Enhancing private healthcare price transparency

• Healthcare systems worldwide face the significant challenge of containing the growth of medical costs to ensure long-term fiscal sustainability. A recent market survey projects global medical cost growth to reach 10.3% in 2026, up from 10.0% in 2025.^{1Legend symbol denoting WTW (2025).} Similarly, Hong Kong's medical inflation is projected to rise to 9.9% in 2026, up from 9.7% in 2025. While slightly below the global average, this figure is still concerning given Hong Kong's baseline healthcare costs are already higher than many other places.
• Enhancing price transparency in private healthcare is a key strategy to address these rising costs. By empowering patients with better price information, transparency encourages cost-conscious choices and fosters market competition, ultimately pressuring high-cost providers to reduce price variations for equivalent services.^{2Legend symbol denoting Given the complex and varied nature of healthcare services, information asymmetry generally exists between healthcare professionals and patients in the private healthcare market. Most patients do not have professional knowledge in medicine, and need to rely on healthcare service providers for advice on their conditions and treatment options. See Health Bureau (2025a)}
• Many developed economies have mandated price transparency in private healthcare to benefit consumers.^{3Legend symbol denoting For example, in the Mainland, the Notice of Issues Related to the Implementation of Market Price Adjustment by Non-Public Medical Institutions launched in 2014 requires medical institutions to provide clear pricing and detailed lists of medical expenses to the public. In the United Kingdom, private healthcare providers are required to disclose price information under the 2014 Private Healthcare Market Investigation Order of the Competition and Markets Authority. See Competition and Markets Authority (2014) and 國家發展和改革委員會(2014).} In Asia, Singapore's Ministry of Health ("MOH") has progressively introduced fee benchmarks since 2018, covering hospital charges and professional fees for surgeon, anaesthetist and inpatient attendance.^{4Legend symbol denoting MOH also introduced fee benchmarks for 18 common dental procedures in October 2025. See Ministry of Health (2025b).} These benchmarks offer stakeholders a common reference for reasonable fees. Since their introduction, MOH reports that nearly 90% of doctors have charged within the recommended limits.
• In Hong Kong, the 2024 Policy Address proposed exploring similar legislation to address medical inflation. In May 2025, the Health Bureau briefed the Panel on Health Services of the Legislative Council ("LegCo") on legislative proposals to make existing voluntary price transparency measures statutory. With the draft regulation expected to be tabled in 2026, there are calls to draw on overseas experiences. This issue of Essentials first reviews the Government's ongoing efforts to improve patient access to price information, including recently proposed legislative measures. It then examines Singapore's experiences of implementing fee benchmarks for doctors' professional fees and hospital charges.

• Hong Kong operates a dual-track healthcare system comprising the public and private sectors.^{5Legend symbol denoting Legislative Council Secretariat (2026).} Notably, while the private sector employs approximately half of the city's doctors, it provides less than 10% of inpatient services and about 68% of outpatient services, highlighting an imbalance in the healthcare system.^{6Legend symbol denoting GovHK (2025a).}
• To address this imbalance and alleviate pressure on the heavily subsidized public sector, the Government has actively encouraged greater use of private healthcare services. The efforts include (a) passage of the Private Healthcare Facilities Ordinance (Cap. 633) in November 2018 to introduce a licensing regime for private healthcare service providers; and (b) the launch of the tax-deductible Voluntary Health Insurance Scheme ("VHIS") in April 2019 to incentivize the public to purchase health insurance.
• Alongside patient safety and affordability, the Government views price transparency as a pillar of private healthcare. In 2016, the Government collaborated with the Hong Kong Private Hospitals Association to pilot price transparency measures. Currently, all private hospitals in Hong Kong voluntarily implement three key practices: (a) publishing fee schedules for major chargeable items; (b) providing budget estimates for 30 common and non-emergency procedures; and (c) disclosing historical bill size statistics ("HBS") for the said procedures.
• Notwithstanding the voluntary price transparency measures, the Consumer Council received 191 complaints concerning services provided by private hospitals and day procedure centres between 2021 and 2024. Price disputes accounted for nearly half (45.5%) of these complaints. Following consultation with stakeholders, the Consumer Council identified three key inadequacies in the current system:
  • (a)
    First, while budget estimates provide patients with preliminary estimates of potential fees and charges, consumer disputes might arise when final bills show marked variations from these estimates. In some cases, such fee variations stem from unforeseeable clinical factors, such as complex medical conditions and post-surgical complications;
  • (b)
    Secondly, private healthcare service providers currently present their price information in different formats, making cross-provider comparison difficult. Some stakeholders call for implementing a standardized coding system to categorize different treatments, which would facilitate easier price comparison and improve reporting accuracy for practitioners; and
  • (c)
    Thirdly, there is inconsistency in budget estimate presentation, where some private healthcare service providers offer a written budget estimate form with detailed breakdown and information, while others only provide a verbal lump sum or rough price range.
• In May 2025, the Government submitted three preliminary legislative proposals to LegCo to enhance price transparency in the private healthcare sector.^{7Legend symbol denoting The Private Healthcare Facilities Ordinance empowers the Secretary for Health to make regulations for the purposes of Sections 61 and 62 on price transparency, including (a) to prescribe the price information to be provided, and the way it is to be provided; and (b) to prescribe the treatments and procedures for which estimates of fees and charges are to be provided, and the way they are to be provided. Section 63 prescribes hospitals to publish historical statistics on the fees and charges for the specified treatments and procedures in the way specified by the Director of Health.} These proposals, scheduled to be considered for implementation in 2026, include:
  • (a)
    Requiring private healthcare facilities (including private hospitals, day procedure centres and clinics) to make available price information through a fee schedule in specified format that clearly sets out all "Basic Service Items" and the most commonly performed "Specified Treatments and Procedures" ("STP")^{8Legend symbol denoting STP will include at least (a) the 30 common and non-emergency treatments/procedures of the existing Pilot Programme for Enhancing Price Transparency for Private Hospitals launched in October 2016; and (b) nearly 470 items of the VHIS Schedule of Surgical Procedures which has been set out in the VHIS Certified Plan Policy Template.}. The fee schedule should, as far as practicable, state fixed prices (e.g. HK$300 per outpatient consultation); otherwise, a price range should be provided;
  • (b)
    Mandating private hospitals to provide budget estimates for STP in a specified format (e.g. a detailed cost breakdown) before the patient receives the relevant healthcare services^{9Legend symbol denoting The budget estimate must separately list out the estimated hospital charges, doctor's fees as well as charges for medication, implants and consumables. The components of estimated doctor's fee include attending doctor's visit fees, surgeon's fees, anaesthetist's fees and specialist's fees. However, if a patient requires admission within 12 hours of booking, the budget estimate can be exempted.}. While final fees may be adjusted due to changes in clinical conditions, private hospitals must provide a written explanation to the patient, the patient's family member(s) or authorized person(s) when final fees significantly exceed the budget estimate (say, by 20% or more); and
  • (c)
    Obliging private hospitals to report and publish HBS on STP fees and charges to the Department of Health and publish the same on their websites annually.^{10Legend symbol denoting The data provided should include annual number of discharges, average length of stay (applicable to inpatient cases only), as well as hospital charges, doctor's fees and total charges (must include the actual range from the lowest to the highest case, and the fee levels for typical case (50th percentile) and high case (90th percentile)) for public reference.} This data must cover the previous calendar year for all standard bed cases, including statistics on instances where final fees significantly exceed the budget estimates. Furthermore, the Government proposes to establish a thematic website of HBS with searching tools to facilitate fee comparison among different private hospitals.

• Like Hong Kong, Singapore operates a mixed healthcare system. The heavily subsidized public sector delivers about 80% of acute hospital services, while the private sector provides approximately 80% of clinic services.^{11Legend symbol denoting As of end-2024, the public sector provides 84% of hospital beds. The private sector is the predominant provider of clinic services, operating 2 493 private clinics relative to 23 public polyclinics as at end-2023. See Ministry of Health (2025a, 2025c)., 12Legend symbol denoting Gaw et al. (2025).} In January 2018, MOH appointed a Fee Benchmarks Advisory Committee ("FBAC") to establish reasonable fee benchmarks for common medical procedures and services,^{13Legend symbol denoting FBAC comprised members from different backgrounds, including representatives from the medical community and healthcare providers, unions and non-profit organizations that could advocate for patients, insurance payers from the public and private sectors, and the academia. It was chaired by a senior cardiologist from private practice.} as part of a broader strategy to curb rising private medical costs. Between 2007 and 2017, the hospital inpatient bill size for Singapore citizens in the private sector grew at an average of 9% per annum, nearly doubling the public sector's 4.9%,^{14Legend symbol denoting Todayonline.com (2018).} with surgical fee as a major cost driver.
• In November 2018, MOH published surgeon fee benchmarks for around 200 common procedures (accounting for more than 85% of cases involving procedures). Benchmarks for anaesthetic fee and inpatient attendance fee were introduced in December 2020, followed by the launch of hospital fee benchmarks in June 2023.^{15Legend symbol denoting Hospital fee benchmarks include fee components such as hospital room charges, surgical facilities and equipment, implants, consumables, investigations, general nursing services and treatment, and medication. However, hospital fee benchmarks exclude doctors' professional fees (i.e. surgeon, anaesthetist and doctors' inpatient attendance fees)., 16Legend symbol denoting The current fee benchmark system does not apply to the public sector. In the public sector, doctors are salaried employees and there is no separate doctor fee charged for the surgical procedure, unlike the private sector.} The fee benchmark system now covers:
  • (a)
    Hospital fee for 21 common surgical procedures and 8 common medical conditions;
  • (b)
    Surgeon fee for 2 180 surgical procedures, covering all surgical procedures eligible for claims under MediSave and MediShield Life (Singapore's national healthcare insurance schemes);^{17Legend symbol denoting MediSave is a national medical savings scheme that requires working Singaporeans to contribute part of their monthly salary into a personal account to pay for their own or immediate family's hospitalization, day surgery and certain outpatient expenses. Meanwhile, MediShield Life is a national health insurance for all Singaporeans covering large hospital bills and costly outpatient treatments, with premiums payable via MediSave or voluntary cash top-ups and supported by government subsidies for lower- and middle-income citizens.}
  • (c)
    Anaesthetist fee for 550 procedures, covering 95% of private-sector cases requiring anaesthesia services; and
  • (d)
    Doctors' inpatient attendance fee.
• In recent years, substantial convergence towards recommended fee ranges and moderation of healthcare cost growth in private healthcare services have been observed. According to MOH, the proportion of doctors charging within recommended fee ranges increased from 80% when the benchmarks were first introduced in 2018 to approximately 90% currently. The annual growth rate in private surgeon fees also dropped from 3% during 2010-2018 to 0.4% in 2019-2023.^{18Legend symbol denoting cna (2025).}
• Singapore's fee benchmark system provides useful reference for Hong Kong regarding price transparency initiatives. Its system is defined by these salient features:
  • (a)
    Flexible range-based approach: The fee benchmark structure adopts a range-based approach rather than fixed prices, based on the 25th to 75th percentiles of historical transaction data. This effectively captures the majority of current market practices while excluding outliers. The fee ranges are calibrated to accommodate legitimate variations in case complexity and patient characteristics, generally with lower fees for simple cases and higher fees for complex ones. This range-based approach establishes clear parameters for reasonable charging while maintaining necessary flexibility in healthcare pricing;
  • (b)
    Extensive stakeholder engagement: FBAC comprises members from diverse backgrounds to ensure comprehensive stakeholder representation. The 12-member committee responsible for the 2023 revision was led by a senior consultant surgeon from private practice and included the Deputy Secretary of MOH, along with representatives from healthcare services, the academia, the insurance sectors, and patient advocacy groups.

    To ensure benchmarks are clinically appropriate and commercially viable, the process involves rigorous consultation. For the most recent review, the committee conducted over 10 stakeholder consultation sessions between June 2022 and March 2023, engaging approximately 600 specialists, hospital administrators and insurers;
  • (c)
    Systematic implementation and review: Singapore has adopted a progressive approach in implementing the fee benchmark system. The first set of benchmarks in 2018 initially focused on surgeon fees for around 200 common procedures, establishing a proof of concept and allowing for assessment of system effectiveness. Building on this foundation, the system was expanded strategically in 2020 and 2023 to cover anaesthetic and doctors' inpatient attendance fees, and hospital charges, thereby creating a more comprehensive framework for healthcare pricing.

    To ensure relevance, MOH adheres to a 3- to 5-year review cycle, with provisions for earlier reviews if market conditions change. FBAC also applies a growth factor to adjust for inflation, accounting for rising operating costs such as manpower, rental and other operating expenses^{19Legend symbol denoting The most recent 2023 benchmark updates incorporated inflation factors (a growth factor) ranging from 2.3% to 2.8% per annum for doctors' fee benchmarks.};
  • (d)
    Uniform surgical procedure coding system: The fee benchmark system is underpinned by MOH's Table of Surgical Procedures ("TOSP"), a comprehensive coding system that categorizes over 2 300 common surgical procedures in Singapore. The procedures are organized into 21 tables (Table 1A/B/C to Table 7A/B/C) based on complexity, with lower-numbered tables representing less complex procedures. According to MOH's latest updates in January 2024, there are currently 2 372 TOSP codes.

    The TOSP coding system facilitates patients' access to price information and enables them to estimate total costs before undergoing planned procedures. Using the relevant TOSP codes provided by their healthcare providers, patients can access the "cost financing" search tool on MOH's website to view recommended doctors' professional fees and/or hospital charges for their specific procedures (Figure 1)^{20Legend symbol denoting Alternatively, the public may search for fees information by diagnosis-related group or relevant keywords associated with the procedure or body part.};

    Figure 1 – Cost financing search tool on MOH's website

    

    Source:Ministry of Health (2026).
  • (e)
    Non-binding benchmarks: The fee benchmarks serve as a common reference rather than a mandatory price cap. Charges outside the benchmarks are permissible, particularly for cases involving unusual complexity. While doctors retain the discretion to charge beyond the benchmark ranges with valid justification, they should inform patients and insurers (where applicable) before the procedures, barring emergency circumstances. Healthcare providers who consistently charge above benchmark ranges may be subject to MOH review to ensure pricing transparency is upheld; and
  • (f)
    Dedicated mediation service: The Healthcare Mediation Scheme ("HMS"), launched by MOH Holdings^{21Legend symbol denoting The MOH Holdings is a 100% government-owned holding company of Singapore's public healthcare institutions, overseeing the effective and efficient distribution of resources to deliver value-based healthcare for Singaporeans. See Ministry of Health (2023b).} in 2014, provides a dedicated platform for resolving healthcare billing disputes. HMS sessions are typically conducted by two neutral mediators, one medically-trained and one legally-trained. Mediation fees are determined by the quantum of claim or the dispute amount^{22Legend symbol denoting The administrative fee for HMS mediation session ranges from S$75 (HK$450) to S$250 (HK$1,500) currently while the mediation fee ranges from S$75 (HK$450) to S$300 (HK$1,800) per hour (free of charge for the first two hours). See Healthcare Mediation (2026).}, with government subsidies available for those claimants facing financial difficulties^{23Legend symbol denoting Ministry of Health (2025d).}.

• In Hong Kong, resource imbalance between the public and private healthcare sectors has led to calls for enhanced price transparency to encourage greater private sector usage and contain medical inflation. Singapore's fee benchmark system shows how price transparency mechanisms can help reduce price variations in private healthcare services and moderate medical cost growth, while serving the interests of healthcare providers, patients, and insurers. Its salient features include a flexible range-based approach, comprehensive stakeholder engagement, systematic implementation and review, a uniform coding system for surgical procedures, non-binding nature of the benchmarks and dedicated mediation services for resolving billing disputes.