
scale of individual services is revised only periodically through
technical committees with the participation of medical

societies. The conversion factor (unit price per relative value,
which is used to convert the relative value into a fee) is
negotiated between NHIS and each provider association every
year, as mentioned above.
The value of physician workload is controversial. There is a big

concern about using physician income to determine the value
of workload in the RBRV because physicians seem to earn
excessive income as a result of an imperfect market for medical
care, i.e., monopoly power of the medical profession. Physician
workload is the major component of the cost of clinics, but
overhead cost accounts for a larger share of hospital costs.
Consequently, overhead cost measurement and allocation is a
very important element of RBRVs for hospitals. The allocation
of overhead cost to various departments and further to
individual services is highly controversial and can even be
arbitrary. Because the majority of hospitals are private, HIRA’s
research on fee scheduling (usually in collaboration with
universities and research institutes) is based on only a small
number of sample hospitals, which causes controversy over the
representativeness of the cost data. HIRA provides some
financial incentives for providers that join the sample, so the
sample changes each year, and its composition is not
representative. To get accurate data for costing is always a
challenge for price setting in Korea.
The FFS system has led not only to an increase in volume and
intensity of services, but also to the provision of services with a
greater margin and even a distortion in the supply of medical
specialties in the long run. For insured services, physicians are
not allowed to charge more than the fee schedule set by NHI
(i.e., no balance billing). However, physicians can provide both
insured and uninsured services in the same episode of care/
visit and charge high fees for uninsured services (so called,
extra billing) to compensate for the low pay by the tight fee
schedule for insured services.
Case-based Payment
DRG-based payments has been applied for seven minor

surgeries since July 2012, including lens procedures,
appendectomies, caesarean sections, tonsil and adenoid
procedures, inguinal and femoral hernia procedures, anal
procedures, and uterine and adnexa procedures for non-
malignancies. The DRG payment system accounts for only
about 5% of inpatient care expenditure. HIRA has a department
responsible for the classification, pricing, and evaluation
associated with DRG-based payments.
To transition from FFS to DRG payment for inpatient care, the

government launched a DRG pilot program in February 1997
for voluntarily-participating providers. The pilot program
confirmed the positive impacts of the DRG payment on the
behaviour of health care providers, such as a reduction in the
length of stay, medical expense, average number of tests, and
the use of antibiotics without a negative effect on quality of

care (Kwon, 2003c), but strong opposition by providers has
been a stumbling block to extending the DRG system beyond
the seven minor surgeries listed above.
A combination of per-diem, FFS, and DRG payment, which is

known as a new case-based payment in Korea, but is very
similar to the DPC (Diagnosis Procedure Combination) payment
in Japan, is applied for all cases in NHIS Ilsan Hospital and all
local government hospitals (Annear et al., 2018). In this
payment, hospitals are still paid for more hospital days
exceeding the pre-specified level, albeit at a reduced rate
(80%), and reimbursed through FFS for those services whose
fee is over about US$ 100. Because it is not a pure prospective
payment, the government expects that providers are more
willing to accept this new type of case-based payment
compared with the DRG-based payment. However, this new
payment has a limited impact on the efficiency of provider
behaviour. It has not reduced the length of stay or health
expenditure, but rather increased the provision of services that
are more expensive than the threshold level of US$ 100 in
participating hospitals (Kwon et al., 2013). Due to provider
opposition to the DRG-payment system, the government seems
committed to a mixed payment system similar to DPC and has
encouraged (private) hospitals to join its pilot program by
offering the carrot of high fees.
Pay for Performance
HIRA has implemented pay for performance (P4P), or the Value

Incentive Program, for selected areas, but mainly for tertiary
care and general hospitals. It began with AMI (acute myocardial
infarction) and caesarean sections. Performance measures used
volume, process (use of timely interventions and medications),
and outcomes (mortality within 30 days) for AMI, and the
difference between actual and risk-adjusted rates in caesarean
sections. The performance of 43 large general hospitals was
first evaluated at the end of 2008, resulting in hospitals being
divided into five groups (relative ranking). A financial incentive,
which was 1% of total health insurance reimbursement, was
paid to group 1 at the end of 2009. A financial disincentive,
which was -1% of insurance reimbursement, was introduced in
2010 when scores lower than the (absolute) threshold (highest
score of hospitals in group 5 in 2008) were recorded. It is
reported that P4P resulted in 1.55% improvement in the
quality measure for AMI between 2007 and 2008, a 0.56%
point drop in the caesarean section rate, and an overall reduced
variance in quality among providers, and significant
improvement in the lowest performers (Cashin et al., 2014;
OECD, 2010).
The target area and hospitals of the program have been

extended, taking into account severity, feasibility, possible
improvement, and social impact (HIRA, 2017). As of 2016, P4P
covers acute stroke for tertiary care hospitals, surgical antibiotic
prophylaxis for general hospitals, hemodialysis for hospitals,
and drug prescription for clinics. The financial incentive
structure has also changed. Hospitals are evaluated and divided
into five groups as before, but the incentive varies for different
target areas. For example, for antibiotic use, the top 3% of
hospitals get incentives and bottom 40% are subject to
disincentives. For dialysis, top 10% get incentives and
hospitals with a performance score under 65 receive
disincentives.
The current P4P model focuses too much on clinical quality and
should be extended to other important performance measures
such as the length of stay, intensity of care, etc. How to use the
P4P framework to improve the quality of primary care is a
concern too. P4P in Korea currently targets areas where it is
easier to measure performance, rather than areas that have the
most serious quality issues. Furthermore, participants are
mainly big hospitals, not because they have the most serious
quality problem, but because their performance is easier to
assess or they have less problems of reporting compared to
small-scale providers. In the future, P4P based on hospitals
should take into account the performance of individual
physicians.
Per-diem Payment for Long-Term Care Hospitals
NHI pays LTC hospitals based on per-diem payment,

differentiated by seven categories: highest medical need, high
medical need, medium medical need, behaviour problems,
cognitive impairment, low medical need, and physical function
problems. Those seven categories are further classified into
subcategories based on ADL (activities of daily living), resulting
in 15 different per-diem payment levels.
Per-diem payments are adjusted upward depending on the

number of physicians, nurses, and other health personnel
above minimum requirements (compared with acute care
hospitals, LTC hospitals have lower minimum requirements in
terms of medical personnel per patient). Per-diem payment
accounts for about 10% of inpatient care expenditure. Per-
diem payment does not include all costs, and FFS is applied to
CT, MRI, special rehabilitation treatment, dialysis, prescription
medicines for dementia, and costs paid for referred services.
Pay for Long-Term Care (by Long-Term Care Insurance)
Korea introduced public insurance for LTC in 2008 (Kwon,

2009b). NHIS manages LTC insurance to collect the
contribution, assess the eligibility of applicants, and reimburse
providers. All insured with NHI are insured for LTC insurance,
but in the case of those under 65 years, LTC insurance provides
coverage only for age-related LTC needs. The LTC insurance
contribution is collected from all enrollees of NHI. The
contribution was set to 6.55% of NHI contributions until 2017,
7.38% in 2018, and 8.51% in 2019.
Benefit packages consist mainly of in-kind benefits, i.e., home

care and institutional care; home-visit care/nursing, bathing,

and assistive devices such as wheelchairs, walkers, and bath
chairs, etc., for home care services; and aged care facilities and
congregate housing for institutional services (Jeon and Kwon,
2017). A ceiling of benefits per month for residential care exists
depending on the five different functional levels based on the
need assessment. The functional levels are determined when
NHIS assesses the eligibility of the applicant for the benefits of
LTC insurance.
In NHI, there is a division of labour between NHIS and HIRA, but

NHIS performs all necessary functions, including claim review
and assessment, in the case of LTC insurance (NHI pays LTC
hospitals, while LTC insurance pays LTC facilities, which are not
required to employ physicians.). The payment for residential
care (at LTC facilities) is per-diem, the level of which depends
on the five functional levels of the beneficiary.
The fee is determined by NHIS, with no negotiation of fee

between NHIS and providers. NHIS plays the major role in the
technical work on collecting and analysing provider activity and
cost data. The absence of fee negotiations in LTC insurance, in
contrast to NHI, shows the weaker professional/bargaining
power of LTC providers compared with health care providers.
Separate public insurance for health care and LTC, although
managed by NHIS, still causes problems in the coordination of
health care (e.g., those provided by LTC hospitals) and LTC (e.g.,
those provided by LTC facilities) (Kim, Jung and Kwon, 2015).
4
Institutions for Cost Estimation and Price
Setting
Price reimbursement to providers by NHIS is supposed to cover
both capital and operating costs, although providers argue that
the price is below the cost of production such that they incur a
loss. Physicians argue that they have incentives to provide
uninsured services, for which they can charge market/
customary prices, to compensate for losses from insured
services. However, there is little scientific evidence to support
the providers’ argument regarding the fairness of NHIS
payments. To the contrary, admission to medical schools has
become more and more competitive, and the entry into the
hospital market has increased with a comparatively very small
number of exits, all of which indicate that the physician and
hospital services markets are very lucrative.
Cost finding mainly uses bottom-up approaches with micro-

costing. As mentioned earlier, the availability and reliability of
cost data is a key challenge, because the majority of providers
are private and reluctant to provide detailed information on
their financial condition. Providers should submit to HIRA data
on the provision of insured services in order to get
reimbursement, but neither the government nor insurers have
regulatory power to force providers to submit data on

uninsured services because those services are not subject to
reimbursement by NHI.
Prices are different for different levels of providers. NHI has a

uniform fee schedule, above which it adds 15% more for
physician clinics, 20% for hospitals, 25% for general hospitals,
and 30% for tertiary care hospitals. The price differential
among different levels of providers is based on the idea of a
higher fee for higher input cost, but there is no guarantee that a
higher cost and price for a higher level of providers leads to
higher value/quality for patients. There is little rationale on the
amounts of top-up for providers, e.g., why tertiary care
hospitals should be reimbursed 10% more than hospitals and
5% more than general hospitals. Further, the higher fee can
provide perverse incentives for hospitals to increase their
physical capacity to a higher level, resulting in the increasing
dominance of big hospitals.
NHI pays a uniform fee to public and private hospitals. Because

more than 90% of hospitals are private, the (uniform) fee is
regarded as a fee for private providers. Almost all public
hospitals have fiscal autonomy, and budget funding for them
accounts for a much smaller share of reimbursement from NHI.
For LTC hospitals, NHI pays a 5% lower price for long-term

stays over six months and 10% lower price for stays over one
year to encourage hospitals not to keep patients longer. It
seems that the discount for long-term stays in LTC hospitals is
not very effective, because patients of long-term stay usually
benefit from the ceiling on out-of-pocket payment under NHI
(no out-of-pocket payment once payment exceeds a threshold).
For physician clinics, there was a price discount of 10% when
the number of patients exceeded 75 per day, but this discount
was abolished in 2015.
5
Review and Monitoring of Provider
Behaviour
Currently, Korea has a sufficient supply of providers who cannot
survive without participating in NHI (in the system of universal
population coverage). However, NHI needs to re-consider the
mandatory participation of providers. The policy of mandatory
participation and no selective contracting limits the single
payer NHI to exercise its bargaining power in the selection of
providers and maintaining quality of care. The compulsory
participation of providers in NHI has been a politically sensitive
and controversial issue. Progressive civic groups are worried
that the abolition of the mandate on providers will lead high-
quality hospitals to not join NHI. Under universal coverage of
the whole population, even leading tertiary care hospitals do
not have financial incentives to opt out of NHI.
In the absence of selective contracting, review and assessment

by the purchaser are important for assuring the quality and

performance of providers. NHIS and HIRA have a strong
information and communications technology (ICT) base for their
purchasing function. HIRA, in particular, fully utilizes claims
data covering all providers and the entire population. For
reimbursement, health care providers should submit claims to
HIRA; 99.9% of health care providers submit claims through an
EDI (Electronic Data Exchange) system introduced in 1996 or
Medical Claims Portal Service introduced in 2011. About 1.4
billion claims are filed every year, approximately 65% of which
are reimbursed after the electronic review. Thanks to ICT, it
takes a maximum 15 days from claim to payment to providers.
HIRA applies an electronic checkup for errors, omissions or

miscalculations, and the electronic review is based on
indicators such as disease type and medication. Some claims
such as outliers are reviewed closely by (full-time) review
personnel, with additional input by (part-time) experts or
committee members. HIRA reviews claims based on detailed
review guidelines. Under FFS payment, the review and
assessment are complicated with ever increasing numbers of
rules, standards, guidelines, etc. When the review is done, HIRA
sends the results to NHIS, which then pays the providers. If
providers do not agree with the review results, they can appeal
to HIRA. If they cannot accept the results of the appeal, they
can appeal to the MoHW. In 2017, HIRA performed on-site
investigations of about 950 health care providers, which is
about 1.3% of all providers (HIRA, 2018).
Thanks to universal population coverage, HIRA manages nation-

wide data, covering all providers and the whole population of
Korea. Performance information is disclosed to the public
through the HIRA website to help them make rational choices
regarding providers. In the inpatient sector, quality is measured
in terms of structure, process and outcome for selected areas,
such as AMI, acute stroke, caesarean sections, and CABG
(coronary artery bypass graft), colorectal cancer, breast cancer,
lung cancer, surgical volume for five surgeries, use of
prophylactic antibiotics for 11 surgeries, etc. For chronic
conditions, hypertension, diabetes, hemodialysis, and asthma
are assessed. Regarding outpatient medications, information is
gathered for the prescription rates of antibiotics and injections,
number of medicines per prescription, and expense of
medicines prescribed.
6
Performance and Effects of Price Setting
The effect of price setting seems limited, as providers can
increase volume under FFS. In health systems where FFS is the
major type of provider payment system without a macro-level
spending cap and where the majority of providers are private,
cost containment is a huge challenge. The number of outpatient
visits in Korea is the highest and the length of stay for inpatient
care is the second highest (after Japan) among OECD countries

(Figure 1 and Figure 2). Korea spends almost 8% of GDP on
health care, which is lower than other OECD countries (Figure
3). However, Korea has experienced the second highest (after
Chile) growth rate of health expenditure in OECD countries
(figure 4). The health insurance contribution has also increased
rapidly.
Figure 1
Average number of outpatient visits per patient per year
(2015)
Korea
Japan*
Hungary
Slovak Republic
Germany
Turkey
Netherlands
Canada
Spain*
Australia
Poland
Belgium
Slovenia
Austria
Estonia
France*
Iceland*
Latvia
Luxembourg
Ireland
Denmark
Finland
Norway
Chile*
Sweden
Mexico
0 2 4 6 8 10 12 14 16
Number of visits per year
Source: OECD Health Statistics, 2016. Note:*2014.

Figure 2
Average length of stay per inpatient case (2015)
Japan
Korea
France*
Hungary
Finland
Czech Republic
Luxembourg
Germany
Portugal
Austria
Switzerland
Latvia
Italy
Belgium*
Estonia
Poland
Spain
Slovak Republic
United Kingdom
Israel
New Zealand*
Slovenia
Norway
Ireland
Iceland
United States*
Sweden
Chile*
Australia*
Denmark
Mexico
Turkey
0 5 10 15 20 25 30
Number of days
Source: OECD Health Statistics, 2016. Note:*2014.

Health expenditure as percent of GDP
212
0
2
4
6
8
10
12
14
16
18
Australia
Austria
Belgium
Canada
Chile
Czech Republic
Denmark
Estonia
Finland
France
Germany
Greece
Hungary
Iceland
Ireland
Tax
Israel
Figure 3
Italy
Japan
Out-of-pocket
Korea
Latvia
Luxembourg
Social health insurance

Mexico
Netherlands
New Zealand
Source: OECD Health Statistics, 2016.

Health expenditure as % of GDP
Norway
Other

Poland
Portugal
Slovak Republic
Private Insurance
Slovenia
Spain
Sweden
Switzerland
Turkey
United Kingdom
United States
Figure 4
Average annual rate of increase in health expenditure (2007-
2016)
Chile
Korea
Sweden
Australia
Israel
Poland
Switzerland
Japan
United Kingdom
Ireland
Czech Republic
New Zealand
Norway
Estonia
Canada
United States
Belgium
Turkey
Germany
Luxembourg
Netherlands
Mexico
Slovak Republic
Austria
France
Slovenia
Finland
Denmark
Spain
Hungary
Iceland
Italy
Latvia
Portugal
Greece
-5 -4 -3 -2 -1 0 1 2 3 4 5 6 7
Rate of increase (%)
Source: OECD Health Statistics, 2016.
More than 70% of the Korean population is enrolled in

(supplementary) private health insurance, which covers
copayment for public health insurance (i.e., NHI) and payment
for uninsured services. In other words, private health insurance
does not set its own prices for medical care, but rather
reimburses the OOP (out-of-pocket) payment to enrollees.
(Some private insurance also provides cash benefits based on
the number of inpatient days.) Jeon and Kwon (2013) show that
private insurance has a negative spillover effect on public
insurance, as those with private coverage increase the
utilization and expenditure of (public) health insurance. The
government currently has a regulation that private health
insurance can cover up to 80% of health expenditures, which
may have to be reduced to mitigate the moral hazard effect of
private health insurance. Other than that regulation, there is
little coordination between NHI and private health insurance.
Providers prefer private health insurance, because the
enrollees use more health care and the review is not as
demanding as that by NHI.

The public share (health insurance and government-funded
health programs) of total health expenditure in Korea, about
57%, is still lower than other OECD countries (OECD, 2018).
OOP payments and private health insurance account for 36%
(19% for NHI copayment and 17% for uninsured services) and
7% of total health expenditure, respectively (NHI, 2017). About
one-third of payments for uninsured services is extra pay for
private wards and specialists with extra years of experience.
Therefore, about two-thirds of the 17%, in other words, about
10% of total health expenditures, are related to extra billing for
uninsured medical services (e.g., high-tech services such as
MRI, da Vinci robot surgery, etc.). Even though the government
has expanded the benefit coverage of health insurance,
providers paid by FFS have rapidly increased the use of new
services and technologies, which are not yet included in the
benefit package. As a result, financial protection and the public
share of health expenditure have been stagnant.
In theory, fee schedules can have some effect on the mix of

primary versus hospital-based care, but they are not very
effective at reducing the rapid increase in hospital-based care.
Even a very high coinsurance rate for outpatient care in
hospitals, along with higher fees, has not curbed the rapid
increase in the utilization of hospital care. Strengthening the
role of primary care physicians as a gatekeeper with capitation
has been discussed for a long time. There is little consensus on
a primary physician and gatekeeping system even in the Korean
Medical Association, however, because different specialties
have different interests. Specialists other than internal
medicine, pediatrics, etc., are against any reform of service
delivery based on primary care physicians and gatekeeping.
The lack of a continuum of care among different levels of
providers results in cost increase and low quality of care and
poses a serious challenge, especially in an era of rapid
population aging.
7
Key Lessons
Many middle-income countries (MICs) are experiencing an
increase in private providers. Because the majority of health
providers are private in Korea, the Korean experience of pricing
of health services can provide important policy lessons for
MICs. From the very beginning of NHI, Korea implemented a
strict price regulation with no balance billing, and providers
were not allowed to opt out of NHI. Since the merger of all
insurance funds to a single insurer system in 2000, a
specialized agency was introduced, which has sophisticated
systems of claim review and assessment based on state-of-the-
art ICT. However, a private sector-oriented health system, where
providers are paid by fee-for-service and price regulation does
not take volume into consideration, seems vulnerable to cost
inflation.

Although fees are tightly regulated, providers have strong
incentives to increase the volume and intensity of care, since
there is no macro-level spending cap in Korea. FFS has been a
major factor contributing to the rapid increase in health
expenditures in Korea, even when it has a sophisticated review
and assessment system. Monitoring and evaluating the
appropriateness of the quantity and type of services provided
under FFS is very costly. It is very expensive to run a claim
review and assessment system for thousands of services under
FFS payment. The guideline book for claim review is already
excessive, and there is never-ending controversy and tension
between providers and NHIS over the adequacy of the fee level
and review guidelines in Korea. The financial sustainability and
efficiency of Korea’s NHI will hinge on the capacity of NHI to
effectively use its purchasing power over providers and
implement payment systems such as capitation, DRG-based
payment, and a spending cap.
The dominance of the private sector in health care delivery is a

barrier to payment system reform. Health care providers are
willing to (and they did in the case of pharmaceutical reform in
2000) go on a strike against government policy that potentially
threatens their financial interests and clinical autonomy. About
90% of Korean hospitals are private, and many of them were
grown from physician clinics by entrepreneurial physicians. As
a result, the Korean Hospital Association and Korean Medical
Association are very strong allies against the government and
the insurer. For example, they strongly criticize and are against
payment system reforms, tight reviews and assessments, etc.
Private hospitals also use various incentive mechanisms for
their physicians, e.g., based on the profits or revenue they
generate, which can further aggravate the perverse incentives
for over-provision under FFS. In addition to technical capacity
in terms of costing, monitoring, and evaluation, the government
needs both the political will and a sophisticated strategy to
implement an efficient provider payment system and pricing of
services in the health sector.

Cashin C, Chi Y, Borowitz M, Smith P, Thompson S. (eds.) Paying
for Performance in Health Care: Implications for Health System
Performance and Accountability. Open University Press; 2014.
Health Insurance Review and Assessment (HIRA). On-site

Investigation Status. (https://www.hira.or.kr/dummy.
do?pgmid=HIRAA040037020000, Accessed 1 November
2018).
Health Insurance Review and Assessment Service (HIRA).

(http://www.hira.or.kr, Accessed 1 November 2018).
Health Insurance Review and Assessment Service (HIRA). The 10

years of History of Health Insurance Review and Assessment
Service. HIRA; 2010.
Health Insurance Review and Assessment Service (HIRA).

Comprehensive quality report of National Health Insurance
2016. HIRA; 2017.
References Jeon B, Kwon S. Effect of Private Health Insurance on Health
Care Utilization in a Universal Public Insurance System: A Case
of South Korea. Health Policy 2013;113:69-76.
Jeon B, Kwon S. Health and Long-term Care Systems in the

Republic of Korea: Policy Challenges and Lessons. Health
Systems and Reform 2017;3(3):214-223.
Kim H, Jung Y, Kwon S. Delivery of institutional long-term care

under two social insurances: Lessons from the Korean
experience. Health Policy 2015;119(10):1330-1337.
Kwon S. Health Care Financing Reform and the New Single

Payer System in Korea: Social Solidarity or Efficiency?
International Social Security Review 2003a;56(1):75-94.
Kwon S. Pharmaceutical Reform and Physician Strikes:

Separation of Drug Prescribing and Dispensing in Korea. Social
Science and Medicine 2003b;57(3): 529-538.
Kwon S. Payment System Reform for Health Care Providers in

Korea. Health Policy and Planning 2003c;18(1): 84-93.
Kwon S. Thirty Years of National Health Insurance in South

Korea: Lessons for Achieving Universal Health Care Coverage.
Health Policy and Planning 2009a;24(1): 63-71.
Kwon S. The Introduction of Long-term Care Insurance in South

Korea. Eurohealth 2009b;15(1):28-29.
Kwon S. Advancing Universal Health Coverage: What

Developing Countries Can Learn from the Korean Experience?
Universal Health Care Coverage Series No. 33; 2018.
Kwon S, Lee T, Kim C. Republic of Korea Health System Review.

Asia Pacific Observatory on Health Systems and Policies,
forthcoming; 2015.
Kwon S, You M, Oh I, Seo S. Evaluation of the Impact of the New

DRG Payment System on Hospital Performance. Report
Submitted to NHIS; 2013.

National Health Insurance Service (NHIS)-NHI Statistics. Various
Years.http://www.nhis.or.kr

(OECD). Improving Value for Money in Health by Paying for
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(OECD). OECD Health Data. 2018.

Development; 2019.

Case study
Thailand
Universal
Coverage Scheme
Viroj Tangcharoensathien*
Walaiporn Patcharanarumol*
Taweesri Greetong **
Waraporn Suwanwela**
Nantawan Kesthom**
Shaheda Viriyathorn*
Nattadhanai Rajatanavin*
Woranan Witthayapipopsakul*
* International Health Policy Program (IHPP)

**The National Health Security Office (NHSO)
The Kingdom of Thailand
219
Thailand Universal Coverage Scheme
Abbreviations 221
Glossary of terms 222
Abstract225
Background 227
Objective and scope 227
1 Budget proposal for USC 228
Source of financing for UCS 228

Policy objectives: use of public finance and
copayment policy 228
Closed end annual budget: cost containment
strategies 231
Contents Closed end annual budget: cost elimination
methodologies 232
Service utilization rate 232
Unit cost 232
Cost of prevention and health promotion 234
Institutional capacities 234
Stakeholder Involvements 235
2 Provider payment and purchasing of services 237
Overview of purchasing services 237

Paying for outpatient services 240
Paying for inpatient services 241
Paying for accident and emergency services 243
NHSO: an active monopsonistic purchaser 243
3 Implications for other countries 244
Fiscal sustainability 244

Providers’ revenue guarantee 247
Efficiency 247
Financial risk protection 247
Universality for health 248
4 Discussion, conclusions and challenges 249
Annexes 251
References 253

Abbreviation Term
A&E Accidents and Emergencies
ART Anti-retroviral therapy
CGD Comptroller General’s Department
CPI Consumer Price Index
CSMBS Civil Servant Medical Benefit Scheme
DHS District Health System
DRG Diagnosis-related group
EPI Expanded Programme on Immunization
GDP Gross Domestic Product
Abbreviations GNI Gross National Income
HWS Health Welfare Survey
HPV Human Papillomavirus Vaccines
IHPP International Health Policy Program
ILO International Labour Organization
MOPH Ministry of Public Health
NCDs Non-communicable Diseases
NHSA National Health Security Act
NHSO National Health Security Office
NHSB National Health Security Board
RW Relative Weight
SHI Social Health Insurance
SSO Social Security Office
UCS Universal Coverage Scheme
UHC Universal Health Coverage

Age-adjusted capitation: The capitation payment for
outpatient services has been adjusted for age composition of
the registered population in the catchment areas since 2005.
The adjustment is in favour of the young and old members due
to the higher use rate by these two groups. The age-specific
expenditure (product of utilization rate and unit cost per visit)
is the main parameter for adjustments.
Blend model: The blend model is the way public and private
providers are paid by NHSO and uses multiple methods that
have policy goals for improved access and cost containment in
mind. The main modes of the blend model are age-adjusted
capitation for outpatients, DRG and global budget for inpatient
care, fee schedule for specific high cost interventions outside
capitation and DRG systems, and disbursement of high cost
medicines and certain medical devices by NHSO. These fee
schedules also apply to the global budget.
Glossary of terms Catastrophic health expenditure: Catastrophic health

expenditure is defined as households spending on health more
than 10% or 25% of total household consumption.
Composite cost inflation: Cost inflation rate based on cost

structure and medical inflation.
Comprehensive set of benefits package: The benefits package,

which covers outpatient, inpatient, high cost care, prevention
and health promotion); all inclusive of medicines and medical
products in the National List of Essential Medicines
Consumer protection: The mechanism in the National Health

Security Office (NHSO) which provides various channels for the
consumer – the beneficiaries and all stakeholders including
service providers – to communicate their inquiries, needs,
problems, and obstacles in universal coverage scheme (UCS)
and service provisions. Its goal, regarding the National Health
Security Act 2002, is to promote awareness and understanding
about consumer rights, service entitlements and duties, ensure
that beneficiaries can access quality health services as needed,
protect beneficiary’s rights, and monitor quality service and
reduce conflicts between beneficiaries and providers. The
consumer voices are heard through hotline 1330, a twenty-
four-hour service, official letters, consumer services centre
within hospitals, consumer coordinating centres in communities
managed by civil society organizations, annual public hearings,
and other social media channels.
Contract model: The agreement between NHSO, as the UCS

management body, and public and private providers, who agree
to provide health services for UCS beneficiaries based on
contractual agreements, bind NHSO to provide funding support
and providers to offer quality services as mutually agreed. This
model is a part of the concept “purchaser – provider split” to
prevent conflicts of interest and selection bias.

Contractor primary health care networks: The provider
networks, which agree to provide health services for UCS
beneficiaries have to comply with the contract signed. For
public providers, all public facilities are required to be
providers under the UCS for primary healthcare and outpatient
services. A District Health System (DHS), which consists of a
district hospital and primary healthcare provider network
within the district, is the main contractor. For private providers,
only accredited private facilities can be enrolled into the
scheme. Both public and private providers act as a contracting
unit for primary healthcare (CUP) and will be paid in advance
with an age-adjusted capitation payment for outpatients and
prevention and health promotion services according to the
population in the catchment area.
Costing method: There are many methods for calculating the

unit cost of outpatient and inpatient services. This study refers
to two methods. One is a conventional costing method, which
applies a cost centre approach, where a simultaneous equation
is applied to allocate indirect costs from transient cost centres
to absorbing cost centres in order to estimate the unit cost for
outpatient and inpatient services. Another is the quick method,
which can be conducted much easier than conventional costing
methods, however, its results are less accurate.
Civil Servant Medical Benefit Scheme (CSMBS): Government

employees, parents, spouses and dependents below 20 years
old (6% of the total Thai population) are automatically covered
under CSMBS by a tax-financed non-contributory CSMBS as a
fringe benefit. This scheme is managed by the Comptroller
General Department of the Ministry of Finance.
Diagnosis related groups (DRG) under global budget: One

kind of payment method used for inpatient budgets. The total
of the relative weights is used to calculate the annual global
budget. The payment per DRG weight varies and depends on
the total number of adjusted relative weights in a year. The
financial risk is transferred from NHSO to healthcare providers
providing inpatient services.
Equalization of health workforce density: Measured by the

personnel per population ratio across provinces to stabilize
health personnel numbers in high density provinces and
deploy more health personnel to lower density provinces.
Diagnosis related group creep: Unjustified changes in hospital

inpatient data records with an intention to increase case-mix
indices or relative weight in order to get a higher amount of
reimbursement.
Full cost subsidy: The money paid to health care providers for
the full cost of production including salary, material and capital
depreciation. Balance billing is not allowed.
Means testing survey: The mechanism to review the economic

status of the poor in order to issue a healthcare entitlement of
free health services to low-income households.

Per capita budget: Health expenditure calculated on a per
capita basis. It is estimated based on the average utilization
rate of outpatients (visit per person per year) and inpatients
(admission per person per year) multiplied with the unit cost
per outpatient visit and unit cost per admission, respectively.
Point systems with global budget: This method is one type of

fee schedule under a global budget.
Project-based payment: One kind of payment method used in

the promotion and prevention budget. Examples include
payments for prevention and condom distribution. Usually, this
payment is managed centrally by NHSO.
Service utilization rate: The use rate from the household

survey in the Health and Welfare Survey conducted by the
National Statistical Office or a projection of the use rate to that
budget year if no such survey in that year was conducted.
Three public health insurance schemes: In Thailand, the three

public health insurance schemes are CSMBS, SHI, and UCS.
Typical provider network: In rural areas, a district health

system with a catchment population of 50 thousand people in
a district served by a district hospital (30-120 beds) and 10-15
health centres. In urban areas with no district hospital in the
municipality, the Ministry of Public Health provincial or regional
hospitals and health centres constitute the provider network
for UCS outpatient care. Some private hospitals and their
affiliated clinics also make up a provider network.
Universal Coverage Scheme (UCS): Thais who are not covered

by CSMBS or SHI, which is around 75% of the total population,
are covered by a tax-financed UCS, which provides citizens with
an entitlement to health as a health safety net. UCS is managed
by NHSO.

Thailand achieved universal health coverage in 2002, when the
whole population was covered by one of the three public
health insurance schemes: the Civil Servant Medical Benefit
Scheme (CSMBS), the Social Health Insurance (SHI) and the
Universal Coverage Scheme (UCS). While CSMBS and SHI are
employment-related coverage, UCS is an entitlement to health
care for Thai citizens. This means that unemployed SHI
members or dependents of CSMBS older than 20 years that had
lost their coverage are automatically covered by UCS. Evidence
has shown favourable outcomes in term of improved access
and financial risk protection with minimum prevalence of
catastrophic health spending and impoverishment. This study
reviews and assesses the budgeting and purchasing of services
by the National Health Security Office (NHSO), which manages
the publicly financed, non-contributory UCS.
The per capita UCS budget is estimated based on the unit cost
of a comprehensive benefits package (outpatient, inpatient,
Abstract high cost care, prevention and health promotion) and the
respective utilization rates. The annual UCS budget is a full cost
subsidy, as the unit cost covers labour, material and capital
depreciation cost, and no copayment. Balance billing is not
allowed and strictly monitored and sanctioned. The full cost
subsidy has justified the termination of supply-side financing
since the inception of UCS. Annual budget allocations to
government health facilities are curtailed except for major
capital outlays. NHSO and partner institutes have developed
skills in conducting conventional costing exercises and quick
methods for annual adjustments of unit costs and
strengthening data on utilization rates.
Because the UCS budget is finite for health services and is

expected to be fully consumed by its 48.787 million members,
NHSO is not allowed to overspend or keep reserves. Given this
situation, NHSO has to apply closed-end provider payment.
Age-adjusted capitation for outpatients is contracted to a
primary healthcare provider network that consists mostly of
Ministry of Public Health district health systems. Diagnosis
related groups (DRG) under global budget are applied to
purchase inpatient care, with a single rate of reimbursement
per adjusted relative weight. For high cost services such as
renal replacement therapy or antiretroviral treatment, NHSO
pays both cash and non-cash through the distribution of
dialysis and medicines. NHSO also exerts monopsonistic
purchasing power to negotiate the best possible price given the
assured quality of high-cost medicines and medical devices
even from a monopoly or oligopoly product. Cost savings from
these negotiations are additional resources to enable higher
coverage to UCS members.

The incoherence of policy and practice on price setting,
purchasing and regulation across the three public health
insurance schemes is the major challenge. This requires
political leadership to resolve inefficiencies in CSMBS, as it
applies fee-for-service for outpatient services and 27 bands of
cost weights for DRG payment without a global budget. The
cost weights are in favour of super-tertiary hospitals. The
expenditure per capita for CSMBS is four times higher than that
of UCS.

Background
Thailand achieved Universal Health Coverage (UHC) in 2002,
when the entire 65 million population was covered by one of
the three public health insurance schemes. Government
employees and dependents (6% of the total population) are
covered by a tax-financed non-contributory Civil Servant
Medical Benefit Scheme (CSMBS) as a fringe benefit managed
by the Comptroller General, Department of the Ministry of
Finance. Private sector employees (excluding dependents)
(19% of the total population) are covered by a payroll-tax
tripartite contributory Social Health Insurance (SHI) managed
by the Social Security Office. The remaining 75% of the
population are covered by a tax-financed Universal Coverage
Scheme (UCS) managed by the National Health Security Office
(NHSO) (IMF, 2000).
While insurance coverage by SHI links with employment status,

UCS provides citizens with the entitlement to health. This
means that, when SHI members retire or become unemployed
and are no longer covered by SHI, these populations will be
automatically transferred to UCS. Conversely, when UCS
members are employed, they will be covered by SHI. For
CSMBS, when the child dependents of government officials turn
20 years old, they are automatically transferred to UCS. This
seamless transition across insurance schemes ensures health
insurance entitlement to the whole Thai population.
Objective and scope

This study identifies the policy objectives of setting the
payment rate for different benefits packages. It describes and
comments on the procedural and technical dimensions of rate
setting and purchasing services from healthcare providers, and
whether these purchasing systems have achieved their stated
policy objectives.
The scope of this study is within UCS managed by the NHSO

and covers the process of setting the payment rate and
regulating purchasing of a) outpatient services, b) hospital
admissions, c) certain high cost interventions, which are paid
outside of outpatient and inpatient services, and d) prevention
and health promotion services.

1
Budget proposal for USC
Source of financing for UCS
UCS was a political manifesto during the general election in

January 2001. To deliver the political promise of achieving UCS
within a year after the election, it was not possible to collect
premiums from UCS members, who were mostly engaged in the
informal sector, due to their erratic and seasonal variations of
income. Thus, a contributory insurance scheme would not have
achieved UHC in a short timeframe to ensure continued
coverage. A political decision was made to finance UCS with
general tax revenues through annual budget negotiations and
allocation through the Budget Bill, given the fiscal capacities
during 2001-2002 (Mills et al., 2000); the economy had not yet
fully recovered from the 1997 Asian Economic Crisis, which
severely affected Thailand, and the country was still on an
International Monetary Fund (IMF) package providing US$17.2
billion bilateral and multilateral assistance to Thailand
(Tangcharoensathien, 2012). Overall, there was a need to
provide a health safety net for the population.
Policy objectives: use of public finance and copayment policy
Historically, CSMBS applied fee-for-service payments for a)

outpatient services by reimbursing outpatients’ bills directly to
patients, and b) inpatient services by reimbursing to hospitals.
Evidence shows that fee-for-service is the main cause of the
high level of expenditures per visit shouldered by CSMBS due
to an excessive use of branded medicines, which were
reimbursed at full cost plus 20-25% mark up (World Bank
Group, 2019). CSMBS, a non-contributory scheme with no
copayment, does not send any signal to patients to use health
resources efficiently. Hospitals have incentives to make higher
margins from using branded medicines. Although CSMBS has
applied Diagnosis Related Groups (DRG) without a global
budget ceiling to pay inpatient services since 2008, it
continues to pay outpatients based on fee-for-service. This
resulted in a per capita expenditure for CSMBS that was four
time higher than that of UCS. This higher expenditure is driven
by the excessive use of branded medicines by both outpatients
and inpatients, higher intensity of diagnosis, and higher
payment for inpatient services under the DRG systems, which
use 27 different cost weights in favour of teaching and super-
tertiary hospitals. Further investigations on these variations are
required.
In contrast, SHI since its inception in 1991 has adopted a

capitation contract model with public and private competitive
contractor hospitals (those having >100 beds and other
infrastructure and staff requirements). SHI members are
mandated to choose and register with their preferred
contractor hospitals annually. SHI members can re-register with

a new contractor hospital once a year (by March of each year) to
suit the changes of their workplace or residence. The capitation,
inclusive of outpatients and inpatients for a year, has proven
more effective in cost containment than the CSMBS fee-for-
service model, with a decent quality of care (World Bank Group,
2019). Capitation sends a positive signal to contractor hospitals
to use more generic medicines.
A simple model of SHI capitation since 1991 was developed

based on a price and quantity approach. As there was no
utilization rate data, we assumed a high estimate of three
outpatient visits per capita per year and 0.1 admission per
capita per year, while the unit costs of B 150 per outpatient
visit and B 3000 per admission came from a conventional
costing method in a number of hospitals. A conventional
costing method applying a cost centre approach is time and
resource consuming. In this case, there was no study in private
hospitals, so that the average unit costs of government
provincial hospitals were used. We used provincial hospitals of
more than 100 beds as SHI contracts hospitals.
The SHI capitation was estimated by the following simple

formula: (3 outpatient visits per SHI member per year x B 150)
+ (0.1 admissions per SHI member per year x B 3000) = B 750
per SHI member per year. A policy decision by the Social
Security Board approved to pay a per capita rate of B 700 to its
contractor hospitals for each SHI member registered with them
(World Bank Group, 2019). The capitation is adjusted annually
based on the utilization rate and unit cost of service from
changes in medical technologies or the medical price index.
However, there has been no capitation adjustment in SHI since
the use rate was lower than the formula in the few initial years.
Members of SHI are healthy workers in the private sector under
60 years old (retirement age), and there are no disabled
persons in the SHI member pool. The Social Security Office
monitors the use rate both for outpatients and inpatients for a
potential under-provision of services, although they are not as
competent as the NHSO in terms of auditing and quality
assurance. This capitation payment covers outpatient and
inpatient services. The exceptions are maternity care and child
delivery, which are paid as a lump sum per delivery, and dental
care, which is paid as a lump sum per visit and not more than
two visits per year. International Labour Organization (ILO)
experts advised the separation of payment for delivery and
dental care from capitation of SHI. Thai reformists when
introducing UCS did not follow this advice due to the
administrative complexities of keeping individual records. The
International Health Policy Program (IHPP) was not successful at
addressing SHI separation for the payment of dental care and
maternity.
Given the negative lessons from CSMBS on cost escalation and,

vice versa, positive lessons from SHI on cost containment and
greater efficiency, reformists in the Ministry of Public Health
(MOPH) who designed the UCS strategic purchasing had
proposed a contract model for UCS since its 2001 inception,

with a more advanced step beyond the SHI inclusive of
capitation. This means that UCS applies capitation for
outpatients and later adjusts for age composition through DRG
under a national global budget for the payment of inpatient
care. The two largest budget ceilings are for outpatients (based
on unit cost and utilization rate) and for inpatients (based on
unit cost and utilization rate), with a few small pots such as high
cost care for anti-retroviral treatment (ART) and renal
replacement therapy. Also, the economic context in 2001 (not
fully recovered from the 1997 Asian financial crisis) was not
favourable to the application of fee-for-service. The Gross
National Income (GNI) per capita was US$ 1990 (International
Labour Organization, 2002), and government revenue was
16.2% of GDP (Tangcharoensathien, 2001).
The explicit policy objectives of UCS are to a) gain efficiency

and cost containment through closed end payment and primary
care fund holder contractual arrangements and exertion of the
NHSO’s monopsonistic purchasing power, and b) improve
financial risk protection through expansion of the benefits
package and ensuring access. To achieve these policy
objectives, the NHSO applies different strategic purchasing
such as benefits package development, which deepens the
financial protection, and devises a blend of provider payment
methods to boost service provisions and improve access.
When the budget estimate for UCS is a full cost subsidy to all
providers for the agreed benefits packages, there is no need for
copayment by users. Hence, balance billing is forbidden and
made known to both providers and patients. In the case of
balance billing, the hospitals are legally enforced to return the
amount to patients. Although a copayment of B 30
(approximately US$ 1) per outpatient visit or per admission
with an exemption to the poor was introduced in 2002, it was
terminated in 2006 due to political reasons and also to protect
the borderline poor from copayment and facilitate improved
access. The revenue from copayment was small, around 1-2%
of the total UCS annual budget, while the administrative cost of
copayment collection and the exemption mechanism of the
poor (which must be reviewed every three years through means
testing surveys) was much larger. Unlike fee-for-service, the
closed end provider payment does not send any signal towards
supplier-induced demand; therefore, copayments to discourage
unnecessary service utilization by patients are not required,
since abuse by the providers is not expected. The monitoring of
balanced billing was managed through a consumer voice
hotline, 1330, which is a twenty-four-hour service provided by
the NHSO and effective sanction for demanding copayment.
The NHSO manages successfully so that the amount of balance
billing or copayment is returned to the patients. Full payment
by offering services outside the benefits package was
uncommon, as UCS benefits packages had covered almost all
cost-effective high cost interventions through regular updating
of the benefits package.

Since the full cost (including salary, material and capital
depreciation) of service is compensated by the NHSO to
government health facilities, the previous annual budget
allocation to pay for labour and operating costs was terminated
since the UCS inception in 2002. Depreciation costs are small
for the purpose of replacing small equipment, while budgets
for new capital such as infrastructure and purchases of major
medical devices are allocated by the MOPH through annual
budgeting processes. This ensures no duplication of parallel
payments to these government facilities and supports a clear
accountability framework between health care providers and
the three insurance funds. A full cost subsidy is also provided
to private health facilities on an equal footing with government
facilities. This supports a smooth UCS operation, as private
facilities are equally treated. The quality and standards of these
private facilities are assessed by the NHSO before the
contractual agreement.
Since the salary of government officials are protected by the

Salary Act, which is managed by their respective Departments
and Ministries, the NHSO has to defer the salary portion to
MOPH to manage salary payment. In other words, the NHSO
only manages the non-salary component of the UCS budget.
Thus, an inequity in the total budget allocation across provinces
emerges in favour of historically high-density locations of
health personnel (which consumes higher staff cost but an
equal portion of the non-staff budget compared with other
provinces). The NHSO cannot hire, fire, or re-allocate health
personnel. IHPP proposed an equalization of the health
workforce density (measured by personnel per population
ratio) across provinces through stabilizing high-density regions
and deploying more health personnel in lower density
provinces. This has been done with stable but slow progress the
last 15 years.
Closed end annual budget: cost containment strategies
When closed-end provider payment is applied, the closed-end

annual budget request is followed accordingly using the budget
per capita of UCS members. The per capita budget was
estimated based on the average per capita utilization
outpatient rate (visits per capita per year) and inpatient rate
(admissions per capita per year) multiplied by the unit cost per
visit and the unit cost per admission. The multiplication of the
per capita budget for outpatient and inpatient services by the
total number of UCS beneficiaries (48.787 million) is the total
resource required. The total has to be spent completely by
providers, as the total represents the real costs of services.
Therefore, no unspent funds for the NHSO carry over to the
next fiscal year. Changes in the burden of disease are reflected
by the utilization rate. Changes in medical technology and
treatment profiles are reflected in the unit cost. Both
parameters, either actual figures or projected figures when
actual data are not available, are used in the formulae for the
annual budget estimate.

In 2001, the reformists recognized that CSMBS and SHI
deliberately did not provide health promotion or prevention in
their benefits packages. The NHSO was then mandated to offer
and purchase these services for the whole Thai population.
Additional benefits beyond outpatient and inpatient services,
such as health promotion and disease prevention, and high cost
services outside outpatient and inpatient payment, also
applied a closed-end budgeting system.
Closed-end budgeting is powerful in cost containment. The

downside of under-service provisions is closely monitored by
the NHSO through audits and a 24-hour call line for consumer
protection and conflict resolution between providers and
patients. The context, in which the majority of provider
networks for UCS is non-profit, has facilitated the smooth
implementation of UCS.
Closed end annual budget: cost elimination methodologies
Service utilization rate
In the initial years (2001 to 2005), preferred service utilization

rates were obtained from household level surveys conducted
by the Health and Welfare Survey (HWS), National Statistical
Office, or projections for the budget year when no survey data
were available. The 2001 capitation budget was B 1202 (US$
37.6 at an exchange rate of B 32) and calculated by using the
use rate from the 1996 HWS, which was the only available data
in 2001, and the unit cost in 1999. The subsequent HWS data
was obtained in 2001, 2003-2007 and thereafter a biennial
survey in 2009, 2011, 2013, 2015 and 2017.
Subsequently, outpatient and inpatient use rates referred to

the routine administrative dataset developed by the NHSO
when the dataset becomes mature and reliable. See Annex 1
for technical details and Annex 2 for a graphical explanation on
how the first per capita budget (B 1202) was estimated.
The methods of estimating the capitation budget were

successfully peer reviewed by actuaries from the International
Labour Organization (Tangcharoensathien 2003) and published
in an international peer-reviewed journal (Simborg, 1981) and
Thai journal (NHSO Archives, 2018; St-Hilaire and Crépeau,
2000; Sriratanaban and Ngamkiatphaisan, 2003).
Unit cost
The unit cost for outpatient and inpatient services is a full cost
estimation based on a conventional costing method (cost
centre approach and simultaneous equation of indirect cost
allocation), which includes staff costs, all operating costs such
as medicines and diagnostics, and capital depreciation cost
(Ngamkiatphaisan, 2005). The unit cost for the estimate of B
1202 per capita budget was based on the cost weight
generated from conventional costs in less than 20 public
hospitals to allow for a quick costing method.

Because establishing and maintaining conventional costing is
not an easy undertaking, data from these 20 public hospitals
are the only available dataset. The hospitals are not
representative; three-quarters are district hospitals and the
remaining are provincial hospitals. None are private hospitals.
There is also some costing information from 50 health centres
for the estimate of per capita budget.
The cost weight, a ratio between unit cost per admission and
unit cost per visit from conventional costing, is applied to
estimate the unit cost using the “Quick Costing Method”
principle, as expressed in the following formula:
total annual expenditure

unit cost per outpatient visit =
total outpatient visits + (cost weight x total
admissions)
unit cost per admission = cost weight x unit cost per outpatient visit
The cost weight is 16 for district hospitals and 19 for provincial

and regional hospitals. There are no cost data from private
hospitals; thus, the cost weight of district hospitals is applied,
because a majority of private hospitals are smaller than 100
beds and have similar service profiles as district hospitals. This
assumption was approved by the sub-committee, where a
private hospital association representative is one of the
committee members. MOPH maintains an annual report on total
annual expenditure by items and throughputs by all 900 MOPH
hospitals. This forms a basis for regular updates of the unit cost
of outpatients and inpatients for the annual budget request.
These hospital financial reports are reliable, as they are
submitted to the Auditor General for review. The cost weights
(16 for district hospitals and 19 for provincial hospital) are
subject to adjustments from time to time when there are
updated unit costs from conventional costing studies. The cost
weights at district and provincial/regional hospitals are driven
by real data. MOPH maintains annual financial and throughput
reports by all hospitals (district, provincial, regional); these
reports are inputs for calculating cost weights jointly by the
NHSO and MOPH. The current figures of 16 and 19 are national
averages from around 800 districts and around 100 provincial/
regional hospitals countrywide. Later, the NHSO estimated the
unit cost of inpatients by cost per adjusted relative weight,
which involved dividing the annual operating expenditure for
inpatients from the financial reports of MOPH hospitals by the
sum of the adjusted relative weight.
When an average is used, providers having unit costs above the

average will face financial difficulty, and those who have their
unit costs below average will have financial gain. Special
additional adjustments are made for districts having higher unit
costs due to sparse population, such as mountainous or island
districts. This ensures adequate funding for operation.
Contractor provider networks keep the surplus from outpatient
capitation payments for use according to their respective rules
and regulations. All MOPH facilities transfer the NHSO budget
to a “hospital revenue” account, and the receipt and use of
“hospital revenue” are governed by MOPH financial regulations.
Cost of prevention and health promotion
In 2001, there was no evidence for the calculation of the health

promotion and prevention components in the initial per capita
budget of B 1202. Researchers assumed that 20% of the cost
of outpatient and inpatient care was used for health promotion
and prevention.
A few years later, there were studies on the cost of health

promotion and prevention benefits packages using activity-
based costing (Simborg, 1981; Seiber, 2007). Estimating the
cost of health promotion and prevention services is
complicated, with different interventions for different
populations with different use rates, such as immunization for
children under five years old for 11 antigens according to the
national Expanded Programme on Immunization (EPI)
guidelines [BCG, Hepatitis B, DTP, OPV, MMR, JE and HPV], family
planning for women and men in reproductive age groups, and
cervical cancer screening.
Similarly, the cost of interventions outside capitation such as

ART (introduced to the benefits package in 2006), renal
replacement therapy (introduced in 2009), secondary
prevention for diabetes mellitus and hypertension (pilot in
2009 and nation-wide in 2010), and medicines for psychotic
patients (pilot in 2010, nationwide in 2011-2012, and
transformed to community psychiatry in 2016) were estimated
based on the incidence and prevalence of specific conditions,
service provisions and unit costs of these services according to
protocol.
Institutional capacities
The capitation rate in 2002 was estimated by a small technical

team using use rates in 1996 and unit costs in 1999, with
several assumptions where data were not available.
Subsequently the capitation budgets for 2003-2005 were
estimated by a technical team under the sub-committee on
UCS financing chaired by a professor in economics. There were
more up-to-date use rates when the Health and Welfare Survey
conducted by National Statistical Office on an annual basis
between 2003 and 2007. A projection of unit costs using
composite cost inflation (based on cost structure and medical
inflation) was also applied when there was no primary data for
unit costs from either the conventional costing method or a
quick costing method (Figure 1). The capitation budgets of
2006 onward have been conducted by an NHSO technical
team, who initiated more complex formulae using more details.
NHSO has developed its internal capacities to estimate

capitation rate. In addition, the NHSO also worked with partners
such as IHPP and MOPH to update unit costs of outpatient and
inpatient services on an annual basis using a quick costing
method and to update the cost weights from a conventional
costing method conducted in certain hospitals.
Figure 1
Composite cost inflation per annum
Assumption Cost structure % growth of unit

cost for outpatient
% total cost and inpatient
Salary & wages Public personal 30.10% 6.00%
salary growth
Temporary Public personal 6.10% 6.00%

wages for salary growth
contract
workers
Other staff No growth 13.90% 0.00%
compensation
Drug & Average 5 years of 31.40% 0.50%

medical supply medical Consumer
Prices Index (CPI)
growth rate
Public utility Average 5 years of 2.30% 0.00%
electricity & water
supply CPI
Other material Average 5 years of 16.20% 6.40%
cost CPI (exclude
medical & elec. CPI)
Composite 3.36%
growth rate per
annum
Source: NHSO fund management manual, 2016.
Stakeholder Involvements
The annual budgetary process of UCS involves extensive

participation by stakeholders. The technical working group of
the sub-committee on the Financing of National Health Security
Board (NHSB) analyzes the unit cost, utilization rate, high cost
interventions and all other benefits packages as approved by
the NHSB, and also proposes a capitation budget. The budget is
scrutinized and reviewed by all relevant actors including the
Ministry of Finance, Bureau of Budget, technical experts, and
representatives from health care providers. This process is
transparent and involves evidence-based negotiation
processes. The final proposal is then approved by the NHSB, as
mandated by National Health Security Act (NHSA), Article 18(3),
before submission to the Cabinet for approval of budget size
and followed by the annual budget bill processes. Although the
Cabinet has the power to comment and adjust the budget size
in consultation with the Ministry of Finance, Bureau of Budget,
and National Economic and Social Development Board,
representatives from these agencies are members of the
technical working group and review the budget size with the
NHSO.

Because UCS is one of the national priorities set by the
government and UCS members are the main stakeholders, with
reference to NHSA, Article 29, “The Board shall submit a request
for the budget of annual expenditure to the Cabinet”. The NHSB
submits the per capita budget for Cabinet approval, after which
the Cabinet takes into account the proposed figures and the
annual fiscal policies, economic growth and expected
government revenue and tax.
The work of the NHSO including budgeting requires comments

through an annual public hearing from beneficiaries and health
care providers as mandated by NHSA, Articles 46 and 18(13)
(Figure 2).
Figure 2
Stakeholder participation in the UCS budget
Beneficiaries National Health The annual UCS The The

and Providers Budget proposal
Security Board Cabinet Parliament
[S.39]
(NHSB)
General opinion
[S.18(10) (13)] The draft of Suggestion and
annual UCS Recommendation
budget proposal [S.39]
Other
Financial management Standard and Quality Ministry of
Subcommittees
Subcommittees under Control Board Finance
under NHSB
NHSB
The Budget
Bureau
The draft of annual
Suggestion
UCS budget proposal
Academic and
Stakeholder
Develop the draft

of annual UCS
budget proposal
Source: Authors’ synthesis from National Health Security Act B.E. 2545
(A.D. 2002)

2
Provider payment and purchasing of
services
Overview of purchasing services
In 2016, the per capita budget approved by the Budget Bill was
B 3,344.17. This consisted of the core benefits package of
B 3,028.94 per capita (Item A in Figure 3) and specific
interventions of B 315.23 per capita (Item B in Figure 3).
The product of the per capita budget (B 3,344.17) and UCS

members (48.787 million) was approved as the total budget
(B 163,152 million). The budget was earmarked to different
sub-items A and B with specific provider payment methods as
described in the last column off Figure 3; all sub-items adhered
to the principle of a closed-end budget, which is fixed in a
given year. The blended payment methods are designed to
improve access and support financial risk protection, as
providers will not offer high cost services such as dialysis or
ART under capitation payment. Unlike outpatient and inpatient
services, special interventions are not homogeneously required
by the whole population. Therefore, there is a need for specific
payment outside capitation.
In Figure 3, the cost of outpatient services (item A1) are paid to

contractor networks based on age-adjusted capitation;
inpatient services (item A2) apply DRG under a global budget;
and prevention and health promotion services (Item A4, 11.9%
of total budget allocation) apply a blend of capitation, project
base and also a provision of vaccines due to their diverse
nature of benefits packages for different target populations.
Certain high cost interventions (such as stroke fast track,
diabetic retinopathy, heart surgery, and heart transplantation),
which are part of either outpatient capitation or inpatient DRG
payment and have poor access due to underservice by a
hospital, are managed centrally by the NHSO (Item A3, 9.1%)
using a point systems with a global budget (called a fee
schedule under a global budget). Rehabilitation (A5) and Thai
Traditional Medicines (A6) also apply point systems under a
global budget. Capital depreciation is allocated based on the
population size in the registration and guided by a provincial
plan to replenish medical equipment in order not to spread
small resources too thinly. The no fault compensation to
patients (A8) having adverse events (death and disability) from
clinical services is paid on a fee schedule approved by the
Standards and Quality Control Board.

Figure 3
Budget allocation to core benefits packages and specific
interventions and related sub-items for UCS, Fiscal Year 2016
Budget Distribution, Provider payment methods

%
Item A: Core benefits package B 3,028.94/capita

A1. Out-patient services 33 Capitation
A2. In-patient services 31.7 DRG with Global Budget
A3. Central reimbursed* 9.1 Point system with Global Budget
A4. Promotion & prevention 11.9 Capitation, project based, vaccines,

quality
A5. Rehabilitation 0.5 Point system with Global Budget
A6. Thai Traditional Medicines 0.3 Point system with Global Budget
A7. Capital depreciation 3.8 Capitation + provincial plan
A8. No fault compensation to patients 0.2 Fee schedule
Subtotal Item A 90.60%
Item B: Specific interventions B 315.23/capita

B1. HIV/AIDS 1.8 Medicines fee schedule, project
based
B2. Chronic Kidney Diseases 3.9 Peritoneal dialysis solution, fee
schedule, project based
B3. N
on-communicable diseases (NCDs) control 0.6 Fixed fee per patient
and prevention
B4. Hardship areas adjustments 0.9 Criteria set by the committee
B5. Compensation to MOPH personnel 1.8 Criteria set by the committee
B6. Long-term care, home-based services 0.4 Fixed fee per patient
Subtotal Item B 9.40%
Total Package A and B B 3,344.17/capita
Total budget 100.00%
Total budget approval B 163,152 million For 48.787 million UCS members
Source: NHSO fund management manual, 2016. Note:*Specific services

such as stroke fast track, diabetic retinopathy, heart surgery, and heart
transplant are managed by the NHSO centrally.
Specific interventions that boost financial protection have a

share of 9.4% (Item B, Figure 3) of total budget allocation.
These include HIV/AIDS, which is paid by a blend model of
distribution of antiretroviral medicines to providers with certain
fee schedules and project-based payment such as prevention
and condom distribution. Services for chronic kidney disease
patients are managed centrally by the NHSO through

negotiation of peritoneal dialysis solutions and distributions to
patients’ home using the national post office. Certain fees for
health care providers for home visits to prevent the most
common complication of peritonitis and in-kind provisions of
erythropoietin for healthcare facilities are also managed.
Non-communicable diseases (NCDs) control and prevention are
paid on a fixed fee per patient, which covers needs for annually
laboratory tests and additional incentives for achieving diabetic
control, as measured by an HbA1C level <7%. The cost of
medical products distributed to providers (such as vaccines in
the EPI program, erythropoietin for end stage renal diseases on
dialysis and antiretroviral medicines for people living with HIV/
AIDS) or patients (such as peritoneal dialysis solutions) are part
of the budget.
Whenever the specific interventions in Item B are approved by

the NHSB, it goes to the Cabinet for program and budget
approval. In the subsequent year, it will enter the regular
budgeting system through budget bill processes. This means
there are no “unfunded mandates” for the NHSO or health care
providers. All interventions and benefits packages are fully
funded with an adequate budget. Providers are liable to report
their services or patients provided for reimbursement, which is
managed centrally by the NHSO. This gives opportunities for
establishing several patient registries such as end stage renal
patients who are on hemo and peritoneal dialysis and waiting
for kidney transplant, and persons living with HIV/AIDS who are
on ART. These disease registries provide invaluable information
on treatment outcome and five-year survival rates compared
with CD4 activity at the entry to hemo and peritoneal dialysis.
Data on reimbursement are important for the subsequent year
budget proposal.
Items B4 and B5, which are hardship allowances for health

professional areas, are managed by a committee, while B6,
“home-based long-term care”, is paid on a fixed fee per patient.
All specific interventions under item B require a provider’s
intensive report with various variables to the NHSO for
disbursement, performance assessment and audit.
When the annual budget is approved, the NHSO produces

annual budget executive guidelines and holds a national
meeting with all provider networks to ensure the smooth
execution of the annual budget. Benefits packages in sub-items
A and B are “ring fenced” and cannot be used across items, as
they are the costs of demands for health services by all UCS
members. Any changes on budget size across items in Figure 3
will take place in the subsequent year based on reviews of the
utilization and cost of service provision of these benefits
packages.
It should be noted that when the NHSO transfers the UCS

budget for whatever purpose, e.g., outpatients, inpatients, etc.,
the budget becomes the revenue of public health facilities or
private hospitals if they are contractors. The management of
personnel, hiring and firing, monthly payroll and additional

incentives such as overtime services are managed by hospitals
in line with the relevant rules and regulations. The purchasing
of medicines, medical supplies and medical devices are also
managed by hospitals, except in cases of high cost medicines,
which are purchased nationally by the NHSO and then
delivered to hospitals or households, e.g., peritoneal solutions
through the post office. In some cases, prices of high cost
medicines are negotiated nationally by the NHSO and then
hospitals procure them based on the negotiated price.
Paying for outpatient services
After the UCS beneficiary database was fully developed and

reliable, the capitation payment for outpatient services was
adjusted for the age composition of the registered population
in the catchment areas in 2005. The adjustment is in favour of
young and old members due to the higher use rate by these
two groups. The age-specific expenditure (multiplications of
utilization rate and unit cost per visits) is the main parameter
for adjustments. Age-adjusted capitation in each province is
±10% of national average, while different contractor provider
networks within a province will receive the same age-adjusted
capitation rate. Age adjustment is conducted every three to
four years (Figure 4).
Figure 4
Age-adjusted cost index for outpatient care
Age group (years)
All age
<3 3 – 10 11-20 21 - 40 41 - 50 51 - 60 61 – 70 >70 groups
0.464 0.364 0.306 0.407 0.789 1.348 1.972 2.351 1
Source: NHSO fund management manual, 2016.
All UCS members have to register with a provider network

capable of providing a comprehensive set of outpatient and
prevention and health promotion services. A typical provider
network in rural areas is a district health system with a
catchment population of 50,000 people in a district served by
a district hospital (30-120 beds) and 10-15 health centres
(Tangcharoensathien et al., 2018). Urban areas have no district
hospital. Therefore, MOPH provincial or regional hospitals and
health centres are the provider network for UCS outpatient
care. Some private hospitals and their affiliated clinics are also
provider networks. Note that Thailand has developed a full
geographical coverage of district hospitals in all 800 districts
and health centers in all sub-districts (Tangcharoensathien et
al., 2018).
The total budget for outpatients is based on the capitation

budget for outpatients multiplied by the total registered
population and adjusted by age. Advanced payment of
capitation on a six-month basis supports a smooth provision of
services for health facilities under MOPH, but monthly for
non-MOPH health facilities. The same capitation rate is equally
paid to either public or private networks. Fair treatment
between public and private networks facilitates smooth start-
up of implementation. Private hospitals are familiar with the
SHI inclusive capitation system.
When a patient needs to be referred to a higher level of care,

contractor networks, as primary care fund holders, are liable to
pay not more than B 700 for an outpatient visit when referred
to MOPH hospitals, or the actual amounts as requested by
non-MOPH hospitals. A patient bypassing their registered
provider network is not covered by UCS and must fully pay the
user charge out-of-pocket. Services from traditional healers and
self-prescribed medicines are not covered by UCS. Contractor
provider networks of primary care are liable to submit
individual records of outpatient service statistics to the NHSO
for monitoring and audits.
To facilitate mobile UCS members who seek jobs outside their

domicile districts, the NHSO allows these members to re-
register to a new provider network convenient for their use
through electronic registration. In these cases, the NHSO
deducts the remaining capitation from the old to the new
registered provider network through real time electronic
management.
Paying for inpatient services
DRG with global budget is used for paying inpatient admission

of UCS members. It uses the following ratio: the budget
approval for inpatients for the whole year (as part of the total
capitation budget) to the total relative weight adjusted for
length of stay of DRG of all UCS patients admitted to hospitals
in a year. Relative weights are adjusted for length of stay for
patients less than 24 hours or one-third the average or beyond
the outlier trim points. When the global inpatient budget is
divided by the total relative weights in a year, the amount is the
compensation per relative weight to hospitals providing
respective admission services. The global budget for inpatient
care is fixed for the whole year.
The global budget safeguards against overspending such as

DRG creep due to the budget’s finite size. DRG creep is defined
as changes in hospital record-keeping practices that increase
case-mix indices and reimbursement (Limwattananon et al.,
2015; Limwattananon, Tangcharoensathien and Prakongsai,
2007). The reimbursement per relative weight depends on the
number in the denominator. While the numerator is fixed from
the beginning of the year, the denominator changes (because
of real changes in case mix or use rate such as flu epidemic or
DRG creep), such that its increase lowers the reimbursement
rate. The NHSO will introduce a stringent audit of inpatient
claims and on-site audits of medical records guided by outliers
or an incompatibility analysis. Monitoring by the NHSO neither
shows rapid increases in case-mix severity nor increases in
admission rates. Changes in the admission rate or unit cost are

adjusted for the following year to estimate the per capita
budget for inpatients. The NHSO deducts the future inpatient
reimbursement against the amount of over-claims by hospitals
from the audit report or transfers the amount of under-claims
by hospitals due to under- or mis-coding.
All public (district, provincial, teaching) and private hospitals

providing admission services are treated under the same
conditions of the global budget and DRG systems without
prejudice. The same relative weight and pay rate to all levels of
hospitals are applied, as the NHSO adheres with the principle
that DRG are iso-resource consumption. Appendectomies
provided by a teaching or a district hospital without
complications or co-morbidity are offered the same payment.
When inpatients are discharged, hospital managers are

required to submit electronically to the NHSO the discharge
summary, which contains essential parameters, in particular the
clinical diagnosis based on ICD10, co-morbidity and
complications, procedure coding using ICD 9CM, patient’s
length of stay, use of the intensive care unit and surgery and
discharge status. Upon correct verification by the NHSO of
these data, a DRG code with relative weight will be generated
and informed to the hospitals. At the end of the month, money
will be wire transferred to the hospital based on its total
monthly relative weight and the global budget that the NHSO
holds. The total inpatient budget has to be spent and disbursed
in full. The NHSO is not allowed to keep the balance as
reserves, because the origin of the budget estimate is a full
cost subsidy.
The NHSO has no deficit, because it disburses its entire budget

to relevant providers. Financial risks are transferred to the
providers, who are “commanders of health resources”, as they
know how to be efficient. The global budget and DRG systems
for inpatient services can result in a lower baht per total
relative weight adjusted for length of stay, equally shouldered
by all providers in a year if there are large increases in the total
national sum of total relative weight adjusted for length of stay
(such as through DRG creep or epidemics). A higher baht per
total relative weight adjusted for length of stay occurs if there
are large decreases. DRG-creep and false coding are rigorously
audited by the NHSO. The capitation budget for outpatient
services is allocated to provider networks. It can be lower than
the networks’ total spending in a year given a high utilization
rate (which can be uncontrollable, i.e., in the case of an
epidemic, and controllable, i.e., unnecessary repeated
appointments and visits) and high unit cost (which is
controllable through the use of generic medicines and the
National List of Essential Medicines). This strategic purchasing
empowers healthcare providers to be financially responsive
and cost conscious through an efficient use of resources. All
providers under UCS use generic drugs in the National List of
Essential Medicines. Unlike CSMBS, where providers have
incentives to use brand versions outside the National List of
Essential Medicines.

Despite universal coverage, there are backlogs of cataract
surgery, which results in long waiting lists. To improve access,
the NHSO, as a learning organization, has unbundled cataract
surgery from the DRG system and pays on a fee schedule in
order to boost surgery and reduce preventable blindness.
Almost all cataract surgeries are 100% day surgeries unless
there are (rarely) complications, which require admission.
Paying for accident and emergency services
To ensure that live saving interventions are promptly provided,

accident and emergency (A&E) cases (medical, surgical, or
accidents) can access any nearby hospital. For A&E cases
treated as outpatients by providers in the same province,
hospitals will be paid by the fund holder contractor network
where the patients are registered based on fee-for-service or a
negotiated rate. For A&E outpatient services provided by
facilities outside the domicile province, the NHSO manages the
payment based on what hospitals charge under a global budget
held by the NHSO. The charges will be converted into a point
system where one baht equals one point.
The NHSO pays the cost of ambulance services for the referral
of patients requiring emergency attention (not only A&E)
between hospitals. The cost of pre-hospital care and ambulance
services from the spot events to hospitals are paid by the
National Institute of Emergency Medicines through its network
of telecommunications and systematic commanding systems.
Certain local governments also subsidize ambulance services
(first responders only).
For A&E cases treated as inpatients, hospitals in the same

public health region will be paid under the DRG system within
the regional global budget ceiling. For A&E cases which are
treated as inpatients by hospitals outside the public health
region, the hospitals will also be paid by the DRG system, but
the NHSO guarantees a higher rate of B 9600 per adjusted
relative weight to ensure that emergency services are promptly
provided. Note that there are thirteen public health regions in
Thailand, consisting of 5-6 provinces and 5-8 million people
per region.
NHSO: an active monopsonistic purchaser
The NHSO, as a large purchaser for the whole Thai population,

exerts its monopsonistic purchasing power when negotiating
prices of certain medical products, in particular monopoly or
oligopoly markets with assured quality from both domestic and
international suppliers. These products are, for example,
cataract lenses, medical devices such as stents for coronary
arteries and certain medicines such as erythropoietin. Such
monopsonistic purchasing power has yielded significant cost
savings, which is the difference between market and negotiated
prices and actual volumes procured (Tangcharoensathien et. al,
2018) (Box 1).

3
Implications for other countries
The payment methods adopted by the NHSO for UCS are good
examples for other countries, especially in terms of budget
containment and health systems efficiency. Since Thailand is
not a rich country and UCS is solely financed by general taxes,
affordability and financial sustainability are key policy
concerns. Empirical evidence of impact from setting and
regulating payments for services in the Thailand UCS are fiscal
sustainability, covering the full cost of all health care providers,
improved efficiency, a high level of financial risk protection and
universal access to health services, which include medicines
and no copayment at the point of service. These can be
experiences to share in how setting payment methods in
Thailand reflects good outcomes.
Fiscal sustainability
Thailand UCS applies a closed-end budget – it cannot spend

beyond its annual budget ceiling. We strongly recommend
using a closed-end budget, as it ensures efficiency and fiscal
sustainability. The UCS budget has significantly increased in 17
years (Figure 5). This is a result of additional benefits packages,
especially high cost interventions, an increased utilization rate
and cost inflation. However, if compared to total government
budget, it has been quite stable, at 5.9% (Figure 6). In terms of
growth, although the annual UCS per capita budget has a higher
growth rate in percentage than GDP per capita, the two have
similarly increased (Figures 7 and 8).
Box 1. Improved access to cataract lens replacement
Between 1996 and 2010, cataract lens replacement was paid based on
DRG weights, with hospitals being compensated for the lens cost of B
4000. To solve the problem of the long waiting list, the private sector was
encouraged to provide lens replacement for a lump sum payment of B
7000 inclusive of lens cost during 1997-2000.
Since 2011, cataract lens replacement has been unbundled from DRG
systems and paid on a fee schedule of B 7000 and 9000 per case
(without and with complication, respectively) and a lens cost of B 700
and 2800 for hard and foldable lens, respectively. This innovation
boosted access to lens replacement, using an interrupted time series,
from 0.8 lens per 100 000 population in 2005-2006 to 64.9 per 100 000
population (p<0.01) in 2009-2013.
Source: Limwattanananon, 2017.

Figure 5
Per capita UCS budget, current price, 2003-2019, baht/capita
3,500
3,000
2,500
THB/Person
2,000
1,500
1,000
500
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
Source: NHSO, 2018.
Figure 6
Percent of UCS budget compared with total government
budget
4,000,000 8
3,500,000 7
UCS budget % of Total government budget, %

Government and UCS Budget, million baht
3,000,000 6
2,500,000 5
2,000,000 4
1,500,000 3
1,000,000 2
500,000 1
0 0
2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
Total government budget UCS Budget as % of Total government budget

UCS Budget (included salary)
Source: NHSO, 2018.

Figure 7
Percentage growth in GDP per capita compared with the
percentage growth in UCS per capita budget
20
15
10
% Growth
-5
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
% growth of UCS per capita budget

% growth of GDP per capita
Source: NHSO, 2018.
Figure 8
Growth of Annual GDP per capita and Annual UCS per capita
budget
4,000 250,000
200,000
3,000
UCS per capita budget (THB/person)
GDP per capita (THB/person)

150,000
2,000
100,000
1,000
50,000
0 0
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
UCS per capita budget (THB)

GDP per capita (THB)
Source: NHSO, 2018.

Providers’ revenue guarantee
Even though the Thai UCS has applied a strictly closed-end

budget and capitation budget basis, the payment method has
been flexibly designed to guarantee revenue to providers. For
outpatient services and health promotion and prevention, the
capitation budget is paid in advance based on the population
in the catchment area. For inpatient services and high cost care,
postpaid or retrospective payment has been adopted. These
payments are guaranteed based on the full cost of services
provided inclusive of salary, material and capital depreciation
costs. DRG with global budget has been applied for inpatient
services. Providers have to submit all discharge summary
parameters to compute the DRG weight and receive
reimbursement from the NHSO. At the beginning of the fiscal
year, the minimum guarantee of the payment base rate per
adjustment relative weight is announced, and it has been more
than 95% of actual payment. Moreover, and importantly from
the provider’s side, revenue from all insurance funds have more
flexible management than budget line items. These earnings
from insurance funds become hospital revenue when spending
is governed by MOPH rules and regulations. This was more
flexible than budget line items in the years prior to UCS and are
subject to external audits.
Efficiency
Health systems efficiency can be achieved through the use of

gate keeping for primary health care and outpatient care. This
applies an efficient allocation of resources according to need.
Primary care promotes better access, with less transport cost
and better continuity of care in particular the management of
chronic non-communicable diseases. In addition, within the
healthcare providers’ lens, the capitation payment method may
induce an under-provision of healthcare; but for the purchaser’s
side this can induce efficiency in budget management along
with a measurement to prevent side effects of per capita
payment such as monitoring, auditing and full cost subsidies of
outpatient services. Lastly, as a manager of UCS, the NHSO
exercises monopsonistic purchasing power to negotiate the
lowest possible price with assured quality, hence gaining
efficiency and significant cost savings for more service coverage.
Financial risk protection
Free from payment at the point of service can protect

households from financial hardship due to health care cost and
reduce barriers to health care utilization. Moreover, strict
prohibition of balance billing is another measure to protect
individual access to health care with no price barriers.
Monitoring, auditing and complaint management systems are in
place to monitor these events and introduce corrective
measures. This results in a high level of financial risk protection
in Thailand, as measured by the low prevalence of catastrophic
health expenditure and impoverishment due to health care

costs. Both indicators have significantly decreased over the
years (Figures 9 and 10).
Figure 9
Financial risk protection from healthcare costs: catastrophic
health expenditure using a threshold of more than 10% of
household consumption expenditure on health (left) and
household impoverishment (right)
Catastrophic health expenditure Impoverishment due to healthcare cost
5
% of household
1990 1993 1996 1999 2002 2005 2008 2011 2014 2017 1990 1993 1996 1999 2002 2005 2008 2011 2014 2017
Source: NHSO, 2018.
Universality for health
In Thailand, public health insurance coverage by SHI is linked to

employment status, while UCS provides citizens with an
entitlement to health. This means that when SHI members
retire or become unemployed and are no longer covered by
SHI, they will be automatically transferred to UCS. Conversely,
when UCS members are employed, they will be covered by SHI.
For CSMBS, when the child dependents of government officials
turn 20 years old, they are automatically transferred to UCS.
This seamless transition across insurance schemes ensures the
universality of health insurance entitlement for the whole Thai
population. Entitlement to health is guaranteed from birth, as
all 0.7 million newborns are registered with either UCS, or
CSMBS if their parents are government employees.

4
Discussion, conclusions and challenges
Compared with the Comptroller General’s Department (CGD),
who manages CSMBS, and Social Security Office (SSO), who
manages SHI, the NHSO is the most advanced purchasing
agency. It has the expertise and capacity to implement and
focuses all its efforts on purchasing health services. It has no
mandate to collect premiums from members, as UCS is fully
funded by general taxes through annual budget negotiations.
SHI is part of the comprehensive social security systems for
14.6 million private sector employees in 444 868
establishments (pension, unemployment, sickness, disability,
health and deaths compensations). SSO, with its workforce of
7223 staffs nation-wide, is also mandated to collect monthly
premiums as a percentage of payroll from its employees and
employers. It manages other benefits beyond health including
the Workmen Compensation Fund (for work related injuries,
sickness, disability and death compensations). CGD with its
limited capacities of less than 30 staff, manages CSMBS as part
of a comprehensive government employee’s benefit systems,
but cannot do strategic purchasing well.
There is no overall regulatory framework for price regulation in

healthcare by purchasing organizations. SSO calculates its
capitation rate and sets rules and regulations for provider
payment, but it has limited capacity to conduct rigorous audits
and discipline providers (in particular, for profit private
hospitals) for the interests of SHI members. All three public
health insurance schemes apply the National List of Essential
Medicines as a drug benefits package and DRG (current version
6.2) as a reference for payment with variations. CSMBS does not
apply a global budget, but has 27 bands of baht per relative
weight, while SSO pays B 15 000 per relative weight for
patients having relative weights higher than two. The NHSO
applies a strict global budget and adjusted relative weight.
These price settings and regulations by the NHSO have

achieved the stated objectives of cost containment, although
the capitation budget increased from B 1202 in 2002 to
B 3344.17 in 2016. This is mostly due to a) an expansion of
high cost benefits packages such as ART and renal replacement
therapy, b) an increased utilization rate of outpatient and
inpatient care, and c) cost inflation and use of more diagnostic
technologies such as CT scan for simple appendicitis.
Compared with CSMBS, which continues to pay outpatient care
by fee-for-service and inpatient care by DRG without a global
budget and different bands in favour of teaching and tertiary
care hospitals, UCS has four times lower expenditure per capita.
It has also achieved financial risk protection to UCS members.
UCS has reduced the probability of catastrophic health
expenditure, defined as households spending on health more
than 10% of their total household spending. There has been a
greater reduction of household out of pocket spending among

high-income households, providing a real safety net for all—
rich or poor (Limwattananon, Tangcharoensathien and
Prakongsai, 2011). Thus, UHC (including all three public health
insurance schemes) provides financial risk protection for the
whole population (Limwattanon, Tangcharoensathien and
Prakongsai, 2007; 2011). In contrast, the CGD and SSO neither
have the capacities nor policies to exert their monopsonistic
purchasing power.
Challenges lie with the fact that, despite the three insurance
schemes applying similar benefits packages, each pays
providers differently. For example, SHI pays inclusive
capitation, though it recently has gradually adopted DRG for
high cost inpatient services of relative weights more than two
while still paying capitation if inpatient relative weights are less
than two.
CSMBS, a tax funded scheme, does not have cost containment

in its policy goals despite using public resources. It continues
to use fee-for-service for outpatient care. For inpatient care,
CSMBS replaced fee-for-service with DRGs in 2009. The design
increased inequity across levels and types of hospitals. For
example, the DRG payment is based on fee-for-service claims
by hospitals, but combined these claims into 27 bands, which
range between B 4131 and B 28 343 per adjusted relative
weight. The average reimbursement in baht per adjusted
relative weight is B 10 629 to B 13 630 for teaching hospitals,
B 10 271 for regional hospitals, B 9346 and B 10 056 for
provincial hospitals, and B 5731 and B 6113 for small district
hospitals. This variation occurs despite the fact that these
hospitals provide similar outcomes for the same DRG group.
These rates are adjusted every one to two years. CSMBS has
overspent its allocated budget every year for the last two
decades, but it was compensated by the Government Central
Fund, which was earmarked for contingencies and national
emergencies and disasters.
An incoherence of policy and practice on price setting,

purchasing and regulation is the major challenge and requires
political leadership to resolve inefficiencies in CSMBS. There
are several rounds of failed reforms due to a lack of reform
capacity in the CGD and resistance from medical communities
who are in favour of fee-for-services.

Annex 1
Estimates of per capita budget: B 1,202 for
Fiscal Year 2002.
Row Parameters Unit National Technical notes

average
1 Reported illness last two weeks per capita per two weeks 0.1669 Data from HWS1996
2 Reported illness in a year per capita per year 4.34 row 1 * 26 (to blow up to 52 weeks/
year)
3 Use at institutional care Ratio 0.661 sum row 5 to 9
4 Number of institutional visit visits per capita per year 2.876 row 2 * row 3
5 Use at health centres Ratio 0.151
6 Use at district hospitals Ratio 0.129
7 Use at provincial and other public Ratio 0.155
hospitals
8 Use at private clinics Ratio 0.195
9 Use at private hospitals Ratio 0.031
10 Cost incurred at health centres baht per capita per year 39.4 row 2 * row 5 * B 60/visit
11 Cost incurred at district hospitals baht per capita per year 123.8 row 2 * row 6 * B 221/visit
12 Cost incurred at provincial hospitals baht per capita per year 186.9 row 2 * row 7 * B 278/visit
13 Cost incurred at private clinics baht per capita per year 187.2 row 2 * row 8 * B 221/visit
14 Cost incurred at private hospitals baht per capita per year 37 row 2 * row 9 * B 278/visit
15 Total OP cost incurred baht per capita per year 574 sum row 10 to 14
16 Admission Admission per capita per 0.066 data from HWS1996
year
17 Use at district hospitals Ratio 0.332 data from HWS1996
18 Use at provincial and other public Ratio 0.488 data from HWS1996
hospitals
19 Use at private hospitals Ratio 0.18 data from HWS1996
20 Cost incurred at District hospitals baht per capita per year 62.7 row 16 * row 17 * B 2857/admission
21 Cost incurred at provincial hospitals baht per capita per year 175.2 row 16 * row 18 * B 5424/admission
22 Cost incurred at private hospital baht per capita per year 64.7 row 16 * row 19 * B 5424/admission
23 Total inpatient service cost incurred baht per capita per year 303 sum row 20 to 22
24 Total cost for curative care per capita baht per capita per year 877 sum row 15 and 23
per year
25 Preventive and promotive packages baht per capita per year 175 row 24 * 20%
26 Capital cost, 10% of curative package baht per capita per year 93 (Row 24+28+29) * 10%
27 Total package including capital baht per capita per year 1,145 sum row 24 to 26
28 High cost care, adjusted from Social baht per capita per year 32 reference social security scheme
Health Insurance
29 Accident and emergency outside baht per capita per year 25 reference social security scheme
contract primary care
30 Total capitation (operating expenditure baht per capita per year 1,202 sum row 27 to 29
only, exclude capital investment)

Annex 2
How budget per capita, B 1,202, in 2002
was estimated
Capitation
1,202 Baht/capita/year in 2002
OP IP Promotion & Depreciation: High cost care A&E

prevention: 10% of OP, IP,
20% of OP+IP high cost, A&E
574 303 175 93.4 32 25
From formulate From formulate Reference to SHI

1990s FYI historical
expenditure

International Monetary Fund (IMF). Recovery from the Asian
Crisis and the Role of the IMF. IMF; 2000. (https://bit.
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International Labour Organization. Technical note on financing

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Confidential document; 2002.
Limwattananon S, Tangcharoensathien V, Prakongsai P.

Catastrophic and poverty impacts of health payments: results
from national household surveys in Thailand. Bull World Health
Organ 2007;85:600–6.
Limwattananon S, Tangcharoensathien V, Prakongsai P.

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Development; 2019.

Case study
The United States

of America
Luca Lorenzoni
Organisation for Economic Co-operation
and Development
Paris, France
255
The United States of America
Abstract 257
Overview 258
1 Medicare 262
Hospital acute inpatient services 265

Skilled nursing facilities services 266
Outpatient hospital services 267
Physician and other health professional
payment system 268
Ambulatory surgical centre 269
Managed care 269
Contents

Quality Payment Program
Medicare value-based purchasing
270
271
Bundled payments 272
2 Medicaid 276
Hospital acute inpatient services 277

Skilled nursing facilities services 279
Physician and other health professional
payment system 280
Outpatient hospital services 281
Managed care 283
3 Private health insurance 284
4 Reference pricing 287
5 Balance billing 288
6 Are hospitals cost shifting? 289
7 Maryland 290
References 294

In the United States of America, private health insurance plans’
prices are largely unregulated and agreed upon through
negotiations between plans and the providers with whom they
contract. Negotiated transaction prices are often unknown to
final consumers and the public as they are treated as
commercially sensitive. These prices can vary substantially for
similar services across providers and insurers and bear little
relation to the cost of production.
In contrast, Medicare and Medicaid – the two largest

government health insurance programs - regulate the rates that
providers receive. Under these rate-setting systems, the federal
or state government establishes how much providers are paid
for health care services. The rates reflect the costs that the
typical efficient provider is expected to incur. The annual
process for updating these prices is public and transparent.
A high fragmentation of the health insurance and financing

Abstract systems results in a large amount of resources devoted to
health insurance marketing and administration, and to billing
activities.
On January 2014, the state of Maryland implemented its

All-Payer Model for hospitals, which shifted the state’s hospital
payment structure from an all-payer hospital rate setting
system to an all-payer global hospital budget that encompasses
inpatient and outpatient hospital services.

Overview
The United States of America (US) health care system has
developed largely through the private sector and combines
high levels of funding with a uniquely low level of government
involvement. It can be thought of as multiple systems that
operate independently with little coordinated system-level
planning in comparison to other high-income countries
(figure 1). This fragmented system results — among other
things — in high administrative costs attributable to billing and
insurance-related activities (Fuchs, 2018; Tseng et al., 2018).
Hospital administrative overheads are far higher in the US than
in other high-spending countries (Himmelstein et al., 2014).
Private sector stakeholders play a stronger role in the US health

care system than in other high-income countries. The private
sector also led the development of the health insurance system
in the early 1930s, as the major federal government health
insurance programs, Medicare and Medicaid, were not
established until the mid-1960s.
After a lengthy national debate, Congress passed legislation in

1965 establishing the Medicare and Medicaid programs as Title
XVIII and Title XIX, respectively, of the Social Security Act. While
Medicare was established in response to the specific medical
care needs of the elderly, coverage was extended for disabled
persons and persons with kidney disease in 1973. On the other
hand, Medicaid was established in response to the widely-
perceived inadequacy of welfare medical care under public
assistance. Administrative responsibility for the Medicare and
Medicaid programs was assigned to the Department of Health,
Education, and Welfare — the forerunner of the current
Department of Health and Human Services. Until 1977, the
Social Security Administration (SSA) managed the Medicare
program, and the Social and Rehabilitation Service (SRS)
managed the Medicaid program. The responsibilities were then
transferred from SSA and SRS to the newly formed Health Care
Financing Administration (HCFA), renamed in 2001 as the
Centers for Medicare & Medicaid Services (CMS)1. CMS also
oversees the Children’s Health Insurance Program (CHIP) and
the Exchanges2.
1 CMS is an operating division within the Department of Health and Human Services (HHS).
HHS is the United States government’s principal agency for protecting the health of all
Americans and providing essential human services.
2 The Patient Protection and Affordable Care Act, signed into law in March 2010, made
broad changes to the way health insurance is provided and paid for in the United States.
In 2014, state and federally administered health insurance marketplaces (or Exchanges)
were established to provide additional access to private insurance coverage, with
income-based premium subsidies for low- and middle-income people. In addition, states
were given the option of participating in a federally subsidized expansion of Medicaid
eligibility.

Figure 1
Organization of the health care system in the United States
Privately insured
Federal government State government individuals
Department Others selected HHS Department of Health & Employer-

of Defense agencies: Human Services (HHS) sponsored
– Centers for disease
control and prevention
(CDC)
– National institutes of
Department health (NIH)
of Veterans – Agency for healthcare
Affairs research and quality
(AHRQ) Centers for Medicare Marketplaces
– Foods and drugs & Medicaid services
administration (FDA)
Veterans Indian
health health Medicare Medicaid Private
TriCare
administration services and CHIP insurance
Providers: hospitals, physicians, long-term care institutions, home health institutions,

pharmacies, public health, mental health institutions, dentists
Non-governmental scientific and

professional organisations (Health and
medicine division of the National
Provider regulatory organisations
academy of science, American medical
(Joint Commission, etc.)
association, etc.)
Hierarchical Overseeing
Contract Regulation
Source: Adapted from Rice et al., 2013.
In 2016, Medicare and Medicaid covered approximately 56 and

71 million people, respectively. Private health insurance
covered 196 million people, and 29 million people were
uninsured (Hartman et al., 2017). Total health care spending
reached US$ 3.3 trillion in 2016, and its share in the gross
domestic product was 17.9%. Hospital care accounted for 38%
of spending (US$ 1082 billion), and physician and clinical
services accounted for 23% (US$ 665 billion). Smaller shares
went to expenditures on retail prescription drugs (12%, or US$
329 billion), nursing care and continuing care retirement
facilities (6%, or US$ 163 billion), and home health care
services (3%, or US$ 92 billion).

Private health insurance accounted for 35.3% of health
spending, and Medicare and Medicaid accounted for 21.1%
and 17.8%, respectively. Smaller shares of spending were from
household out-of-pocket (11.1%); other third-party payers and
government public health activities (10.7%); and CHIP, Indian
health services3, Department of Defence4 and Department of
Veterans Affairs5 (4%).
Both private and public payers purchase health care services

from providers that are subject to regulations imposed by
federal, state and local governments, as well as by private
regulatory organizations. However, private and public payments
for health care services are determined through very different
mechanisms:
__ Private plan prices are largely unregulated (except in the
state of Maryland, see below) and agreed upon through
negotiations between insurance plans and providers with
whom they contract. Transaction prices are the result of
many discrete negotiations often unknown to final
consumers and to the public as they have been treated as
commercially sensitive. These prices can vary substantially
for similar services across providers and insurers6, may bear
little relation to the cost of providing services, and rise in
response to changing market conditions.
__ In contrast, Medicare and Medicaid – the two largest
government health insurance programs — regulate the rates
that providers receive. Under these rate-setting systems, the
federal or state government establishes how much providers
are paid for health care services. The rates reflect the costs
that a typical efficient provider is expected to incur. The
annual process for updating these prices is public and
transparent with prices being constrained by policy to
increase relatively slowly.
A description of the base for payment, the level of payment and

the process by which the price level is determined by the three
major insurers – Medicare, Medicaid and private plans – is
reported below. As to the base upon which prices are defined
and services paid for, large differences can be observed across
provider types and insurers (figure 2).
3 The Indian Health Service, an agency within the Department of Health and Human
Services, is responsible for providing federal health services to Native Americans and
Alaska Natives.
4 The Military Health System - the global health system of the Department of Defense
- operates a worldwide health care delivery system that includes care delivered in over
50 military hospitals and over 600 clinics, as well as a supporting network of private
sector providers offered under its health insurance system known as Tricare. This system
provides health services to approximately 9.6 million beneficiaries — active duty service
members, military retirees, their eligible family members and survivors.
5 The Veterans Health Administration (VHA) is the largest integrated health care system,
providing care at 1243 health care facilities, including 172 medical centres and 1062
outpatient sites of care of varying complexity (VHA outpatient clinics), serving 9 million
enrolled Veterans each year.
6 This approach is called “price discrimination” in economist jargon. It means that an
identical service is sold to different buyers at different prices.

Figure 2
Base upon which prices are defined and services paid
Provider type Medicare Medicaid Private plans
Office-based Fee-for-service Fee-for-service Fee-for-service

physicians
Outpatient Ambulatory Fee-for-service; Fee-for-service
hospital services payment ambulatory
classifications patient
classification
Inpatient hospital Medicare Diagnosis related Diagnosis
services severity groups, per diem related groups,
diagnosis related fee-for-service,
groups per diem
Skilled nursing Per diem Per diem
facilities (adjusted using
resource
utilization
groups)
Ambulatory Ambulatory
surgical centres payment
classifications
Source: author’s compilation.
Starting in the late 1960s and early 1970s, at least 30 states

implemented programs to either review or directly regulate
hospital rates and budgets (Anderson, 1991). Evidence is mixed
(Eibner et al., 2009); but some studies indicate that, if properly
structured, rate setting systems show better ability to meet the
goals of reduced cost growth and improved access than most
market-based systems (McDonough, 1997; Murray, 2009;
Murray and Berenson, 2015). Maryland was the first, most
stable and only remaining all-payer hospital rate setting
program. The main features of the Maryland price setting
system are described below.

1
Medicare
Medicare is a health insurance program for people age 65 or
older, people under age 65 with certain disabilities and people
of all ages with end-stage renal disease (permanent kidney
failure requiring dialysis or a kidney transplant).
Medicare has different parts that help cover specific services7:

__ Part A (Hospital Insurance): it helps cover inpatient care in
hospitals, including critical access hospitals, and skilled
nursing facilities (not custodial or long-term care). It also
helps cover hospice care and some home health care.
Beneficiaries must meet certain conditions to get these
benefits. Most people do not pay a premium for Part A
because they or their spouse have already paid for it
through their payroll taxes while working.
__ Part B (Medical Insurance): it helps cover doctor services and
outpatient care. It also covers some other medical services
that Part A does not cover, such as physical and occupational
therapist services, and some home health care. Part B helps
pay for these covered services and supplies when they are
medically necessary. Most people pay a monthly premium
for Part B.
__ Part D (Prescription Drug Coverage): it is available to
everyone with Medicare. To get Medicare prescription drug
coverage, people must join a plan approved by Medicare
and pay a monthly premium.
The goal of the Medicare payment policy is to obtain adequate

value for program expenditures, which means maintaining
beneficiary access to high-quality services while encouraging
efficient use of resources: “Anything less does not serve the
interests of the taxpayers and beneficiaries who finance
Medicare through their taxes and premiums” (Medicare
Payment Advisory Commission, 2018a).
In 2016, managed care8 was the largest Medicare spending

category (28%), followed by inpatient hospital services (21%),
prescription drugs provided under Part D9 (14%), services
reimbursed under the physician fee schedule (11%), outpatient
hospital services (7%) and skilled nursing facilities (4%).
Spending for inpatient hospital services was a smaller share of
total Medicare spending in 2016 than it was in 2007, falling from
29% percent to 21%, whereas spending on beneficiaries
enrolled in managed care plans grew from 19% to 28% over the
same period (Medicare Payment Advisory Commission, 2018b).
7 https://www.cms.gov/Medicare/Medicare-General-Information/MedicareGenInfo/index.html.
8 The Medicare Advantage program allows Medicare beneficiaries to receive their Medicare
benefits from private plans (managed care) rather than from the individual fee-for-service
programs.
9 In 2006, Medicare began a voluntary outpatient drug benefit known as Part D. Prescription
drug plans compete for enrollees on the basis of annual premiums, benefit structures,
specific drug therapies covered, pharmacy networks, and quality of services. Medicare
subsidizes premiums by about 75% and provides additional subsidies for beneficiaries who
have low levels of income and assets (Medicare Payment Advisory Commission, 2018b).

Health care facilities must demonstrate compliance with the
Medicare conditions of participation (providers), conditions for
coverage (suppliers) or conditions for certification (rural health
clinics) to be eligible to receive Medicare reimbursement.10-11
Health care facilities that are “provider entities”12 are allowed
to demonstrate this compliance through accreditation by a
CMS-approved accreditation program of a private, national
Accrediting Organization (AO)13. Accreditation on a voluntary
basis by a CMS-approved national AO is an alternative to being
subject to assessment of compliance by an applicable State
Survey Agency. AOs currently have CMS approval for eight
provider or supplier program types: hospital, psychiatric
hospital, critical access hospitals (CAH), home health agency
(HHA), hospice, ambulatory surgical centre (ASC), outpatient
physical therapy (OPT), and speech-language pathology
services and rural health clinics (RHC). Figure 3 below reports
the number of providers which received accreditation from an
AO (deemed) and by a state survey agency (non-deemed) in
Fiscal Year 2017.
Figure 3
Number of accredited providers by program type
Provider type Deemed (%) Non-deemed Total

(%)
Hospital 3460 (88) 481 (12) 3941
Psychiatric hospital 419 (85) 72 (15) 491
Critical Access Hospitals 418 (32) 895 (68) 1313
Home Health Agency 4276 (45) 5145 (55) 9421
Hospice 1868 (42) 2606 (58) 4474
Ambulatory Surgical Centres 1530 (28) 3982 (72) 5512
Outpatient physical therapy and 206 (10) 1905 (90) 2111

speech-language pathology
services
Rural health clinics 339 (8) 3812 (92) 4151
Total 12178 (40) 18436 (60) 30614
Source: Centers for Medicare and Medicaid Services, 2018. Note: Deemed
are those providers that received accreditation from an Accrediting
Organization. Non-deemed are those providers that received accreditation
by a state survey agency.
10 Those “conditions” refer to health and safety standards which are the foundation for
improving quality and protecting the health and safety of beneficiaries.
11 When services are furnished through institutions that must be certified for Medicare, the
institutional standards must be met for Medicaid as well. In general, the only types of
institutions participating solely in Medicaid are (unskilled) Nursing Facilities, Psychiatric
Residential Treatment Facilities and Intermediate Care Facilities for the Mentally
Retarded. Medicaid requires Nursing Facilities to meet virtually the same requirements
that Skilled Nursing Facilities participating in Medicare must meet. Facilities for the
Mentally Retarded must comply with special Medicaid standards.
12 “Provider entities” include providers of services, suppliers, facilities, clinics, agencies or
laboratories. Physicians, as well as nurses and many allied health professionals are
accredited by licensing boards in the state in which they practice. In addition to
state-level regulations, physicians are also regulated at the federal level by CMS criteria
for reimbursing providers.
13 The process of recognition of an AO by CMS is called “deeming”.

As of September 2016, there were nine national AOs with 21
approved Medicare accreditation programs, the largest being
The Joint Commission (figure 4) (Centers for Medicare and
Medicaid Services, 2018).
Figure 4
Approved Medicare accrediting organizations by type of care
Accrediting organization Hospital Psychiatric CAH HHA Hospice ASC OPT RHC
hospital
American Association for Accreditation of 174 206 194

Ambulatory Surgery Facilities
Accreditation Association for Ambulatory 767
Health Care
Accreditation Commission for Health Care 682 215
American Osteopathic Association/Healthcare 122 27 28

Facilities Accreditation Program
Community Health Accreditation Partner 1989 761
Centre for Improvement in Healthcare Quality 39
DNV GL-Healthcare 264 66
The Compliance Team 145
The Joint Commission 3035 419 325 1605 892 561
Total 3460 419 418 4276 1868 1530 206 339
Source: Centers for Medicare and Medicaid Services, 2018. Note: CAH:
critical access hospitals; HHA: home health agency; ASC: ambulatory
surgical centre; OPT: outpatient physical therapy, RHC: rural health clinics.
A description of the systems used by Medicare to pay for

inpatient hospital services, skilled nursing facilities services,
outpatient hospital services, physicians and other health
professionals, ASC services and managed care as well as a
description of quality payment incentive programs and bundled
payments is reported below. Of note, there is no spending
target or revenue cap at the provider level.

Hospital acute inpatient services
In 2016, 3238 hospitals provided almost 9.2 million discharges

under Medicare’s acute inpatient PPS, and 1345 CAH14
provided 309 000 discharges. The number of discharges
declined from 2015 to 2016 at both PPS hospitals and CAHs
(Medicare Payment Advisory Commission, 2018c).
The acute inpatient prospective payment system (IPPS) rates

are intended to cover the costs that reasonably efficient
providers would incur in furnishing high quality care.15 The IPPS
pays per discharge rates that begin with two national base
payment rates —covering operating and capital expenses
— which are then adjusted to account for two broad factors
that affect hospital costs of providing care: the patient’s
condition and related treatment strategy, and market conditions
in the location of the facility.
To account for patient needs, discharges are assigned based on

Medicare severity diagnosis related groups (MS–DRGs),16 in
other words, patient groups with similar clinical conditions that
require similar amounts of hospital resources. Each MS–DRG
has a relative weight that reflects the expected relative cost of
inpatient treatment for patients in that group. CMS recalibrates
the MS-DRG weights annually, without affecting overall
payments, based on standardized costs for all cases in each
MS-DRG.
To account for local market conditions, the payment rates for

MS–DRGs in each local market are determined by adjusting the
national base payment rates to reflect the relative input-price
level in the local market (wage index).
In addition to these two factors, the operating and capital

payment rates are increased for facilities that operate an
approved resident training program (based on hospital teaching
intensity)17 or that treat a disproportionate share of low-income
patients. Conversely, rates are reduced for certain transfer
cases, and outlier payments are added for cases that are
extraordinarily expensive. Figure 5 shows how an inpatient
payment is calculated.
14 Eligible hospitals must meet the following conditions to obtain CAH designation: have 25
or fewer acute care inpatient beds; be located more than 35 miles from another hospital;
maintain an annual average length of stay of 96 hours or less for acute care patients and
provide 24/7 emergency care services.
15 Equity in payment — which means that hospitals in similar situations get paid the same
price for the same service — is an underlying key principle of the IPPS design framework.
This also means that payment is not hospital specific.
16 The MS-DRGs system has 335 base DRGs, most of which are split into two or three
MS-DRGs based on the presence of either a comorbidity or complication or a major
comorbidity and complication.
17 Medicare pays separately for the direct costs of operating approved training programs for
residents.

Figure 5
Calculation of Medicare acute inpatient payment
Adjustment for geographical factors Adjustment for case mix
Operating Labour- related Non-labour Base rate

adjusted for MS-DRG Adjusted base
base payment portion + related portion x weight payment rate
rate geographical
factors
Hospital
wage MS-DRG
index
Adjustment for transfers
Full
Policy adjustments for hospitals that qualify length
Per case
of stay
payment
rate High-cost
Adjusted Indirect medical Disproportionate
outlier: payment
base + education + share payment Short LOS or = Payment ** + outlier
payment rate payment discharged
Per diem payment
to other
acute payment
rate If case is
hospitals or extraordinarily
post-acute costly
care *
Source: Adapted from Medicare Payment Advisory Commission, 2018e.

Note: * Transfer policy for cases discharged to post-acute care settings
applies for cases in 280 selected MS–DRGs. ** Additional payment made
for certain rural hospitals.
Skilled nursing facilities services
The total number of skilled nursing facilities (SNFs) has

increased moderately since 2009, and the mix of facilities
shifted from hospital-based to freestanding facilities. In 2017,
hospital-based facilities made up 5% of the 15 277 SNF
facilities. Medicare covered 2.3 million admissions with an
average 25.7 days covered per admission in 2016 (Medicare
Payment Advisory Commission, 2018c).
The Medicare SNFs benefit covers skilled nursing care,

rehabilitation services and other goods and services and pays
facilities a pre-determined daily rate for each day of care. The
prospective payment system rates are expected to cover all
operating and capital costs that efficient facilities would be
expected to incur in furnishing most SNF services, with certain
high-cost, low-probability ancillary services (such as magnetic
resonance imaging and radiation therapy) paid separately.
Daily payments to SNFs are determined by adjusting the base

payment rates for geographic differences in labour costs and
case mix. To adjust for labour cost differences, the labour-
related portion of the total daily rate is multiplied by the
hospital wage index in the SNF’s location. The daily base rates

are adjusted for case mix using a system known as resource
utilization groups (RUGs)18. Each RUG has associated nursing
and therapy weights that are applied to the base payment
rates.
Outpatient hospital services
Most hospitals provide outpatient services, including

outpatient surgery and emergency services. From 2007 to
2017, overall spending by Medicare and beneficiaries on
hospital outpatient services increased by 115% (Medicare
Payment Advisory Commission, 2018c).
The unit of payment under the outpatient prospective payment

system (OPPS) is the individual service as identified by
Healthcare Common Procedure Coding System codes. CMS
classifies services (and their codes) into ambulatory payment
classifications (APCs) based on clinical and cost similarity. All
services within an APC have the same relative weight. In
addition, drugs and biologicals whose costs exceed a threshold
(US$ 110 per day in 2017) have separate APCs. Furthermore,
CMS assigns some new services to “new technology” APCs
based only on similarity of resource use. CMS chose to
establish new technology APCs because some services were
too new to be represented in the data the agency used to
develop the initial payment rates for the OPPS19.
CMS reviews and revises the APCs and their relative weights
annually. The review considers changes in medical practice,
changes in technology, addition of new services, new cost data
and other relevant information. CMS consults with a panel of
outside experts as part of this review. CMS also annually
updates the conversion factor by the hospital market basket
index minus a multi-factor productivity adjustment.
18 A new case-mix classification system — the Patient-Driven Payment Model (PDPM) — will
be used as from October 1 2019. In the PDPM, there are five case-mix adjusted
components: Physical Therapy (PT), Occupational Therapy (OT), Speech-Language
Pathology (SLP), Non-Therapy Ancillary (NTA), and Nursing. Each resident is to be
classified into only one group for each of the five case-mix adjusted components. For
each of the case-mix adjusted components, there are a number of groups to which a
resident may be assigned: 16 PT groups, 16 OT groups, 12 SLP groups, six NTA groups and
25 nursing groups. As opposed to RUG, in which a resident’s classification into a single
group determines the case-mix indexes and per diem rates for all case-mix adjusted
components, PDPM classifies residents into a separate group for each of the case-mix
adjusted components, which each have their own associated case-mix indexes and per
diem rates. Additionally, PDPM applies variable per diem payment adjustments to three
components, PT, OT, and NTA, to account for changes in resource use over a stay. The
adjusted PT, OT, and NTA per diem rates are then added together with the unadjusted SLP
and nursing component rates and the non-case-mix component, as is done under RUGs, to
determine the full per diem rate for a given resident.
19 Services remain in these APCs for two to three years, while CMS collects the data
necessary to develop payment rates for them.

Physician and other health professional payment system
In 2016, total primary care services had grown to 148.8 million

units of service, an increase of about 10% compared with
2012. Primary care physicians accounted for most of these
services (73%). Primary care services billed by advanced
practice nurses20 grew from 15.3 to 28.2 million, or 19%, from
2012 to 2016. Primary care services billed by physician
assistants increased to 12.5 million, or 8% (from 7.5 million or
6% in 2012) (Medicare Payment Advisory Commission, 2018c).
Medicare reimburses specialist services (including office visits,

surgical procedures and a broad range of other diagnostic and
therapeutic services) according to a relative value scale that
ranks several reimbursable medical procedures based on
complexity and resources used.
Since 1992, the price of such services is calculated based on

Relative Value Units (RVUs) developed with extensive input
from the physician community, the United States Department
of Health and Human Services, and academics. Medicare’s
physician fee schedule determines payments for over 7500
physician services. Physician services, as classified by Current
Procedural Terminology (CPT) codes and Healthcare Common
Procedure Coding System (HCPCS) codes, range from those
requiring considerable amounts of physician time and effort,
clinical staff, and specialized equipment, to those that require
little if any physician time and minimal other resources.
For each service, Medicare determines RVUs for three types of

resources. First, physician work accounts for the time, technical
skill and effort, mental effort and judgment, and stress to
provide a service. Second, practice expenses account for the
non-physician clinical and non-clinical labour of the practice,
and for expenses for building space, equipment, and office
supplies. Third, professional liability insurance accounts for the
cost of malpractice insurance premiums21.
Adjustments are made to this ranking of services to transform

them into fees used for payment. The payment is determined
by multiplying the total value of those three factors by a
“conversion factor,” a dollar amount determined by CMS. The
amount is adjusted after applying a geographic adjustment
factor considering the varying costs of providing care based on
resources available at a location. The RVUs are updated
annually based on recommendations by the American Medical
Association and its Specialty Society RVS Update Committee.
CMS reviews the RVUs of new, revised, and some potentially
mis-valued services annually. HCPCS codes and the conversion
factor are also updated annually.
20 “Advanced practice nurses” include certified registered nurse anaesthetists,

anaesthesiologist assistants, nurse practitioners, certified nurse-midwives and clinical
nurse specialists.
21 Relative Value Units (RVUs), Health Policy Forum, January 12, 2015 http://www.nhpf.org/
library/ the-basics/Basics_RVUs_01-12-15.pdf.

Ambulatory surgical centre
ASCs are distinct entities that furnish ambulatory surgical

services not requiring an overnight stay. The most common ASC
procedures are cataract removal with lens insertion, upper
gastrointestinal endoscopy, colonoscopy, and nerve
procedures. The number of Medicare-certified ASCs grew at an
average annual rate greater than 1% from 2010 through 2016
to 5532 centres. 94% of those centres are for-profit facilities
located in urban areas (Medicare Payment Advisory
Commission, 2018c).
The unit of payment in the ASC payment system is the

individual surgical procedure. Each of the approximately 3500
procedures approved for payment in an ASC is classified into an
ambulatory payment classification (APC) group based on
clinical and cost similarity. There are several hundred APCs. All
services within an APC have the same payment rate. The ASC
system largely uses the same APCs as the OPPS. The relative
weights for most procedures in the ASC payment system are
based on the relative weights in the OPPS. These weights are
based on the geometric mean cost of the services in that
payment group according to outpatient hospital cost data. The
ASC system uses a conversion factor to translate the relative
weights into dollar amounts.
Managed care
The Medicare Advantage (MA) program gives Medicare

beneficiaries the option of receiving benefits from private plans
rather than from the traditional fee-for-service (FFS) Medicare
program. In 2017, the MA program included almost 3,300 plan
options offered by 185 organizations and enrolled about 19
million beneficiaries (32% of all Medicare beneficiaries).
Medicare pays plans a fixed rate per enrollee rather than FFS
Medicare’s fixed rate per service (Medicare Payment Advisory
Commission, 2018d). Payments are enrollee specific, based on a
plan’s payment rate and an enrollee’s risk score. Risk scores
account for differences in expected medical expenditures and
are based in part on diagnoses that providers code. Plans often
have flexibility in payment methods, including the ability to
negotiate with individual providers, care-management
techniques that fill potential gaps in care delivery (e.g., programs
focused on preventing avoidable hospital readmissions) and
robust information systems that can potentially provide timely
feedback to providers. Plans also can reward beneficiaries for
seeking care from more efficient providers and give
beneficiaries more predictable cost sharing, albeit one trade-off
is that plans typically restrict the choice of providers.

The plan types are:
__ HMOs and local preferred provider organizations (PPOs):
these plans have provider networks and, if they choose, can
use tools such as selective contracting and utilization
management to coordinate and manage care and control
service use. They can choose individual counties to serve
and can vary their premiums and benefits across counties.
These two plan types are classified as coordinated care
plans (CCPs).
__ Regional PPOs: these plans are required to offer a uniform
benefit package and premium across CMS designated
regions made up of one or more states. Regional PPOs have
more flexible provider network requirements than local
PPOs. Regional PPOs are also classified as CCPs.
__ Private FFS (PFFS) plans: these plans are not classified as
CCPs. They have to either locate in areas with fewer than
two network plans or operate as network-based PFFS plans.
Two additional plan classifications cut across plan types: special

needs plans (SNPs) and employer group plans. SNPs offer
benefit packages tailored to specific populations (those
beneficiaries who are dually eligible for Medicare and
Medicaid, are institutionalized, or have certain chronic
conditions). SNPs must be CCPs. Employer group plans are
available only to Medicare beneficiaries who are members of
employer or union groups that contract with those plans.
Plan bids partially determine the Medicare payments that plans

receive. The bid covers an average, or standard, beneficiary and
includes plan administrative cost and profit. CMS bases the
Medicare payment for a private plan on the relationship
between its bid and benchmark (a bidding target).
Quality Payment Program
The Quality Payment Program, established by the Medicare

Access and CHIP Reauthorization Act of 2015 (MACRA), is a
quality payment incentive program for physicians and other
eligible clinicians, which rewards value and outcomes in one of
two ways: Merit-based Incentive Payment System (MIPS) or
Advanced Alternative Payment Model (APM).
Under MIPS, clinicians are included if they are an eligible

clinician type and meet the low volume threshold, which is
based on allowed charges for covered professional services
under the Medicare Physician Fee Schedule and the number of
Medicare Part B patients who are covered for professional
services under the Medicare Physician Fee Schedule.
Performance is measured through the data clinicians report in
four areas: quality, improvement activities, promoting
interoperability and costs.22
22 See https://qpp.cms.gov/mips/overview

An APM is a payment approach that gives added incentive
payments to provide high-quality and cost-efficient care. APMs
can apply to a specific clinical condition, a care episode or a
population.23
Medicare Value-Based Purchasing
The Hospital Value-Based Purchasing (VBP) Program is a CMS

initiative that rewards acute-care hospitals with incentive
payments for the quality care provided to Medicare
beneficiaries. CMS rewards hospitals based on:
__ The quality of care provided to Medicare patients
__ How closely best clinical practices are followed
__ How well hospitals enhance patient experiences of care

during hospital stays
Under the Hospital VBP Program, Medicare makes incentive

payments to hospitals based on their performance on each
measure compared with that of other hospitals during a
baseline period or their performance improvement on each
measure compared with their performance during the baseline
period.
CMS bases hospital performance on an approved set of

measures and dimensions grouped into four quality domains:
safety, clinical care, efficiency and cost reduction, and person
and community engagement. CMS assesses each hospital’s
total performance by comparing its achievement and
improvement scores for each applicable Hospital VBP measure.
Hospital VBP payment adjustments are applied to the base
operating Medicare Severity DRG payment amount for each
discharge occurring in the applicable fiscal year on a per-claim
basis. The Hospital VBP Program is funded by reducing
hospitals’ base operating MS-DRG payments by 2%.
The Hospital Readmissions Reduction Program (HRRP) supports

the VBP program by reducing payments to hospitals with excess
readmissions. CMS uses excess readmission ratios (ERR) to
measure performance for six conditions/procedures: acute
myocardial infarction; chronic obstructive pulmonary disease;
heart failure; pneumonia; coronary artery bypass graft surgery
and elective primary total hip and/or total knee arthroplasty.
CMS calculates ERRs for Medicare FFS beneficiaries admitted

for inpatient care at an applicable hospital, with a principal
discharge diagnosis of one of the six conditions or procedures
listed above. The measures assess all-cause unplanned
readmissions that occur within 30 days of discharge from the
initial admission. The measures count patients who are
readmitted to the same hospital, or another acute care hospital,
for any reason, that is regardless of the principal diagnosis.
23 See https://qpp.cms.gov/apms/overview

CMS calculates a payment adjustment factor for all applicable
hospitals. The payment adjustment factor determines the
percent the hospital’s payment is reduced. In FY 2019, the
maximum reduction is 3%. CMS applies the adjustment factor
to all base operating DRG payments for discharges in the
program year, regardless of the condition.
Beginning in FY 2019, CMS uses a stratified methodology to

calculate hospital payment adjustment factors. The stratified
methodology has the following steps:
__ Hospitals are assigned to one of five groups based on a
hospital’s dual proportion. The groups are called peer
groups. The dual proportion is the proportion of Medicare
FFS and managed care stays where a patient was dually
eligible for Medicare and full-benefit Medicaid.
__ Median ERR is calculated for each measure and peer group.
This peer group median ERR is the threshold CMS uses to
assess hospital performance relative to other hospitals
within the same peer group. Hospitals whose ERR is greater
than the peer group median are considered to have excess
readmissions.
__ CMS assesses hospital performance for each measure for
which the hospital has at least 25 discharges for that
procedure or condition. If a hospital has excess readmissions
on a measure, that measure enters a formula called the
“payment adjustment factor formula”. The formula used to
determine the payment adjustment factor (P) is the
following:
NMMPayment(dx) Ú max {(ERR(dx) – Median peer

group ERR(dx)), 0}
{
P=1-min 0.03, ∑ All payments
}
where “dx” is any one of the six conditions/procedures,

“payments” are base DRG payments and “ERR” is a hospital’s
performance on that measure.
__ The payment adjustment factor formula includes a neutrality
modifier (“NM”) that ensures that the stratified methodology
meets requirements around maintaining the budget
neutrality of the program.
__ The payment adjustment factor formula calculates the size
of the payment reduction. CMS caps the payment reduction
at 3%, thereby setting a minimum payment adjustment
factor of 0.97.
Bundled payments
The CMS Innovation Center has launched a new voluntary

episode payment model, the Bundled Payments for Care
Improvement Advanced (BPCI Advanced) for 32 Clinical
Episodes. This model holds clinicians and provider
organizations accountable for quality and costs of care across a

defined episode comprising either a hospitalization or
procedure and 90 subsequent days. The first cohort of
participants has started participation in this model on October
2018, and the initiative will run through the end of 2023.
BPCI-Advanced is defined by following key characteristics:

__ Voluntary model
__ A single retrospective bundled payment and risk track for

Clinical Episodes, which begins on the first day of the
triggering inpatient stay or outpatient procedure and extend
through the 90-day period starting on the day of discharge
from the inpatient stay or the completion of outpatient
procedure
__ Twenty-Nine Inpatient Clinical Episodes and three
Outpatient Clinical Episodes24
__ Payment is tied to performance on quality measures
__ Preliminary target prices are provided in advance
BPCI Advanced aims to encourage clinicians to redesign care

delivery by adopting best practices, reducing variation from
standards of care and providing a clinically appropriate level of
services for patients throughout a clinical episode. It operates
under a total-cost-of-care concept, in which the total Medicare
FFS spending on all items and services furnished to a BPCI
Advanced Beneficiary during the Clinical Episode, including
outlier payments, will be part of the Clinical Episode
expenditures for purposes of the Target Price and reconciliation
calculations (unless specifically excluded).
Acute Care Hospitals (ACHs) and Physician Group Practices

(PGPs) can participate as a Non-Convener Participant (NCP),
whereas eligible entities that are Medicare-enrolled providers
or suppliers, eligible entities that are not enrolled in Medicare,
ACHs and PGPs can participate as Convener Participant (CP). A
CP is a type of participant that brings together multiple
downstream entities, referred to as “Episode Initiators” (EI). A
CP facilitates coordination among its EIs and bears and
apportions financial risk under the model. A NCP is a participant
that is an EI and does not bear risk on behalf of multiple
downstream EIs.
24 The 29 Inpatient Clinical Episodes are the following: disorders of the liver excluding
malignancy, cirrhosis, alcoholic hepatitis; acute myocardial infarction; back & neck except
spinal fusion; cardiac arrhythmia; cardiac defibrillator; cardiac valve; cellulitis; cervical
spinal fusion; COPD, bronchitis, asthma; combined anterior posterior spinal fusion;
congestive heart failure; coronary artery bypass graft; double joint replacement of the
lower extremity; fractures of the femur and hip or pelvis; gastrointestinal haemorrhage;
gastrointestinal obstruction; hip & femur procedures except major joint; lower extremity/
humerus procedure except hip, foot, femur; major bowel procedure; major joint
replacement of the lower extremity; major joint replacement of the upper extremity;
pacemaker; percutaneous coronary intervention; renal failure; sepsis; simple pneumonia
and respiratory infections; spinal fusion (non-cervical); stroke; and urinary tract infection.
The Outpatient Clinical Episodes are the following: percutaneous coronary intervention;
cardiac defibrillator; and back & neck except spinal fusion.

CMS has selected seven quality measures for the BPCI
Advanced model. Two of them, All-Cause Hospital Readmission
Measure and Advance Care Plan, are required for all Clinical
Episodes. The other five quality measures below only apply to
select Clinical Episodes:
__ Perioperative Care: Selection of Prophylactic Antibiotic, First
or Second-Generation Cephalosporin
__ Hospital-Level Risk-Standardized Complication Rate
following Elective Primary Total Hip Arthroplasty and/or
Total Knee Arthroplasty
__ Hospital 30-Day, All-Cause, Risk-Standardized Mortality Rate
following Coronary Artery Bypass Graft Surgery
__ Excess Days in Acute Care after Hospitalization for Acute
Myocardial Infarction
__ CMS Patient Safety Indicators
BPCI Advanced involves Medicare FFS payments with

retrospective reconciliation based on comparing all actual
Medicare FFS expenditures for a Clinical Episode for which the
participant has committed to be held accountable to the final
Target Price for that Clinical Episode. This results in a positive or
a negative reconciliation amount. All positive and negative
reconciliation amounts will be netted across all Clinical
Episodes attributed to an EI, resulting in a positive or negative
total reconciliation amount. This total reconciliation amount for
an EI is then adjusted based on quality performance, resulting
in the adjusted positive or negative total reconciliation amount,
respectively.
For an EI that is a NCP, the adjusted positive total reconciliation

amount is the Net Payment Reconciliation Amount (NPRA),
which CMS will pay to the participant. If instead this calculation
results in an adjusted negative total reconciliation amount, this
amount is the repayment amount which must be paid by the
participant to CMS.
For CPs, all adjusted positive total reconciliation amounts are

netted against all the adjusted negative total reconciliation
amounts for the participant’s EIs to calculate either a NPRA or a
Repayment Amount.
To determine the EI-specific Benchmark Price for an ACH, CMS

will use risk adjustment models to account for the following
contributors to variation in the standardized spending amounts
for the applicable Clinical Episode:
__ Patient case-mix
__ Patterns of spending relative to the ACH’s peer group over

time
__ Historical Medicare FFS expenditures efficiency in resource
use specific to the ACH’s Baseline Period

CMS uses an alternative method to determine the PGP’s
Benchmark Price. Specifically, since physician affiliation to a
PGP changes over time, discrepancies often occur between the
pool of Clinical Episodes in the Baseline Period and the pool of
Clinical Episodes in the Performance Period. Consequently,
BPCI Advanced will base the PGP’s Benchmark Price on the
Benchmark Price for the ACH where the Anchor Stay or Anchor
Procedure occurs. CMS will adjust this ACH-specific Benchmark
Price to calculate a PGP-specific Benchmark Price that accounts
for the PGP’s level of efficiency in the past and the PGP’s
patient case mix, each relative to the ACH.
The Target Price (TP) = Benchmark Price (BP) * (1 - CMS

discount). Preliminary Target Prices will be provided
prospectively before each applicant finalizes its participation
agreement with CMS and prior to selection of Clinical Episodes.
EIs will receive a preliminary Target Price, determined
prospectively based upon the historical patient case-mix. A
final Target Price will be set retrospectively at the time of
reconciliation by replacing the historic Patient Case Mix
Adjustment with the realized value in the Performance Period,
which will be transparent and specific to the participant’s
beneficiaries.
If aggregate Medicare FFS expenditures for items and services

included in the Clinical Episode are less than the final Target
Price (the Target Price updated to account for actual patient
case-mix) for that Clinical Episode, then this results in a Positive
Reconciliation Amount. If aggregate Medicare FFS payments for
items and services included in the Clinical Episode exceed the
final Target Price, then this results in a Negative Reconciliation
Amount.
Reconciliation payments, both to participants from CMS and

from participants to CMS, are capped at ±20% of the volume-
weighted sum of the final Target Prices across all Clinical
Episodes netted to the level of the EI within the Performance
Period.
Early enrolment data report 1547 participants, 715 (46%)

physician group practices and 832 (54%) hospitals (Navathe,
Huang, and Liao, 2018). On average, participants enrolled in
eight clinical episodes each. As proportions of all selected
episodes, major joint replacement of the lower extremity
(53%), congestive heart failure (45%), and sepsis (44%) were
the most commonly selected inpatient episodes. The least
commonly selected inpatient episodes were double joint
replacement of the lower extremity (11%) and combined
anterior posterior spinal fusion (11%).

2
Medicaid
All states, the District of Columbia, and the US territories have
Medicaid programs designed to provide health coverage for
low-income people. Although the federal government
establishes certain parameters for all states to follow, each
state administers their Medicaid program differently, resulting
in variations in Medicaid coverage across the country.
Beginning in 2014, the Affordable Care Act provides states the
authority to expand Medicaid eligibility to individuals under
age 65 in families with incomes below 133% of the Federal
Poverty Level25 and standardizes the rules for determining
eligibility and providing benefits through Medicaid, CHIP and
the health insurance Marketplace.
The foundational statutory provision that governs payment for

all Medicaid-covered services identifies several fundamental
aims for Medicaid payment policy:
__ Assure that payments promote efficiency, quality and
economy
__ Avoid payment for unnecessary care
__ Promote access within geographic areas equal to the general

population
There is little federal regulation addressing these payment

principles, and states have considerable flexibility in the design
of policies to achieve these objectives.
Medicaid uses a variety of payment approaches for different

types of providers and for different kinds of services. These
include:
__ FFS payments with payment for each service determined
based on a fee schedule, relative value scale, percent of
charges, or another basis
__ Per day, per visit, or per encounter payments, which include
all services rendered during the relevant period
__ Per episode or bundled payments, which include services
associated with a specific procedure or diagnosis, usually
over more than one day, and which can be narrow (e.g., only
inpatient services) or broad (e.g., inpatient, outpatient, and
ancillary services)
__ Capitation, premium, or global payments that provide an
individual with coverage for a defined set of benefits
(whether they are used or not) for a specific time (generally
one month)
25 Federal poverty levels are a measure of income issued every year by the Department of
Health and Human Services (HHS). They are used to determine eligibility for certain
programs and benefits, including savings on Marketplace health insurance, and Medicaid
and CHIP coverage.

__ Supplemental or incentive payments not directly related to
a service, but generally to a provider characteristic (e.g.,
serves a disproportionate share of uninsured patients,
located in a rural area) or a desired outcome (e.g., achieves
certain utilization or spending targets, performs well on
quality measures)
In the absence of detailed administrative rules, legal challenges

(mainly by providers) have been used to determine the criteria
by which these principles should be applied.26
On 4 January 2016, CMS implemented new regulations that

create a standardized, transparent process for states to follow
prior to implementing Medicaid provider payment rate changes
in the provider payment structure for services provided on a
FFS basis. States are now required to consider input from
providers, beneficiaries, and other stakeholders when
evaluating the potential impacts of rate changes. In addition,
states need to analyse the effect that rate changes may have on
beneficiary access to care and then monitor the effects for at
least three years after the changes are effective.
In 2015, hospital care was the Medicaid largest spending

category (33.9%), followed by nursing care facilities and
continuing care retirement communities (16.9%) and
physicians and clinical services (12.8%) (Medicaid and CHIP
Payment and Access Commission, 2017a).
A description of the systems used by Medicaid to pay for

inpatient hospital services, skilled nursing facilities services,
outpatient hospital services, physicians and other health
professionals and managed care is reported below. As each
state is subject to a balanced budget, they frequently alter their
tariff schedules as financial conditions warrant.
Hospital acute inpatient services
States have selected, and CMS approved, a wide range of

payment methods for inpatient hospital services, including:
__ Diagnosis-related groups (DRGs): most states have adopted
payment methods based on DRGs, a classification system
adopted by Medicare in 1983. Under this method, hospitals
are paid a fixed amount per discharge, with outlier payments
for especially costly cases.
__ Per diem: some states pay hospitals for the number of days
that a patient is in the hospital. Under this method, every
procedure has the same base rate, which is multiplied by the
total number of days during the stay to determine the total
payment.
__ Cost-based: some states pay for inpatient services based on
each individual hospital’s reported costs. This approach is
less common than DRGs or per diem-based payment. Many
26 In January 2015, the U.S. Supreme Court heard arguments in the case of Armstrong v.
Exceptional Child Care, Inc. and determined that only CMS has the authority to decide
whether Medicaid rates are sufficient and that the private parties may not bring suit.

states use cost-based reimbursement for certain types of
hospitals, such as small hospitals (such as CAHs) and
government-owned hospitals.
As of March 2018, 37 states used DRGs27 and eight established

per diem rates for inpatient hospital services. Five states used
some other method, such as a per stay payment or cost-based
reimbursement (Medicaid and CHIP Payment and Access
Commission, 2018a). For each of these payment methods, a
state establishes a base payment. For DRG payments, states
typically establish either a base rate specific to each hospital, a
state-wide base rate, or a rate based on hospital peer groups.
For per diem and cost-based payment methods, base payments
are determined using hospitals reported costs.
States adjust hospitals’ base payments according to a variety of

factors. These include:
__ Outlier (48 states): payments are adjusted to account for
cases that are extraordinarily costly.
__ Location (18 states): payments are adjusted for different
geographic areas, generally to reflect significant underlying
differences in the cost to provide care in rural versus urban
areas.
__ Hospital type: some states adjust the base payment or use a
different payment method entirely for certain hospitals. For
example, many states have separate payment policies for
small hospitals, CAHs, teaching and academic medical
centres, government-owned hospitals and children’s
hospitals.
All states have implemented non-payment polices for provider

preventable conditions, including health care-acquired
conditions such as foreign object retained after surgery and
stage III and IV pressure ulcers, and other provider-preventable
conditions such as surgical or other invasive procedure
performed on the wrong body part. Thirty-two states made
incentive payments to hospitals for reducing readmission rates.
States can supplement low FFS base payments by using upper

payment limit (UPL) 28, disproportionate share hospital (DHS)29
or uncompensated care pool payments to pay for Medicaid
shortfall, which is the difference between a hospital’s Medicaid
payments and its cost to provide services to Medicaid-enrolled
patients (Medicaid and CHIP Payment and Access Commission,
2018b).
27 Some states use the All-patient refined (APR), others the Medicare severity (MS) and a few
the All-patient (AP) DRG classification system.
28 UPL payments are lump-sum payments that are intended to fill in the difference between
FFS base payments and the amount that Medicare would have paid for the same service.
29 Medicaid DSH payments are statutorily required payments to hospitals that serve a high
share of Medicaid and low-income patients.

Skilled nursing facilities services
State Medicaid programs typically pay nursing facilities a daily

rate. State programs generally establish nursing facility payment
rates through a cost-based or price-based methodology. In a few
cases, states use a combination of the two.
__ Cost-based: rates are established based on each nursing
facility’s reported costs. Typically, each facility’s costs are
divided by the number of days a patient is in the facility to
determine a per diem (daily) amount. Facilities are then paid
their actual costs per day up to a predetermined ceiling.
__ Price-based: rates are established based on the costs of a
group of facilities. All facilities in a group are paid the same
base rate or price per day.
As of October 2014, 30 states used cost-based methods and 12

states established prices for nursing facilities. Nine states used
a combination of these approaches (Medicaid and CHIP
Payment and Access Commission, 2014).
States typically adjust base nursing facility rates according to a

variety of factors which include:
__ Acuity or case-mix (40 states): rates are adjusted to account
for the acuity (level of need) of nursing facility residents. The
most common source of information on resident acuity is
known as the Minimum Data Set, which is also used to
determine Medicare nursing facility payment.
__ High-need patients (39 states): rates are adjusted to account
for residents with particularly high needs such as ventilator
dependence or traumatic brain injury.
__ Peer groups (29 states): rates are determined based on peer
groups of facilities of similar size and in the same
geographic area.
States may also make supplemental payments or incentive-

based payments to nursing facilities:
__ Supplemental payments (20 states): these are typically
lump-sum payments that are not directly associated with an
individual nursing facility service. Such payments are often
made to public facilities.
__ Incentive payments: 23 states made incentive payments
based on measures of quality of care. Also, 23 states made
payments based on efficiency, typically to reward providers
for keeping costs below a specified amount.

Physician and other health professional payment system
State Medicaid programs, like Medicare and commercial payers,

typically pay physicians and other clinicians using a fee
schedule that establishes base payment rates for every covered
service. State Medicaid programs that pay physicians on a
direct, FFS service basis generally use one of three methods for
establishing base payment rates (fee schedules):
__ The resource-based relative value scale (RBRVS): this system,
initially developed for the Medicare program, assigns a
relative value to every physician procedure based on the
complexity of the procedure, practice expense and
malpractice expense. The relative value is multiplied by a
fixed conversion factor to determine the amount of
payment. State Medicaid programs can use the relative
value units and conversion factors established by Medicare
or apply their own conversion factors and then update or
change the factors when appropriate.
__ Percentage of Medicare: this system adopts the Medicare fee
schedule, which is based on RBRVS, but pays Medicaid
providers a fixed percentage of the Medicare amounts. The
Medicaid fee schedule in a state would then be updated
automatically whenever Medicare adjusts its physician
payment amounts. The amount Medicaid pays is typically
less than 100% of the Medicare amount.
__ State-specific factors: states can develop their own
physician fee schedules, typically determined based on
market value or an internal process. States may develop fee
schedules when there is no Medicare or commercial
equivalent or when an alternate payment methodology is
necessary for programmatic reasons (e.g., to encourage
provider participation in certain geographic areas).
As of November 2016, 23 states used the RBRVS, 14 states paid

physicians a percentage of the Medicare fee schedule and 11
states had a state-developed fee schedule for physician
services (Medicaid and CHIP Payment and Access Commission,
2017b).
States may adjust base physician payment rates according to a

variety of factors which include:
__ Site of service (30 states): payment rates are adjusted to
account for the service site (e.g., physician’s office or in an
institutional facility).
__ Patient age (25 states): separate fee schedules for adults
and children are developed, particularly for physician
services for which there is no adult equivalent (e.g., neonatal
critical care) or where the paediatric protocols for an office
visit are significantly different from adult protocols.
__ Provider type (15 states): separate fee schedules for primary
care physicians, mid-level professionals (e.g., nurse
practitioners, physician assistants, or nurse midwives), and

specialists are developed. A state may pay mid-level
practitioners a percentage of the physician fee schedule or
pay specialists an additional amount for certain services.
As of November 2016, every state made some type of

adjustment to the base physician fee schedule. The most
common adjustments were for advanced practitioners (provider
type) and site of service.
States may also make incentive or add-on payments to

physicians. Common add-on payments include:
__ Academic health centre (26 states): additional payments are
made for professionals practicing in an academic health
centre to account for the higher average acuity of their
patients.
__ Primary care case management (22 states): primary care
case management programs, in which enrollees are assigned
to a primary care provider who receives a small additional
payment each month to assume responsibility for
coordinating the enrollee’s care and assure access.
__ Health home (17 states): an incentive or add-on payment for
Medicaid physicians practicing in a designated health home
is offered.
__ Quality or pay-for-performance (eight states): an incentive or
pay-for-performance payment is offered if a physician meets
certain quality benchmarks, such as a reduction in
emergency department use or compliance with diabetes
treatment protocols.
In most cases, physician payment is triggered when the provider

submits a claim indicating that a service has been provided.
Each claim contains a record of the services provided and these
services are reported using billing codes. Physician services are
commonly reported using CPT codes that are developed and
maintained by the American Medical Association.
Outpatient hospital services
State Medicaid programs generally use one of four approaches

to pay for hospital outpatient services:
__ Fee schedule: a fee schedule is a state’s complete list of
services and the corresponding payment amounts, which are
typically determined based on market value, an internal
process, or as a percentage of the Medicare rate. States
often have accommodations for services without an
established fee.
__ Cost-based reimbursement: states pay a percentage of
hospital costs, typically as reported in a hospital’s Medicare
cost report. These costs have a maximum allowable
reimbursement rate as well as other state-specific limits.
__ APC groups: the APC system, used by Medicare, bundles
individual services into one of 833 APCs based on clinical

and cost similarity. All services within an APC have the same
payment rate. A single visit may have multiple APCs and
multiple separate payments.
__ Enhanced ambulatory patient groups (EAPGs): EAPGs bundle
ancillary and other services commonly provided in the same
medical visit; payment is based on the complexity of a
patient’s illness.
As of November 2015, 18 states used a bundled payment

approach, such as APC or EAPG, 16 used a cost-based system
and 13 states used a fee schedule (Medicaid and CHIP Payment
and Access Commission, 2016).
States may adjust outpatient payment rates according to a

variety of factors. These include but are not limited to:
__ Hospital type: some states adjust the base payment or use a
different payment method entirely for certain hospitals. For
example, 29 states have separate payment policies for small
hospitals and critical access hospitals. Less commonly, states
establish separate payment policies for teaching hospitals
(16 states), government-owned hospitals (11 states),
children’s hospitals (nine states) and psychiatric facilities
(eight states).
__ Location (six states): payments are adjusted for services
provided in specific geographic areas, to reflect significant
underlying differences in the cost to provide care in rural
versus urban areas.
__ Exempt services: other services, such as clinical laboratory
services and partial hospitalizations, are excluded from the
outpatient payment methodologies in most states. These
services are usually paid for using a different method, such
as a cost-based reimbursement.
Forty-five states require prior authorization for certain services

before approving payment. The most common services
requiring prior authorization are various forms of rehabilitation;
physical, occupational, and speech therapies; mental health
and certain psychiatric services, and certain diagnostic imaging
or radiology services.
States may also provide incentive or add-on payments for

outpatient hospital services in addition to the base payment.
States commonly provide add-on payments to the following
hospital types:
__ Government owned: just over 20 percent of US hospitals in
2011 were state or local government owned or operated
(Medicaid and CHIP Payment and Access Commission, 2016).
About a third of states provide supplemental payments to
these hospitals for outpatient services.
__ Safety net (nine states): supplemental payments to safety-
net hospitals, which provide a significant amount of care to
vulnerable populations, are made.

__ Academic health centre (13 states): additional payments are
made for services provided in an academic health centre to
account for higher patient acuity.
__ Quality incentives (six states): incentive payments as part of
initiatives to improve the quality of health care or to reward
hospital efficiency are made.
Managed care
In 2014, almost 60 percent of all Medicaid beneficiaries were

enrolled in a comprehensive managed care plan. States have
incorporated managed care into their Medicaid programs for a
number of reasons. Managed care provides states with some
control and predictability over future costs. Compared with fee
for service, managed care can allow for greater accountability
for outcomes and can better support systematic efforts to
measure, report and monitor performance, access and quality.
In addition, managed care programs may provide an
opportunity for improved care management and care
coordination.
Use of managed care varies widely by states, both in the

arrangements used and the populations served. Medicaid
programs use three main types of managed care delivery
systems (Medicaid and CHIP Payment and Access Commission,
2018c):
__ Comprehensive risk-based managed care. In such
arrangements, states contract with managed care plans to
cover all or most Medicaid-covered services for their
Medicaid enrollees. Plans are paid a capitation rate, a fixed
dollar amount per member per month, to cover a defined set
of services. The plans are at financial risk if spending on
benefits and administration exceeds payments; conversely,
they are permitted to retain any portion of payments not
expended for covered services and other contractually
required activities.
__ Primary care case management (PCCM). In a PCCM program,
enrollees have a designated primary care provider who is
paid a monthly case management fee to assume
responsibility for managing and coordinating their basic
medical care. Individual providers are not at financial risk in
these arrangements and continue to be paid on a FFS basis.
Several states have enhanced their PCCM programs with
targeted care monitoring and chronic illness management to
specific enrollees with high levels of need, and by
incorporating performance and quality measures and
financial incentives for providers.
__ Limited-benefit plans. Most states contract with limited-
benefit plans to manage specific benefits or to provide
services for a particular subpopulation, such as providing
inpatient mental health or combined mental health and
substance abuse inpatient benefits, non-emergency
transportation, oral health or disease management.

States use a variety of methods to set rates for risk-based
managed care plans, but all must pay within an actuarially
sound range. Many use an administrative process in which a
specific rate is set by the state. Others use a competitive
bidding or negotiation process. States may also use hybrid
approaches, such as setting a range of rates and then asking
plans to bid competitively within that range.
At least 24 states use measures of health status to risk adjust

their rates, rather than relying on demographic factors alone.
Such techniques are meant to adjust rates to better reflect a
plan’s mix of enrollees and their expected care needs and
related expenditures.
3
Private health insurance
States are the primary regulators of private health plans. Each
state requires insurance issuers to be licensed to sell health
plans in the state, and each state has a unique set of
requirements that apply to state-licensed issuers and the plans
they offer. State insurance laws have sought to keep insurance
companies financially solvent, protect against fraud, ensure
that consumers receive the benefits promised under their
insurance policies and promote the spreading of health risks
(Corlette et al., 2017). State regulation of insurance is grounded
in laws enacted by each state, and as a result can vary
significantly. State Departments of Insurance (DoI) are the
primary entities that work directly with insurers to ensure
compliance with federal and state standard. The range of
regulatory and oversight tools provided via state laws includes
in most cases licensing (insurance companies are required to
apply for a “certificate of authority”), rate review (DoI have the
authority to review premium rates before they are
implemented), policy review (DoI review and approve insurers’
policy forms before they can be sold), network adequacy,
marketing practices and market oversight.
The federal government also regulates state-licensed issuers

and the plans they offer. Federal requirements establish a
federal floor with respect to access to coverage (e.g., prohibition
from basing applicant eligibility on health status-related
factors), premiums (e.g., a tobacco user can be charged up to
1.5 times the premium charged to a non-tobacco user), benefits
(as an example, minimum hospital stay after childbirth), cost
sharing (e.g., limits on annual out-of-pocket spending) and
consumer protection (e.g., the percentage of premium revenue
spent on medical claims). However, federal law does not
prevent a plan from establishing varying reimbursement rates
for providers based on quality or performance measures
(Fernandez, Forsberg and Rosso, 2018).

Private sector health care prices are largely unregulated (except
in the state of Maryland, see below) and agreed upon through
negotiations between insurance plans and the providers with
whom they contract. Negotiated transaction prices are often
unknown to final consumers and to the public30 as they have
been treated as commercially sensitive (“Chaos behind a veil of
secrecy” in Uwe Reinhardt’s words (2006)). These prices can
vary substantially for similar services across providers and
insurers (Clemens, Gottlieb and Molná, 2017). On average,
commercial prices are about 50% higher than average hospital
costs and are often far more than 50% above Medicare
payment rates (Cooper et al., 2019; Medicare Payment Advisory
Commission, 2018a; Selden et al., 2015). Prices also vary
substantially across regions, across hospitals within regions and
even within hospitals (Cooper et al., 2019). At the state level,
Massachusetts, New York, Rhode Island, Vermont, and New
Hampshire have all published reports on the causes and extent
of provider price variation within their borders. All reports
conclude or assume that high prices are correlated with a
provider’s position within the health care market, which the
reports define in terms of size, competitive position and/or
brand. Although these studies were designed differently and
use slightly different methodologies, the results are informative.
In Massachusetts, “the highest-priced hospitals were
consistently paid 2.5 to 3.4 times more than the lowest-priced
hospitals for the same set of services” (The Commonwealth of
Massachusetts, 2017). The New York report (New York State
Health Foundation, 2016) concludes that, depending on the
region, in 2014 the highest-priced hospitals were paid blended
prices 150% to 270% more than the lowest-priced hospitals.
The Rhode Island report (Xerox, 2012) determines that in 2010,
its highest-paid hospital received rates that were 210% more
for inpatient care and 73% more for outpatient care. The
Vermont report (University of Vermont College of Medicine,
University of Massachusetts Medical School, and Wakely
Consulting Group 2014) finds that in 2012 its highest-paid
hospital was paid 180% more for inpatient care. Finally, the
New Hampshire report (London et al., 2012) finds that in 2009
its highest-paid hospital was paid 217% more.
Insurers and providers negotiate how much providers are paid

for services. Like any negotiation, provider payments reflect the
parties’ respective bargaining positions. For example, if an
insurer covers a large percentage of the patient population, it
can steer a large amount of business to the “in-network”
providers with which it contracts. Providers may agree to accept
relatively lower rates from the insurer to access this patient
volume and capture this source of revenue. On the other hand, if
a provider has a good reputation or strong brand name, offers
specialty services, or is the largest or only provider in the area, it
may have the leverage to demand higher rate from insurers and
have greater increases in prices over time (Baker et al., 2014).
30 The federal government adopted the requirement for hospitals — as of 1 January 2019
— to post list prices for all their services to promote “transparency” in health care in the
belief that health markets would work better if consumers had more information.

Providers’ market power and negotiating leverage are derived
from several complex and mutually reinforcing factors,
including reputation, location, and unique service offerings.
Some hospitals and physicians can demand higher prices based
on a reputation for quality, regardless of whether that
reputation is correlated with objective measures of higher
quality. Others benefit from their prominence as well-known,
research-oriented, academic health centres. Insurers often
believe that, without these so-called must-have providers, their
networks will not be attractive to employers and consumers.
Institutional details have been also found to have an influence
on physician services pricing, with large providers likely to
engage in detail bargaining with insurers over service-specific
pricing, whereas insurers offer small physicians’ groups contract
based on a fixed fee schedule.
While factors that contribute to increased negotiating leverage

in health care markets are complex and the outcome of price
negotiations between dominant insurers and dominant
providers — also known as a bilateral monopoly31 — is difficult
to predict, the result appears clear: prices bear little relation to
the cost of production and price variations are not adequately
explained by differences in hospital costs of delivering similar
services at similar facilities.
A common feature of contracts negotiated between private

health plans and providers is a form of benchmark to Medicare.
This enables contractors to simplify their contracts, use the
information available from Medicare on the relative cost of
providing services as a benchmark and ensure access to
“medically necessary” services (Clemens, Gottlieb and Molná,
2017). Hospital prices negotiated with private health plans
have been found to be partly associated with Medicare
payment rates (Cooper et al., 2019), whereas payment rates set
by Medicare significantly influence private insurance payments
to physicians, in particular, in markets with low physician
concentration or high insurer concentration (Clemens, Gottlieb
and Molná, 2017). Three quarters of the services and 55% of
the spending (physicians) are benchmarked to Medicare.
Deviations from Medicare payment rates involve contracts with
large physicians’ groups and payments for diagnostic imaging
services. Benchmarking is strongest in payment for services
where the average cost reimbursement will be most aligned
with marginal costs.
The information content of the relative value scale on which

Medicare’s payments are based can be interpreted as a
knowledge standard and, more generally, as a public good.
However, as prices convey signals and guide firms when they
make production decisions and consumers as they allocate
their budgets, Medicare price distortions may result in
inefficient allocation of resources among providers and levels
of care, and inefficient provider cost structure.
31 As a matter of economic theory, under a “bilateral” monopoly, output falls below

competitive levels and consumers are worse off than they would be with competitive
structures in both markets (Blair, Kaserman, and Romano, 1989).

The markets for hospitals, specialist physician organizations,
and primary care physician organizations at the Metropolitan
Statistical Area (MSA) level became more concentrated across
the United States between 2010 and 2016 (Fulton, 2017). In
2016, 90% of MSAs were highly concentrated32 for hospitals,
65% for specialist physicians, 39% for primary care physicians
and 57% for insurers. Insurance markets are highly
concentrated: the national market shares of the four largest
commercial health insurers was 83% in 2014 (up from 74% in
2006) (Dafny, 2018), and the two largest insurers had 70% or
more of the market in half of the MSA (Gaynor, 2018).
Consolidation between hospitals, physician practices and

insurers who are close competitors has reduced competition,
leading to higher prices through enhanced bargaining position
and leverage in negotiations with the relevant counterpart
(Melnick and Fonkych, 2016; Dafny 2018; Gaynor, 2018).
4
Reference pricing
Reference pricing is a type of health benefit design that gives
consumers seeking health care services an incentive to shop
around for the best deal. Under reference pricing, the health
insurer sets a cap — or “reference price” — for certain elective
treatments and procedures (e.g., knee replacement) that
represents the maximum amount the insurer will pay for the
treatment or procedure regardless of the health care provider
selected by the patient. If the patient selects a provider who
has negotiated a price with the insurer that is at or below the
reference price, the entire price is covered by the insurer and
the patient owes nothing. If the patient selects a provider
whose price is higher than the reference price, the insurer will
pay the reference amount, leaving the patient responsible for
the difference.
Reference pricing may increase pressures for price competition

and lead to further cost-reducing innovations in health care
products and processes (Robinson, Brown and Whaley, 2017). It
could save money when there are big price variations and
consumers have the time and information to shop for the best
option in areas with several providers. However, if low-priced
providers increase prices to the reference price or near it,
potential savings will not materialize (Fronstin and Roebuck,
2014).
32 The Herfindhal-Hirschman index (HHI) is used to measure market concentration. It is

calculated by squaring the market share of each firm competing in a market and summing
those values across all firms. Highly concentrated markets are those with HHIs greater
than 2500.

5
Balance billing
In 29 states and the District of Columbia, there are no state
laws or regulations that protect privately insured consumers
from balance billing by out-of-network providers in Emergency
departments or in-network hospitals (Lucia, Hoadley, and
Williams, 2017). Given that many insurance plans have very
minimal or do not have any out-of-network coverage, exposure
to balance billing is a source of increased concern to
consumers (Hempstead, 2018).
Medicare participating providers33 cannot balance-bill for

additional charges, whereas non-participating providers can
balance-bill beneficiaries, but by law the amount they balance-
bill cannot exceed 15% of the Medicare-approved payment
amount for non-participating providers for each service (95%
of the Medicare fee schedule amount)34.
Additional protections apply to Medicare beneficiaries with low

incomes and limited savings who are enrolled in the Qualified
Medicare Beneficiary (QMB) program. Beneficiaries enrolled in
the QMB program do not have to pay Medicare cost sharing
(deductibles, copayments, and coinsurance) and Medicare
participating and non-participating providers are not allowed to
bill them for Medicare cost sharing or balance billing amounts.
The Medicaid program in the beneficiary’s state is responsible
for paying for cost-sharing expenses. The amount paid for cost
sharing, however, may be limited according to state rules
(Kosimar, 2017).
33 Medicare participating providers are those that have signed an agreement to accept the
Medicare-approved amount as full payment for covered services, whereas non-
participating providers are those that haven’t signed an agreement to accept Medicare
rates but they can still choose to accept Medicare rates for individual services.
34 https://www.medicare.gov/your-medicare-costs/part-a-costs/lower-costs-with-
assignment.

6
Are hospitals cost shifting?
One argument for why prices have been rising is that hospitals
are simply cost shifting by demanding higher private payment
rates to make up for lower payment rates from Medicare and
Medicaid. Price differences alone do not provide evidence of
cost shifting because different payers may have a different
willingness to pay for services. At issue is whether one set of
payers (usually private insurers) is paying more because
someone else (usually public payers) is paying less. The notion
that high private payment rates are efforts to cost shift assumes
that hospitals operate under a structure so that any reduction
in payment rates from public programs like Medicare must be
made up by increases in private payment rates.
There is an alternative theory that hospitals in concentrated

markets with high private payment rates have negative
Medicare margins because of higher costs (Frakt, 2014). Weak
cost controls could be caused by the lack of competition in
these markets. In this scenario, higher payments from private
payers compensate for higher costs rather than for lower
payments from public programs. This theory is consistent with
findings from the Massachusetts Attorney General (The
Commonwealth of Massachusetts, 2017) that higher prices for
health care in the state reflected the hospitals’ higher cost
structures but were not necessarily caused by them. This theory
is also consistent with recent studies demonstrating that
private payment rates and market conditions are related to
hospital cost structure. Hospitals in markets with less
competition appear to be less efficient and thus have higher
cost structures; this reduces their overall margins and
necessitates higher commercial rates.
A study of 61 hospitals participating in the value-based

purchasing initiative of the Integrated Healthcare Association
demonstrated that hospitals in concentrated markets are more
likely to focus on revenue enhancement from private payers
— cost shifting — while hospitals in competitive markets are
more likely to focus on cost moderation. A review of inpatient
payment rates across hospital markets between 1995 and 2009
found that the hospitals most adversely impacted by Medicare
cuts — that presumably had the highest Medicare volumes
— did not make up the shortfall with increased prices from
other payers, while those affected the least actually increased
revenues. These studies find that what looks like cost shifting
may be inefficient behaviour related to markets lacking
competition (National Academy of Social Insurance, 2015).

7
Maryland35
In 1977, Maryland became the first and only state to receive
a waiver from CMS, allowing the state to set rates for all
patients, regardless of their insurance, so long as the state was
able to keep the cost growth below the national level. An
independent state agency, the Health Services Cost Review
Commission (HSCRC)36, was also empowered to set prices for
hospital procedures across the state. These rates are updated
each year based on multiple factors, including the Medicare
“market basket” forecast, economic conditions, productivity
improvements, changes in case mix and the previous year’s
performance. Hospitals can appeal the commission if they feel
that rates are unfair.
Evidence shows that Maryland’s rate setting program has

consistently held hospital cost growth per admission to below
the national average (Murray, 2009). Between 1976 and 2007,
Maryland had the second lowest rate of increase in costs per
admission in the US. The Maryland experience shows the
advantages of a system that ties all stakeholders together
under a common set of rules and illustrates the importance of
an independent authority to set rates that ensure cost
containment and provide the means of financial stability to
hospitals.
The fact that Maryland’s established rates have been relatively

generous — set higher than Medicare reimbursements in the
rest of the country — ensured that hospitals were able to cover
their costs and have sufficient incentives to continue to provide
the service, avoiding shortages. Additionally, the use of quality
measures has protected against decreases in the quality of
services provided. However, in recent years, the cost per
admission grew at a faster rate in Maryland than in the rest of
the nation, leading to concerns that, absent a change in this
trajectory, Maryland’s long-standing waiver could be in
jeopardy. Furthermore, the focus on cost per admission was
poorly aligned with other health care delivery system reforms
under way in Maryland and nationally that focus on
comprehensive, coordinated care across delivery settings.
On January 1, 2014, Maryland implemented its All-Payer Model

for hospitals, which shifted the state’s hospital payment
structure to an all-payer, annual global hospital budget that
encompasses inpatient and outpatient hospital services
(Rajkumar et al., 2014). Maryland’s All-Payer Model builds on
the state’s all-payer hospital rate setting system. The All-Payer
Model operates under an agreement with CMS37 that limits per
35 The state of Maryland has a population of 6 million inhabitants served by 47 general
acute care hospitals.
36 The HSCRC works closely with the Maryland department of health, and its seven
commissioners are appointed by the Maryland governor. The agency employs 39 full-time
staff, and its budget of US$ 14.1 million is funded by a fee collected from hospitals. The
HSCRC operates an Advisory Committee and technical Working Groups for formal expert
technical consultation. The HSCRC is independent and thus its decisions are not reviewed
by the legislative or executive branches.
37 http://www.hscrc.state.md.us

capita total hospital cost growth for both Medicare and all
payers and generates US$ 330 million in Medicare savings over
5 years. Under the Maryland All-Payer Model, the HSCRC
establishes an annual global budget38 built from allowed
revenues during a base period (the year 2013), which are
adjusted for following years using a number of factors, both
hospital specific and industry wide: an allowed rate of hospital
cost inflation, approved changes in the hospital’s volume based
on changes in population demographics and market share,
rising costs of new outpatient drugs, and additional
adjustments related to reductions in potentially avoidable
utilization and quality performance (Health Services Cost
Review Commission, 2018).
The HSCRC sets an agreement with each hospital in Maryland

following the “Global Budget Revenue” (GBR) model. This
model is a revenue constraint and quality improvement system
designed by the HSCRC to provide hospitals with strong
financial incentives to manage their resources efficiently and
effectively in order to slow the rate of increase in health care
costs and improve health care delivery processes and
outcomes. The GBR model is consistent with the hospital’s
mission to provide the highest value of care possible to its
patients and the communities it serves. The GBR model assures
hospitals that adopt it that they will receive an agreed-on
amount of revenue each year — i.e., the hospital’s “Approved
Regulated Revenue” under the GBR system — regardless of the
number of Maryland residents they treat or the amount of
services they deliver provided that they meet their obligations
to serve the health care needs of their communities in an
efficient, high quality manner on an ongoing basis.
The GBR model removes the financial incentives that have

encouraged hospitals to increase their volume of services and
discouraged them from reducing their levels of “Potentially
Avoidable Utilization”. It also provides hospitals with flexibility
to use their agreed-on global budgets to effectively address the
objectives of better care for individuals, higher levels of overall
population health and improved health care affordability. In
accepting the agreement, the hospital agrees to operate within
the GBR’s financial constraints and to comply with the various
patient-centred and population-focused performance
standards established by the HSCRC, including all the existing
components of the Maryland Hospital Acquired Conditions
program, the Quality Based Reimbursement program and the
readmissions reduction program. The hospital agrees also to
cooperate with HSCRC in the collection and reporting of data
needed to assess and monitor the performance of the GBR
model and in the refinement of the GBR model and the related
performance standards in the future.
The HSCRC then sets rates for services that Maryland hospitals
use to bill all payers so that total payments (based on expected
utilization) will match the global budget. As under Maryland’s
previous hospital payment system, each hospital bills payers
38 The global budgets encompass 95% of hospital revenues.

for services provided using the hospital’s service-specific rates.
Unlike the previous system, the global budget establishes a
ceiling on hospital revenues. In this context, hospitals have an
incentive to ensure that revenues do not fall short of or exceed
their budgets. To the extent that actual utilization deviates from
projected utilization and hospital revenues vary from the global
budget, a one-time adjustment to the approved budget for the
following year is made to compensate hospitals for charges less
than the approved budget and to recoup charges in excess of
approved revenues. However, hospital revenues are expected
to conform closely to the global budgets, otherwise penalties
are applied to discourage patterns of overcharging or
undercharging.
To compensate for some amount of deviation from the

underlying utilization assumptions, hospitals are permitted to
adjust their rates during the course of the year to reach their
global budgets39. However, there are limits on the size of
adjustments that are permitted40 and rate adjustments must be
applied uniformly to all services.
Maryland’s All-Payer Model has continued to reduce both total

expenditures and total hospital expenditures for Medicare
beneficiaries without shifting costs to other parts of the health
care system outside of the global budgets. These reductions
were driven by reduced expenditures for outpatient hospital
services. In contrast, there were no statistically significant
impacts on total expenditures or total hospital expenditures
among commercial insurance plan members. Maryland
hospitals were able to operate within their global budgets
without adverse effects on their financial status (RTI
International, 2018). However, the current approach, which is
focused on hospitals, does not sufficiently provide for
comprehensive coordination across the entire health care
system. Because of this limitation, the federal government
required Maryland to develop a new model that encompasses
all of the health care that patients receive, both inside the
hospital and the community. To this aim, on July 9, 2018,
Maryland and the federal government signed the Total Cost of
Care Model (TCCM) State Agreement, which became effective
January 1, 2019. To achieve a patient-centred system, the TCCM
includes the following key elements:
__ Care will be coordinated across both hospital and non-
hospital settings, including mental health and long-term
care.
__ The TCCM will invest resources in patient-centred care teams
and primary care enhancements.
__ Maryland will set a range of quality and care improvement
goals. Providers will be paid more when patient outcomes
are better.
39 The HSCRC monitors hospital charges and service volume through monthly reports to
ensure compliance with the global budget of each hospital.
40 Hospitals are permitted to vary their charges from the approved rates plus or minus 5%
without permission. Up to 10% variation is allowed but requires permission from the
HSCRC. The HSCRC will consider variation beyond 10% under special circumstances such
as to avoid penalizing hospitals for reductions in Potentially Avoidable Utilisation.

__ Maryland will set a range of population health goals
addressing opioid use and deaths, diabetes, and other
chronic conditions.
__ State flexibility will facilitate programs centred on the
unique needs of Marylanders, the provider community,
geographic settings, and other key demographics.
As part of the federal agreement to put the new TCCM in place,

all-payer hospital cost growth will continue to be limited to
3.58% per capita, a limit that was set in 2014 based on the
long-term growth of Maryland’s economy. As part of this Model,
Maryland commits to saving US$ 300 million in annual total
Medicare spending by the end of 2023.
A central part of the TCCM is the Maryland Primary Care

Program which is intended to support the delivery of advanced
primary care throughout the state and allow community
providers to play a vital role in prevention, improving health
outcomes and controlling total health care spending growth.
CMS will provide funding directly to the practices to strengthen
and transform the delivery of primary care around five
functions: access to care; care management;
comprehensiveness and coordination; patient and caregiver
experience; and planned care and population health. Care
Transformation Organizations41 will assist practices in meeting
care transformation requirements by providing care
coordination services; support for care transitions; data
analytics and informatics; standardized screening; and
assistance with meeting care transformation requirements.
41 A Care Transformation Organization is defined as an entity that hires and manages an

interdisciplinary care management team capable of furnishing an array of care
coordination services to practices. The interdisciplinary care management team may
furnish care coordination services such as: pharmacist services, health and nutrition
counselling services, behavioural health specialist services, referrals and linkages to
social services, and support from health educators and community health workers
(https://health.maryland.gov/mdpcp/Pages/care-transformation-organizations.aspx).

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Price Setting and Price Regulation in Health Care: Lessons For Advancing Universal Health Coverage

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Price setting and price

regulation in health care

Sarah L Barber, Luca Lorenzoni and Paul Ong

Sarah L Barber, Luca Lorenzoni and Paul Ong

Foreword and Acknowledgments vii

1. Why pricing is important 1

1.1. How does pricing fit within the commitments for

2. Comparison of case studies 8

Contents 2.1. Demographics and health resources 9

3.1. The base for payments 16

4. Process by which price is determined 28

4.1. Individual negotiations 29

5. Technical process of setting the price per unit

5.1. Costing methods  40

6. Aligning pricing with overall policy goals 49

6.1. Adjustments and add-ons to ensure payment

7.1. Institutional entities 61

8. Best practices for low- and middle-

8.1. Investing in data infrastructure 72

Annexes: Case studies

The objectives of this study are to describe experiences in price

The World Health Organization (WHO) and the Organisation for

Term Abbreviation Definition

viii Price setting and price regulation in health care

Price setting and price regulation in health care ix

Provider payment systems consist of one or more payment

x Price setting and price regulation in health care

Investing in data infrastructure. In setting the level of

Building institutional capacities. In several settings,

Establishing prices that approximate the most efficient way

Using prices as instruments to promote value for health

Price setting and price regulation in health care xi

Establishing systems of ongoing revision, monitoring and

Policies about pricing and purchasing health care services are

xii Price setting and price regulation in health care

Price setting and price regulation in health care 1

Pricing health services is a key component in purchasing the

In the case of balance billing, health care providers are

2 Price setting and price regulation in health care

For most commodities, pricing is determined based on supply

Important externalities exist in health, implying that

As such, health markets differ from conventional markets in

4 Price setting and price regulation in health care

Average annual percentage increase between 2000-16

100 Annual average 4%

Low income Lower middle Upper middle

Source: WHO, 2018.

occurring across all countries (WHO, 2018), whereby spending

Within the increase in public spending on health, countries are

In response to these opportunities, many countries are

Price setting and price regulation in health care 5

In some low- and middle-income settings, a large share of

Passive purchaser Strategic purchaser

Resource allocation Performance based

Source: Evetovits, 2019.

6 Price setting and price regulation in health care

Price setting and price regulation in health care 7

8 Price setting and price regulation in health care

Inputs per 1000 population

Foreword and Acknowledgments vii

1. Why pricing is important 1

1.1. How does pricing fit within the commitments for

2. Comparison of case studies 8

Contents 2.1. Demographics and health resources 9

3.1. The base for payments 16

4. Process by which price is determined 28

4.1. Individual negotiations 29

5. Technical process of setting the price per unit

5.1. Costing methods 40

6. Aligning pricing with overall policy goals 49

6.1. Adjustments and add-ons to ensure payment

7.1. Institutional entities 61

8. Best practices for low- and middle-

8.1. Investing in data infrastructure 72