Impact analysis of regulatory regime options for integrated health care provider networks in the Philippines

Abstract

Background: The enactment of the Philippine Universal Health Care (UHC) Act mandates the formation of Integrated Health Care Provider Networks (IHCPN), linking hospitals and health facilities, which includes government and privately-owned primary care providers. While hospitals and some health facilities are already under government regulation, primary care providers have not been
subjected to formal licensing requirements. In this changing service delivery model, the possible impact of three regulatory policy options being considered need to be assessed according to the goal of ensuring that health services remain affordable and are of high quality.

Methodology: A multi-method approach to regulatory impact analysis (RIA) systematically assessed three regulatory options: 1) one Department of Health (DOH) license per hospital and health facility (status quo); 2) one DOH license for all public hospitals and health facilities within an IHCPN and another for individual private hospitals and health facilities; and 3) one DOH license per individual hospital and health facility, and one DOH certification issued to individual hospitals and health facilities as part of an IHCPN. Information from literature, documents, focus group discussions, and cost analyses were triangulated.

Results: Regulators are faced with two main risks: there is no standard for networked health care delivery that could provide a foundation for regulation, and provider participation is voluntary, which could lower the interest of private providers to integrate. The three regulatory options considered these risks. Option 1 requires the least change in regulatory policy, but is expected to increase costs to regulators due to the expansion of licensing and enforcement work covering primary care providers. Option 2 requires the most change in regulatory policy, but may be the least expensive to enforce, especially if all facilities join a network. This can also be preferred in a setting with existing interlocal health zones, and participation in the network by private providers poses the most challenge. Option 3 is a tiered regulatory set up that projects the highest cost to regulators as a result of both establishing new certification standards and guidelines on top of a wider scope for enforcement.

Conclusion: This is the first RIAconducted for the Philippine health system, with challenges similar to those experienced in developing countries. Across the three pre-determined regulatory models, the least costly option may not be the easiest to mount and enforce. Implementability appears to be a stronger consideration which seems to be hinged to the option requiring incremental rather than large form of changes.