[co-author: Lee Qiu Li]

As part of efforts to keep healthcare costs sustainable, the Singapore Ministry of Health (MOH) has on 13 November 2018 introduced fee benchmarks for surgeon fees at private hospitals and clinics. As at the date of writing, the document released by MOH is titled ‘Fee Benchmarks for Private Sector Surgeon Fees.

The 2018 fee benchmarks, developed by a Fee Benchmarks Advisory Committee comprising of various stakeholders including medical practitioners and representatives from the healthcare and insurance industries, cover 222 common surgical procedures. Data was obtained from private healthcare providers, with the aim of ensuring sufficient empirical basis for the intended benchmarks.

This is not the first guideline of its kind in Singapore. Since 2003, MOH has already publicised historical hospital bill sizes (including operation fees) for public sector hospitals, which subsequently extended to private hospitals. The Singapore Medical Association (SMA) – an association representing the majority of medical practitioners in Singapore – published a Guideline on Fees (GOF) in 1987 for the private sector. The 4th edition of the GOF in 2006 had expanded to cover almost 1,500 surgical procedures, but was withdrawn by the SMA in 2007 due to anti-competition concerns. In recent years, amid calls for fee guidelines for the private sector, the MOH proceeded to develop fee benchmarks for private medical practitioners.

The 2018 fee benchmarks were designed to serve as guidelines for private medical practitioners in setting fair and reasonable fees for surgical procedures. By pushing toward greater transparency, the MOH also hopes to facilitate and empower patients to make informed decisions.

Other stakeholders such as insurers could also take the fee benchmarks into consideration in insurance policy claims and assessment processes.

The fee benchmarks, developed by reference to actual transacted data, cover only surgeon fees. Other fees, such as facility fees and anaesthetist fees, are not included.

Please also note that while it is not specifically addressed in the MOH’s 2018 fee benchmarks, the Committee intended for the fee benchmarks to be periodically updated. The Committee recognised that over the years, there should be an allowance for some increase in the fees.

Implications on private medical practitioners

The fee benchmark for each procedure is expressed as a range of fees. The MOH recognises that there would be variation in skill and complexity within each surgical procedure, and has made it clear that the upper bound of the benchmarks do not constitute a fee cap. Private practitioners are thus not bound to peg their fees to stay within the benchmark ranges. However, it is recommended that private practitioners should use the benchmark ranges when setting their fee rates and make reference to the benchmarks when providing financial counselling to patients or their caregivers.

The fee benchmarks also place a greater imperative on practitioners to explain matters to patients should the fees exceed the upper bound. This explanation should be done before the operation. As a matter of good practice, medical practitioners should document clearly their explanations on the available treatment options and fees for the procedures, with the appropriate level of detail.

MOH has also stressed that fees exceeding the upper bound do not necessarily amount to overcharging. Nevertheless, medical practitioners may wish to note that the fee benchmarks may serve as a reference for regulators such as the Singapore Medical Council (SMC) and the MOH when investigating complaints relating to overcharging. Private medical practitioners should take care to ensure that departures from the fee benchmarks are justified and that appropriate explanations are provided to patients or their caregivers.


The publishing of the fee benchmarks is a welcome development. Greater information symmetry may also help to reduce complaints of overcharging against private practitioners.