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Since the issuance of the “Second Advisory on the Payment of Fees to Managed Care Companies, Third Party Administrators, Insurance Entities or Patient Referral Services (“Third Parties”)” on 23 June 2017, the Singapore Medical Council (“SMC”) has been made aware that some Third Parties have amended their fee structures or have explained or elaborated further on the basis of their fees, and the SMC has continued to receive queries from doctors on whether these amended fee structures are in compliance with Guideline H3(7) (“the Guideline”) of the 2016 edition of the SMC Ethical Code and Ethical Guidelines. 

While the SMC is unable to comment on individual fee structures, we wish to state that where the Third Parties have set out the rationale for different tiers of fees payable, e.g. higher administrative fees where the claims involve greater complexity of work, and doctors are satisfied that the fees payable to the Third Parties do reflect the amount of work to be done by the Third Parties, the payment of such fees by the doctors would not be in breach of the Guideline.

However, if two cases within the same tier of complexity are charged different fees, such a fee structure may appear to be based primarily on the services the doctor provides or the fees he or she collects, rather than the complexity of work required of the Third Party. A doctor who enters an arrangement to pay Third Parties according to such a fee structure may be in breach of the Guideline.

Finally, with regard to the quantum of these fees, we note that this is a function of market forces and business costs, and each doctor must assess the reasonableness of the quantum of these fees, bearing in mind that whatever quantum he or she chooses to pay must not compromise the proper care of his or her patients.

We hope the above sufficiently addresses the concerns of the profession, and look forward to the cooperation of all doctors in complying with the Guideline when it comes into force on 1 July 2017.