Download as docx, pdf, or txt
Download as docx, pdf, or txt
You are on page 1of 77

Running head: ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS i

Western Mindanao State University


College of Public Administration and Development Studies
Normal Road, Baliwasan, Zamboanga City

Assessing PhilHealth’s Unwarranted Claims to Private


Employers in Zamboanga City

A Research Paper

Presented to:

Bernard Q. Suriaga
Professor

Presented by:

Aldrich C. Tan
Researcher
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS ii

March 2020
ABSTRACT

With reference to the Revised Implementing Rules and Regulations (RIRR) of the

National Health Insurance Act of 2013 regarding the payment of Premium Contributions, "The

failure of the employer to remit the required contribution and to submit the required remittance

list shall make the employer liable for reimbursement of payment of a properly filed claim in the

concerned employee or dependent/s avail of program benefits, without prejudice to the

imposition of other penalties as provided for in this rules."

The Corporation then issued PhilHealth Circular No. 0028- 2015 on the Quality Procedures for

the Recovery of Payments for Properly Filed Claims by Employed Members but Without

Qualifying Contributions (Unwarranted Claims).The coverage of the order shall apply to claims

duly paid for by PhilHealth for employee-members and/or their qualified dependents but without

qualifying contribution (unwarranted claims), whose employer is delinquent, under-remitting,

non-remitting and/or non-reporting. The order shall also apply to employers who retain services

of accounting firms which include, but not limited to payment and remittance of PhilHeallth

premiums in behalf of the employer and their employees and the submission of corresponding

reports.
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS iii

ACKNOWLEDGEMENT

First and foremost, praises and thanks to the God, the Almighty, for His

blessings throughout the completion of my research.

I would like to express my deep and sincere gratitude to my PA 299 A – Research

Methods in Public Administration II Professor Mr. Bernard Q. Suriaga, for giving me the

opportunity to do the research and for providing invaluable guidance throughout this

research. His vision, sincerity and motivations have deeply inspired me. Also for her

patience, motivation, enthusiasm and immense knowledge that lead to the accomplishment

and success of this paper. She has taught me the methodology to carry out the research

and to present the research works as clearly as possible. It was a great privilege and

honor to study under his guidance. I am extremely grateful for what she has offered me.

I would also like to thank my colleagues from Philippine Health Insurance

Corporation who provided insights and expertise that greatly assisted the research.

Lastly, I would like to also thank my family, relatives and friends who in one way or

another shared their support.


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS iv

TABLE OF CONTENTS

I. INTRODUCTION 1
1.1 Background of the Study 1
1.2 Mandate 2
1.3 Powers and Functions 3
1.4 Members 7
1.5 Dependents 11
1.6 Registration Procedures 12
1.6.1 For individuals 12
1.6.2 For employers 12
1.7 Payment Premium Schedule 14
1.7.1 For individually paying members 14
1.7.2 For employers 16
1.8 Premium Requirement for Availment 18
1.8.1 Exemptions 19
1.9 Procedures of using PhilHealth in Accredited Health Care Institutions 20
1.9.1 Conditions before availing benefits 21
1.10 Organizational Chart 24
1.11 Definition of Terms 25
1.12 Statement of the Problem 26
1.13 Significance of the Study 27
1.14 Scope and Limitation 27
1.15 REVIEW OF RELATED LITERATURE 28
1.15.1 Theoretical Framework 29
1.15.1.1 Health Care System in Japan 29
1.15.1.2 Overview 30
1.15.1.3 Political Context 32
1.15.1.4 Foundation of the Health Insurance System 33
1.15.1.5 Expansion 34
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS v

1.15.1.6 Growth and Equity 34


1.15.1.7 Organization and Governance 37
1.15.1.8 Overview of the Health System 38
1.15.1.9 Historical Background 39
1.15.1.10 Regulation 40
1.15.1.11 Financing 41
1.15.1.12 Sources of revenue and financial flows 42
1.15.2.1 Conceptual Framework 45
1.15.2.2 No Balance Billing Policy 47

II. METHODOLOGY 51
2.1 Research Design 51
2.2 Research Locale 51
2.3 Research Instrument 51
2.4 Respondents of the Study 52
2.5 Data Gathering Procedure 52
2.6 Statistical Treatment of Data 53

III. RESULTS 54
3.1 Presentation 55
3.2 Analysis and Interpretation of Data 58

IV. DISCUSSION 62
4.1 Summary 62
4.2 Recommendation 63
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 1

CHAPTER 1

INTRODUCTION

1.1 Background of the Study

The call to serve the rural indigents echoed since the early '60s when the Philippine Medical

Association introduced the Maria Project which prioritized aid to communities in need of

medical assistance. The Project would then be considered a valuable precursor to the Medicare

program, from which a medical care plan for the entire Philippines was created. On August 4,

1969, Republic Act 6111 or the Philippine Medical Care Act of 1969 was signed by President

Ferdinand E. Marcos which was eventually implemented in August 1971. The Philippine

Medical Care Commission (PMCC) was tasked to oversee the implementation of the program

which went for almost a quarter of a century.

In the 1990s, a vision for a better, more responsive government health care program was

prompted by the passage of several bills that had significant implications on health financing.

The public's clamor for a health insurance that is more comprehensive in terms of covered

population and benefits led to the development of House Bill 14225 and Senate Bill 01738 which

became The National Health Insurance Act of 1995 or Republic Act 7875 signed by President

Fidel V. Ramos on February 14, 1995. The law paved the way for the creation of the Philippine

Health Insurance Corporation (PhilHealth), mandated to provide social health insurance

coverage to all Filipinos in 15 years' time.

PhilHealth assumed the responsibility of administering the former Medicare program for

government and private sector employees from the Government Service Insurance System in

October 1997, from the Social Security System in April 1998, and from the Overseas Workers
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 2

Welfare Administration in March 2005. The National Health Insurance Act of 1995 was then

amended by Republic Act 9241 signed on February 10, 2004 and Republic Act 10606 signed on

June 19, 2013.

1.2 Mandate

The National Health Insurance Program was established to provide health insurance coverage

and ensure affordable, acceptable, available and accessible health care services for all citizens of

the Philippines. It serves as the means for the healthy to help pay for the care of the sick and for

those who can afford medical care to subsidize those who cannot. It initially consist of Programs

I and II or Medicare and have expanded progressively to constitute one universal health

insurance program for the entire population. The program includes a sustainable system of funds

constitution, collection, management and disbursement for financing the availment of a basic

minimum package and other supplementary packages of health insurance benefits by a

progressively expanding proportion of the population. The program is limited to paying for the

utilization of health services by covered beneficiaries. It is prohibited from providing health care

directly, from buying and dispensing drugs and pharmaceuticals, from employing physicians and

other professionals for the purpose of directly rendering care, and from owning or investing in

health care facilities. (Article III, Section 5 of RA 7875 as amended)


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 3

1.3 Powers and Functions

Philippine Health Insurance Corporation is a tax-exempt Government Corporation attached to

the Department of Health for policy coordination and guidance. (Article IV, Section 15 of RA

7875 as amended). It shall have the following powers and functions (Article IV, Section 16 of RA

7875 as amended by RA 10606):

a) To administer the National Health Insurance Program;

b) To formulate and promulgate policies for the sound administration of the Program;

c) To supervise the provision of health benefits and to set standards, rules and regulations

necessary to ensure quality of care, appropriate utilization of services, fund viability, member

satisfaction, and overall accomplishment of Program objectives;

d) To formulate and implement guidelines on contributions and benefits; portability of benefits,

cost containment and quality assurance; and health care provider arrangements, payment,

methods, and referral systems;

e) To establish branch offices as mandated in Article V of this Act;

f) To receive and manage grants, donations, and other forms of assistance;

g) To sue and be sued in court;

h) To acquire property, real and personal, which may be necessary or expedient for the

attainment of the purposes of this Act;


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 4

i) To collect, deposit, invest, administer, and disburse the National Health Insurance Fund in

accordance with the provisions of this Act;

j) To negotiate and enter into contracts with health care institutions, professionals, and other

persons, juridical or natural, regarding the pricing, payment mechanisms, design and

implementation of administrative and operating systems and procedures, financing, and delivery

of health services in behalf of its members;

k) To authorize Local Health Insurance Offices to negotiate and enter into contracts in the name

and on behalf of the Corporation with any accredited government or private sector health

provider organization, including but not limited to health maintenance organizations,

cooperatives and medical foundations, for the provision of at least the minimum package of

personal health services prescribed by the Corporation;

l) To determine requirements and issue guidelines for the accreditation of health care providers

for the Program in accordance with this Act;

m) To visit, enter and inspect facilities of health care providers and employers during office

hours, unless there is reason to believe that inspection has to be done beyond office hours, and

where applicable, secure copies of their medical, financial, and other records and data pertinent

to the claims, accreditation, premium contribution, and that of their patients or employees, who

are members of the Program;

n) To organize its office, fix the compensation of and appoint personnel as may be deemed

necessary and upon the recommendation of the president of the Corporation;


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 5

o) To submit to the President of the Philippines and to both Houses of Congress its Annual

Report which shall contain the status of the National Health Insurance Fund, its total

disbursements, reserves, average costing to beneficiaries, any request for additional

appropriation, and other data pertinent to the implementation of the Program and publish a

synopsis of such report in two (2) newspapers of general circulation;

p) To keep records of the operations of the Corporation and investments of the National Health

Insurance Fund;

q) To establish and maintain an electronic database of all its members and ensure its security to

facilitate efficient and effective services;

r) To invest in the acceleration of the Corporation’s information technology systems;

s) To conduct information campaign on the principles of the NHIP to the public and to accredited

health care providers. This campaign must include the current benefit packages provided by the

Corporation, the mechanisms to avail of the current benefit packages, the list of accredited and

disaccredited health care providers, and the list of offices/branches where members can pay or

check the status of paid health premiums;

t) To conduct post audit on the quality of services rendered by health care providers;

u) To establish an office, or where it is not feasible, designate a focal person in every Philippine

Consular Office in all countries where there are Filipino citizens. The office or the focal person

shall, among others, process, review and pay the claims of the overseas Filipino workers

(OFWs);
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 6

v) Notwithstanding the provisions of any law to the contrary, to impose interest and/or

surcharges of not exceeding three percent (3%) per month, as may be fixed by the Corporation,

in case of any delay in the remittance of contributions which are due within the prescribed period

by an employer, whether public or private. Notwithstanding the provisions of any law to the

contrary, the Corporation may also compromise, waive or release, in whole or in part, such

interest or surcharges imposed upon employers regardless of the amount involved under such

valid terms and conditions it may prescribe;

w) To endeavor to support the use of technology in the delivery of health care services especially

in far flung areas such as, but not limited to, telemedicine, electronic health record, and the

establishment of a comprehensive health database;

x) To monitor compliance by the regulatory agencies with the requirements of this Act and to

carry out necessary actions to enforce compliance;

y) To mandate the national agencies and LGUs to require proof of PhilHealth membership before

doing business with a private individual or group;

z) To accredit independent pharmacies and retail drug outlets; and

aa) To perform such other acts as it may deem appropriate for the attainment of the objectives of

the Corporation and for the proper enforcement of the provisions of this Act.
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 7

1.4 Members

a. Members in the Formal Economy – those with formal contracts and fixed terms of

employment including workers in the government and private sector, whose premium

contribution payments are equally shared by the employee and employer.

1. Government Employee- an employee of the government, whether regular, casual or

contractual, who renders services in any of the government branches, military or police

force, political subdivisions, agencies or instrumentalities, including government-owned

and-controlled corporations, financial institutions with original charter; Constitutional

Commissions, and is occupying either an elective or appointive position, regardless of

status of appointment.

2. Private Employee - an employee who renders services in any of the following:

i. Corporations, partnerships, or single proprietorships, NGOs, cooperatives, non-profit

organizations, social, civic, or professional or charitable institutions, organized and based

in the Philippines including those foreign owned;

ii. Foreign governments or international organizations with quasi-state status based in the

Philippines which entered into an agreement with the Corporation to cover their Filipino

employees in PhilHealth;

iii. Foreign business organizations based abroad with agreement with the Corporation to

cover their Filipino employees in PhilHealth.


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 8

3. All other workers rendering services, whether in government or private offices, such as

job order contractors, project-based contractors and the like

4. Owners of Micro Enterprises

5. Owners of Small, Medium and Large Enterprises

6. Household Help- as defined in the Republic Act of 10361 or “Kasambahay Law”

7. Family Drivers

b. Members in the Informal Economy- this sector would include but are not limited to the

following:

1. Migrant Workers – documented or undocumented Filipinos who are engaged in a

remunerated activity in another country of which they are not citizens.

2. Informal Sector - to this sector belong, among others, street hawkers, market vendors,

pedicab and tricycle drivers, small construction workers, and home-based industries and

services.

3. Self-Earning Individuals – individuals who render services or sell goods as a means of

livelihood outside of an employer-employee relationship or as a career. These include

professional practitioners including but not limited to doctors, lawyers, engineers, artists,

architects and the like, businessmen, entrepreneurs, actors, actresses and other

performers, news correspondents, professional athletes, coaches, trainers, and such other

individuals.

4. Filipinos With Dual Citizenship – Filipinos who are also citizens of other countries.
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 9

5. Naturalized Filipino Citizens – those who have become Filipino citizens through

naturalization as governed by Commonwealth Act No. 473 or the Revised Naturalization

Law.

6. Citizens of other countries working and/or residing in the Philippines – foreign citizens

with valid working permits and/or Aliens Certificate of Registrations (ACRs) working

and/or residing in the Philippines.

c. Indigent – a person who has no visible means of income, or whose income is insufficient

for family subsistence, as identified by the DSWD based on specific criteria set for this

purpose in accordance with the guiding principles set forth in Article I of the Republic Act of

10606.

d. Sponsored Member – a member whose contribution is being paid by another individual,

government agency, or private entity according to the rules as may be prescribed by the

Corporation.

e. Lifetime Member – a member who has reached the age of retirement under the law and has

paid at least one hundred twenty (120) monthly premium contributions. Lifetime members

shall include but not limited to the following:

1. Retirees/ Pensioners from the Government Sector

i. Old-age retirees and pensioners of the GSIS, including non-uniformed

personnel of the AFP, PNP, BJMP and BFP who have reached the compulsory

age of retirement before June 24, 1997, and retirees under Presidential Decree

408.
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 10

ii. GSIS Disability Pensioners prior to March 4, 1995.

iii. GSIS Retirees who have reached the age of retirement on or after March 4,

1995 and have at least 120 months PhilHealth premium contributions.

iv. Retirees and Pensioners who are members of the Judiciary who have reached

the age of retirement and have at least 120 months PhilHealth contributions.

v. Retirees who are members of Constitutional Commissions and other

Constitutional Offices who have reached the age of retirement and have at least

120 months PhilHealth contributions.

2. Retirees/ Pensioners from the Private Sector

i. SSS Pensioners prior to March 4, 1995.

ii. SSS Permanent Total Disability Pensioners prior to March 4, 1995.

iii. SSS Death/ Survivorship Pensioners prior to March 4, 1995.

iv. SSS Old-age Retirees who have reached the age of retirement on or after

March 4, 1995 and have at least 120 months PhilHealth premium contributions.

3. Uniformed Members of the AFP, PNP, BJMP and BFP

i. Uniformed personnel of the AFP, PNP, BJMP and BFP who have reached the

compulsory age of retirement before June 24, 1997, and retirees under

Presidential Decree 408.ii. Uniformed members of the AFP, PNP, BJMP and BFP

who have reached the compulsory age of retirement on or after June 24, 1997,

being the effectivity date of RA 8291 which excluded them in the compulsory
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 11

membership of the GSIS and have at least 120 months PhilHealth premium

contributions.

4. Members of PhilHealth who have reached the age of retirement as provided by law and

have met the required premium contributions of at least 120 months, regardless of their

employer/s’ or sponsor’s arrears in contributions and is not included in the Sponsored

program nor declared as dependent by their spouse of children.

1.5 Dependents

The following also enjoy PhilHealth coverage without additional premiums:

 Legitimate spouse who is not a member;

 Child or children - legitimate, legitimated, acknowledged and illegitimate (as appearing

in birth certificate) adopted or stepchild or stepchildren below 21 years of age, unmarried

and unemployed.

 Children who are twenty-one (21) years old or above but suffering from congenital

disability, either physical or mental, or any disability acquired that renders them totally

dependent on the member for support, as determined by the Corporation;

 Foster child as defined in Republic Act 10165 otherwise known as the Foster Care Act of

2012;

 Parents who are sixty (60) years old or above, not otherwise an enrolled member, whose

monthly income is below an amount to be determined by PhilHealth in accordance with

the guiding principles set forth in the NHI Act of 2013; and,
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 12

 Parents with permanent disability regardless of age as determined by PhilHealth, that

renders them totally dependent on the member for subsistence.

 Qualified dependents shall be entitled to a separate coverage of up to 45 days per

calendar year. However, the 45 days allowance shall be shared among them.

1.6 Registration Procedures

1.6.1 For individuals under:

1. Formal Sector

a) Fill-out two (2) copies of the PhilHealth Member Registration Form (PMRF) and;

b) Fill-out two (2) copies of PhilHealth Report of Employee-Members Form (ER2) for

newly hired employees duly signed by the Head of Agency or Human Resource

Officer.

2. Informal Sector

a) Fill-out two (2) copies of the PhilHealth Member Registration Form (PMRF)

b) Submit PMRF to the nearest Local Health Insurance Office

c) Claim Member Data Record (MDR) and PhilHealth ID Card

1.6.2 For employers:

All government and private sector employers are required to register with PhilHealth to

enable them to provide social health insurance coverage to their employees.


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 13

Private sector employers (including those of household helps) who have registered with

the SSS prior to July 1, 1999 are automatically registered but are required to update their

records with PhilHealth.

Employers may register through the Philippine Business Registry (PBR). Once registered

in this system, they will no longer be required to submit documents. However, if the

employer fails to register through the PBR, the following shall be submitted:

1. Single Proprietorship

- Department of Trade and Industries (DTI) Registration

2. Partnerships and corporations

- Securities and Exchange Commission (SEC) Registration

3. Foundations and non-profit organizations

- Securities and Exchange Commission (SEC) Registration

4. Cooperatives

- Cooperative Development Authority (CDA) Registration

5. Backyard Industries/Ventures and micro-business enterprises

- Barangay Certification and/or Mayor’s Permit

To register their employees they have to submit the following documents, to wit:
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 14

 Two copies of Employer Data Record (ER1) Form

 Two copies of PhilHealth Membership Registration Form (PMRF)

for each employee

After processing, the employer will be issued the following:

 PhilHealth Employer Number (PEN) and the Certificate of Registration

 PhilHealth Identification Number (PIN) and Member Data Record (MDR) of

registered employees

Employers are required to display the Certificate of Registration in conspicuous area of

their offices.

1.7 Payment Premium Schedule

1.7.1 For individually paying members:

 Earning an average monthly income of P25,000 and below pay P200 monthly or

P2,400 per year, while those earning above P25,000 pay P300 monthly or P3,600 per

year. Premium contributions may be paid monthly, quarterly, semi-annually or

annually.
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 15

 Schedule of payment:

Pay until the last Pay until the last


Pay until the last Pay until the last working day of the
working day of working day of
working day of first quarter of the
the month being the first quarter of
Monthly the quarter being
Quarterly Semi-Annually Annually
year being paid for.
paid for. the semester
paid for.
being paid for.

Example: Example: Example:


Example: Period: January
Period: January to Period: January to
Month: January to December
March June
Deadline: January Deadline: March
Deadline: March Deadline: March
31 31
31 31

Figure 1. Individually Paying Members’ payment scheme

Figure 1 shows the Schedule of payment for individually paying members of PhilHealth. The

members have the option to choose whether to pay monthly, quarterly, semi-annually or

annually. As can be observed, the payment scheme of each payment period is due on the last

working day of the month.


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 16

1.7.2 For employers:

Step 1:Deduct the amount of monthly premium corresponding to the employee’s share

from the employee’s basic monthly salary.

Table 1

Employed Members’ Premium Contribution Table


Monthly Basic Monthly Premium Personal Share Employer Share
Salary x 2.75%
P 10,000.00 and P 275.00 P 137.50 P 137.50
below
P 10,000.01 to P P 275.02 to P P 137.51 to P 549.99 P 137.51 to P 549.99
39,999.99 1,099.99
P 40,000.00 and P 1,100.00 P 550.00 P 550.00
above
Note: the deduction would be in compliance with PhilHealth Circular No. 2017-0024 re:
Adjustment in the Premium Contributions of the Employed Sector to Sustain in the National
Health Insurance Program (NHIP)

As can be observed in Table 1, effective the applicable month of January 2018 and

onwards, the monthly premium contributions shall be at the rate of 2.75% computed

straight based on the monthly basic salary, with a salary floor of P10,000.00 and a ceiling

of P40,000.00, to be equally shared by the employees and their employer. With the

removal of the salary brackets, computation shall be based on the table presented.

Moreover, in accordance with RA 10361, the premium contributions of the Kasambahay

shall be shouldered solely by the household employer, However, if the Kasambahay is

receiving a monthly salary of five thousand pesos (P 5,000.00) or above, the Kasambahay

shall pay his/her proportionate share.


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 17

Step 2:Payment though Accredited Collecting Agents

Table 2

Employed Members’ payment schedule

Payment Schedule

Employers with PENs Every 11th-15th day of the month following the
ending in 0-4 applicable period

Employers with PENs Every 16th-20th day of the month following the
ending in 5-9 applicable period

Note: Remit the employee’s premium contribution, together with the employers’ share to
any of the Accredited Collecting Agents nationwide on or before the due date.

Step 3:All employers are required to use the Electronic Premium Remittance System

(EPRS) application as the mode for the payment of the premiums, and preparation and

submission of remittance report. The EPRS is a web-based application designed to allow

access to employee information through the employer's PhilHealth Employer

Engagement Representatives (PEERS). Security features are put in place to ensure the

confidentiality of information.

The E-Pay Services of the Bank of the Philippine Islands, Citibank, Unionbank, Security

Bank Development Bank of the Philippines, Asia United Bank, China Banking

Corporation, CTBC Bank (Philippines) Corporation, Philippine National Bank, East West

Banking Corporation, RCBC Savings Bank, Philippine Veterans Bank and Metropolitan
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 18

Trust & Bank Company are also available for the employers to facilitate payment and

reporting of premium contributions.

1.8 Premium Requirement for Availment

Consistent with PhilHealth Circular No. 2019-0004, to become eligible to PhilHealth benefits,

the member should have established the following premium payments within the immediate

twelve (12)- month period prior to the first day of availment:

1. At least three (3) months contributions within the immediate six (6) months prior to

the first day of confinement. The six- month period shall include the month of

confinement

2. Sufficient regularity of payment of premium contributions- payment of at least six (6)

months contributions preceding the required three (3) months contributions within the

twelve (12)- month period prior to the first day of availment.

Thus, a total of nine (9) months premium contributions within the immediate twelve (12) months

prior to the first day of availment shall be required to become eligible to PhilHealth Benefits

The counting of the twelve (12) month period prior to availment of benefits shall reckon from the

month of availment.
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 19

1.8.1 Exemptions:

1. Members with validity period:

a. Indigent members

b. Overseas Filipino Program (OFP) members

c. iGroup members

d. Members tagged as Point of Service (POS), both Financiall Incapable (FI) and

Financially Capable (FC) and Sponsored by Local Government

2. Members with automatic and continuous availment

a. Lifetime Members

b. Senior Citizens

3. Kasambahay in accordance with RA 10361 and PhilHealth Circular No. 016-2015

4. Group Enrollment members as defined in PhilHealth Circular No. 2017005 and

directly hired job order workers, contract of service and project-based personnel in the

government per PhilHealth Circular No. 2017-00

5. Women About to Give Birth (WATGB) as stipulated in PhilHealth Circular No. 025,

s. 2015
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 20

1.9 Procedures of using PhilHealth in Accredited Health Care Institutions

Present PhilHealth
Identification (ID) to PhilHealth Cares Check
PhilHealth Cares assigned in eligibility to avail either via
the Admitting Section of eclaims portal or iCares portal
Hospital

Submit Claims Signature


Form to the Billing Section
For all sectors: Fill out
together with the Photocopy
Claims Signature Form
of Philhealth ID and Member
Data Record (MDR)

Billing Section deducts


PhilHealth Benefits from
Hospital Bill

Figure 2. Process Flow

Once a PhilHealth member or eligible beneficiary has ailment that requires medical attention, a

claim for health benefit such as refund of hospital and medical expenses can be filed.
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 21

1.9.1 Conditions before availing benefits

The following must first be met to avail of your PhilHealth benefits:

 Filing for claim of benefits must be within the validity period as stated in your

Member data record or MDR or in the payment receipt. This means that if your

record indicates the coverage is from January to December of 2019, the health claim

must reflect on this specific period.

 The 45 days allowance for room and board of the member and the separate 45 days

allowance shared among the dependents have not been consumed yet.

1.9.1.1 Steps on claiming PhilHealth benefits

1. For outright/automatic deduction of benefits:

 Submit to the billing section the following prior to discharge from the hospital:

 Duly accomplished Claims Signature Form

 Clear copy of MDR.

 If MDR is not available, submit official receipt of applicable

premium payment

 If qualified dependent is not listed in the MDR – submit applicable

proof of dependency

 Agree with your attending physicians on how much is left to be paid for their

services over the professional fee (PF) benefit.


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 22

 Upon submission of all applicable documents, the billing section will compute

and deduct your benefits from your total hospital bill.

2. For direct filing/reimbursement:

Submit the following to PhilHealth or through the hospital in addition to the

documents mentioned earlier within 60 calendar days after discharge:

 PhilHealth Claims Signature Form

 Official receipts or hospital and doctor’s waiver

 Operative record for surgical procedures performed

For confinements abroad:

Submit the following within 180 days after discharge. Overseas confinements shall be

paid based on Level 3 hospital benefit rates.

 PhilHealth Claims Signature Form

 MDR or supporting documents

 Proof of applicable premium payments

 Original official receipt or detailed statement of account (written in English)

 Medical certificate (written in English) indicating the final diagnosis, confinement

period and services rendered.


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 23

3. Reminders after claiming benefits

After the automatic deduction or reimbursement of your benefits, PhilHealth will

send you (to the address you have indicated in your claim form) a benefit payment

notice or BPN. The BPN is a report of actual payments made by PhilHealth relative to

your confinement/availment.
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 24

1.10 Organizational Chart


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 25

Office of the
Regional Vice
President

Public Affairs
Planning Unit
Unit

Information
Technology Legal Office
Management
Section

Management Field Health Care


Services Operations Delivery
Division Division Management
Division
Fund
Administrative Collection
Management
Section Section Accreditation
Section
and Quality
Assurance
Comptrollershi General Membership Section
p Unit Services Unit Section
Benefit
Cashiering Zamboanga Administration
Human Section
Unit Resource Unit City Service
Office

Zamboanga
Sibugay Service
Office

Zamboanga del
Norte Service
Office

Zamboanga del
Sur Service
Office

Figure 3. Organizational Chart


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 26

1.11 Definition of Terms

 Properly Filed Claim- a legitimate paid, claim of a member and/or his/her qualified

dependents.

 Employee- any person who performs services for an employer in which either or both

mental and physical efforts are used and who receives compensation for such services,

the performance of which is under an employer-employee relationship.

 Employer- a natural or juridical person who pays or compensates for services rendered by

one or more individuals.

 Delinquent Employer- a registered employer who has missed payment of the monthy

contribution in behalf of all its employees for at least one (1) month within a period of six

(6) months

 Under-remitting Employer- a registered employer who remitted and reported

contributions for all its employees that is less than the amount of premium prescribed by

the Corporation and/or an amployer who remitted the prescribed amount of contribution

but did not include all its employees.

 Non-remitting Employer- a registered employer who has not remitted any premium

contributions in behalf of its employees from the start of operations or has not paid any

premium contribution for a period of six (6) months or more.

 Non-reporting Employer- a registered or unregistered employer who may or may not

have remitted premium contributions in behalf of its employees but has not submitted any

reports for at least one month within a period of six (6) months.

 N-claims - is the existing method of processing manually encoded claims submitted

directly by Health Care Institutions


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 27

 PMAIS- Stands for PhilHealth Member Accounts Information System which is a

database for remittances and reports for all members.

 EPRS- is a web-based application designed to allow access to employee information

through the employer’s representative. Security features are put in place to ensure the

confidentiality of information.

 PEER- stands for PhilHealth Employer Engagement Representatives who helps the

employers to ensure that the membership and contribution records of their agency/

company, among others, are updated with PhilHealth. The PEERs will also servee as the

link between the employer and PhilHealth in the effective dissemination of pertinent

information regarding the latest PhilHealth issuances concerning the Formal Sector

1.12 Statement of the Problem

With over a million worth of claims processed by PhilHealth, there will be those claims that are

unwarranted. The researcher will look into the cause of these Properly Filed Claims by employed

members but Without Qualifying Contributions and also identify the course of action to address

the continuous increase of these claims.

The motivations for the conduct of this research shall be to answer the following questions, to

wit:

1. What is the impact of these Unwarranted Claims to PhilHealth, Private Employers and its

employees?

2. What can be done to avoid Unwarranted Claims?

3. How does this affect the corporation’s funds?


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 28

1.13 Significance of the Study

This study aims to understand the impact of Unwarranted claims to Private employers. It is

important to understand and assess the cause of these unwarranted claims, to inform the

employers the required number of contributions for eligibility to PhilHealth benefits and help

PhilHealth Employers Engagement Representatives (PEERs) understand their primary

obligations are to remit the premium contribution of their employees on time, submit and post

report to avoid interest charges and inconveniences in time of benefit availment. On the other

hand, this will also help the corporation prevent future losses.

Further, this paper will also aid in the understanding of the policies that govern the corporation

especially on Unwarranted claims and would also raise the awareness of private employers on

their remittances to avoid future litigation.

1.14 Scope and Limitation

The study will focus on the processes that involve in availing of PhilHealth Benefits in

Accredited Health Care Institutions and different policies that lead to the concept of

Unwarranted Claims. Further, the data to be presented will be limited Private employers within

Zamboanga City.
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 29

1.15 REVIEW OF RELATED LITERATURE

The purpose of this chapter is to present a theoretical and conceptual framework which will be

employed by this study. It will give the framework that serve as a foundation for the

development of Unwarranted Claims in PhilHealth to Private Employers within Zamboanga

City.

Moreover,this chapter will give an overview of literature that is related to the Health Care

System in the Philippines.It will also be explaining the process of Availing Benefits in Health

Care Institutions that result to the concept of Unwarranted Claims. Further, this chapter will also

be clarifying the legal sanctions or penalties that an employer will be facing for the inability to

abide by the mandate set by the corporation.

Furthermore, it will present a conceptual framework of the variables contributing to the cause of

Unwarranted Claims and also the variables that intervene to the occurrence of these claims going

through policies that govern the study. These are presented to fully understand and strengthen the

foundation and the result of this study.


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 30

1.15.1Theoretical Framework

1.15.1.1Health Care System in Japan

In a study done by World Health Organization, Regional Office for South-East Asia in

2018, the Universal Health Insurance System in Japan has provided comprehensive

coverage to all Japanese citizens. Associating with economic growth, Japan has achieved

numerous successes in health such as control and eradication of common infectious

diseases, substantial decrease of transport accident death, and most famously, achieving

the world’s highest life expectancy.

However, negative population growth with low fertility rate coupled with an ageing

population, shrinking economy and increasing unemployment pose critical structural

challenges to Japanese health. In addition, tight control of health-care cost and a laissez-

faire approach to service delivery has resulted in a mismatch between need and supply of

health-care resources and reduction in accountability for care quality. Japan’s economic

slowdown, high life-expectancy and growing use of expensive technologies have led to

an ever-increasing rate of health-care expenditure. Consequently, good quality of care

with comparably low price is no longer available.

To counteract this, the government has adopted several reforms in the past two decades in

service delivery and financing: Long-term care insurance system (2000); Integrated

Community Care System (2006); The Comprehensive Reform of Society Security and

Tax (2010); and Regional Healthcare Vision (2014).


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 31

Moreover, young Japanese health-care leaders have already proposed Japan Vision:

Health Care 2035, which encourages a paradigm shift to the new system, with a goal to

build a sustainable health-care system that delivers better health outcomes through care

that is responsive and equitable to each member of the society and that contributes to

prosperity in Japan and the world.

1.15.1.2 Overview

Japan, the world’s third-largest economy, with a corresponding high standard of living,

level of development, safety and stability, has made a large number of noticeable

successes in health since its universal health insurance system was founded in 1961. This

includes the full implementation of universal insurance coverage, achieving the world’s

highest life expectancy and control and eradication of common infectious diseases. In

addition, transport accident deaths have decreased substantially in the past 50 years.

Despite these achievements, the country faces many challenges including a negative

population growth with low fertility rate, an ageing population, shrinking economy and

increasing unemployment rate. Increasing NCD related disease burden and degenerative

diseases especially in recent decades along with population ageing places a strain on the

national health system in many aspects especially in terms of service delivery and

financing.

Japan’s health system is characterized by universal insurance scheme, where participants

are free to choose health care facilities and good quality of care with comparably low

price. However, Japan’s policy of tight control of health-care cost and a laissez-faire

approach to service delivery, with inadequate governance of provider organizations,


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 32

created a mismatch between need and supply of health-care resources and impeded

accountability for care quality. Japan’s economic slowdown, high life expectancy, and

growing use of expensive technologies have led to an ever-increasing rate of health-care

expenditure (THE of % GDP: 6.3% in 1995 to 10.9% in 2015, by OECD). This

demographic dilemma requires a drastic reform in health-care and long-term care

systems.

Building on the robust implementation of universal health insurance system, several

reforms have been adopted in the past two decades in order to meet the challenges posed

by demographic changes.

Long-term care insurance system (2000): social insurance scheme for elderly aged 65

years and above who require long-term care or social services. This is reviewed and

revised every three years to maintain sustainability.

Integrated Community Care system (2006): a comprehensive system at the community

level that integrates prevention, medical services, and long term care and also provides

living arrangements and social care.

The Comprehensive Reform of Social Security and tax (2010): a joint reform for the

social security system and taxation system that should improve fiscal sustainability for

the Japanese social security system in Japan. In seven years since its start, several related

laws have successfully been enacted or amended under this reform plan and this plays the

central policy for healthcare and long-term care. Priority areas are: measures for the

support of children and child-raising, employment of young people, reform of medical


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 33

and long-term care services, pension reform, measures against poverty and income

inequality and measures for low income earners as a cross-system issue.

Regional Healthcare Vision (2014): The Ministry of Health, Labour and Welfare has

asked each prefectural government to create a region specific vision, specifically

requesting that prefectures estimate the future supply and demand for healthcare and

create region-specific healthcare systems by 2025. Together with ICCS, this vision aims

to provide seamless support for the elderly (from disease prevention to long-term care) in

their respective communities.

Japan needs a paradigm shift to the new system as proposed in Japan Vision: Health Care

2035, a report for the Health Minister by young Japanese health leaders in June 2015

under the former Health Minister, Yasuhisa Shiitake’s leadership. The goal of Japan

Vision: Health Care 2035 is to build a sustainable health-care system that delivers better

health outcomes through care that is responsive and equitable to each member of the

society and that contributes to prosperity in Japan and the world. This report proposes

that Japan’s health system move from inputs to outcomes, from quantity to quality and

efficiency, from cure to care, and from specialization to integrated approaches across all

sectors.

1.15.1.3 Political Context

Japan’s journey towards the universal insurance system has been marked by eras of

foundation, expansion and managed growth in a post-War nation. But seemingly, the path

to universal insurance was illuminated by strong egalitarian principles. Comparatively,

with reference to other countries at the same level of industrialization and wealth, it is not
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 34

surprising that the universal insurance system could be achieved in Japan; however, what

remains unusual is the breadth and depth of the health system that has been achieved.

Unique to the Japanese health system is the existence of both: Employees’ Health

Insurance plans and Community Health Insurance (CHI) plans, which are now classified

as National Health Insurance. Employee’s Health Insurance system has its origin in the

Bismarckian system of social health insurance in Germany. Although Employees’ Health

Insurance and CHI have different origins, together they extended coverage to the entire

population over time. CHI - This later became National Health Insurance (NHI), mainly

covered self-employed and temporary workers.

The history of national insurance systems after the Second World War was marked by a

movement towards attaining a higher level of care, in terms of health-care and welfare

similar to that of Western nations. Even now, tensions among contending political

parties, interest groups and public opinion on health care and health insurance have

continued to influence political debate, especially during national elections.

1.15.1.4 Foundation of the Health Insurance System

The foundation of the Japanese health insurance system arose from an effort towards

industrialization, in favor of progress. The most significant event in the history of the

Employee’s Health Insurance system was the enactment of the Health Insurance Act of

1922, which was promoted both by the government and industrial sectors to provide

health insurance, in order to maintain the health of workers and prevent them from being

attracted to socialism.
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 35

1.15.1.5 Expansion

By the middle of the 1930s, the majority of employees had access to health insurance,

thanks to the Employees’ Health Insurance system, while a very limited number of the

unemployed had access to health care.

In 1938, the Central Government decided to create an insurance system that targeted the

unemployed population so as to provide 100% insurance coverage to all Japanese

residents. Responding to the threat of socialism from the Union of Soviet Socialist

Republics, the government acted to extend coverage to both employed and unemployed

populations nationally. Later, as the political agenda became more influenced by the

military, the Ministry of Health and Welfare further expanded coverage with the main

purpose of recruiting healthy soldiers during the early 1930s. However, CHI was offered

on a voluntary basis and there were still many people who were not covered either by

Employees’ Health Insurance or CHI.

1.15.1.6 Growth and Equity

When the Second World War ended in 1945, many social services, including health care,

were destroyed, and the then-government was urged by GHQ (General Headquarters)

operated in the USA to create social infrastructure. Subsequently, political conflict

between the major parties resulted in the expansion of coverage to more vulnerable

groups, as the Liberal Democratic Party (LDP) attempted to weaken the socialist and

communist party agendas. NobusukeKishi, the LDP prime minister at that time, strongly

believed that attaining equitable health care and a welfare system could be the driving

force in making his cabinet sustainable. He expressed his intention to pursue universal
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 36

insurance coverage in his speech at the Diet in 1957 and enacted the National Health

Insurance Act (New) in 1958, which forced all municipalities to transform voluntary-

basis Community Health Insurance to mandatory National Health Insurance. This law

was enforced in 1959, and Japan officially achieved universal health insurance coverage

in 1961.

During a period of almost 15 years of economic growth that started in the early 1960s

with an unprecedented 10% growth rate (known as the economic miracle), the then LDP

prime ministers Hayato Ikeda and Kakuei Tanaka expanded the breadth and depth of

universal insurance coverage (initial co-payment rate started at 50% and was then

reduced to 30% by the 1980s). At the same time, there was increasing pressure from the

Socialist Party that urged a faster expansion of the coverage to the elderly, who were not

receiving the full benefits of economic growth. Advocates highlighted the fact that

because the elderly had lower income but more likely to experience illness, if their co-

payment for accessing health system was kept the same, even if they access the system at

the same rate, they would spend proportionally higher rate of their income on health care

costs. The ruling LDP thus decided to provide free health care for the elderly who were

above the age of 70 years. This populistic policy would later impose a heavy financial

burden on the Japanese health system.

The recession of the 1973 oil crisis marked the end of the “economic miracle” and

resulted in much slower economic growth. In a period of decreasing fiscal space and

increasing health expenditures, tensions between the LDP and the Socialist Party were

higher than ever. Although the Cabinet was sensitive to the increasing burden of health-
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 37

care costs (mainly due to free health care for the elderly) and the need to reduce health-

care expenditure, actions to contain health spending did not come until the late 1970s.

When the LDP won the national elections in the early 1980s, prime minister Yasuhiro

Nakasone started an austere fiscal policy, also known as “small government.” At a time

when global leaders like Margaret Thatcher from the United Kingdom and Ronald

Reagan from the USA were promoting austere fiscal policy, the Japanese government

started to reduce the health care budget primarily by abolishing free health care for the

elderly and introducing a fee-control schedule.

After a long period of austere fiscal policy for health, government actions were required

to address inequities inherent to a system with a complex governance structure and with

fragmented insurance plans with varying premium levels. In 2001, Junichiro Koizumi

was elected as prime minister with a promise of a more progressive approach to health.

However, poor macroeconomic performance and strong opposition from the Japan

Medical Association (JMA) (mainly directed at strong austere fiscal policy on healthcare

and the increase in both OOP and insurance premiums) limited such changes. The JMA’s

opposition, however, was weakened after Koizumi’s overwhelming victory in the general

election in 2005 (JMA made a significant blunder in the general election by taking an

anti-Koizumi stance, although health care was not at stake). With the overwhelming

majority, the Koizumi administration launched a fiscal policy in social security, in which

the natural increase of the social security budget would be suppressed by 1.1 trillion yen

in 5 years. Such an austere fiscal policy (the fee schedule for providers was decreased by

2.6% in 2006, the largest-ever price cut in its history) inevitably strained the health care
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 38

setting and created “health care crisis”. Since then, the balance between cost and quality

of health care remains a central debate in Japan.

More recent laws and policies have aimed to consolidate insurance plans, promote

community-level integration of health care, provide long-term care, encourage use of

health data including ICT use in health care and settle controversies on highly priced

drugs. In 2015, an advisory panel commissioned by the former health minister Yasuhisa

Shiozaki presented its vision for health care in 2035. In this proposal, a reformed system

will still promote egalitarian principles and at the same time underscore individual patient

values; it clearly states that its goal is to provide a “sustainable health-care system that is

responsive and equitable to each member of society.”

1.15.1.7 Organization and Governance

The Ministry of Health, Labour and Welfare (MHLW) is the central leading organization

in the Japanese health care system. Japan’s health care system is characterized by

excellent health outcomes at a relatively low cost; the system emphasizes equity,

facilitated by universal insurance coverage through social insurance premiums and tax

subsidies, with virtually free access to health-care facilities. The country’ population is

rapidly ageing and Japan needs to transform its health care system into one that prioritize

patient value, quality and efficiency of care, and integrated approaches across sectors.

The MHLW as Japan’s leading organization, actively collaborates and cooperates with

various other bodies such as the Cabinet, several other ministries and professional

organizations. Traditionally, the Ministry of Finance (MOF), the Ministry of Education,

Culture, Sports, Science and Technology (MEXT), and the Ministry of Agriculture,
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 39

Forestry and Fisheries (MAFF) are involved in financing (in particular, the fee schedule

and drug pricing), medical professional education, food security and one health, among

others. Recently, the Cabinet Office and the Ministry of Economy, Trade and Industry

(METI) have become more involved in health care and the medical industry. In 2013, the

Central Government published the Japan Revitalization Strategy, in which health care

was determined to be one of the top driving forces for revitalizing the Japanese economy

(Prime Minister of Japan and His Cabinet, 2013). Under this strategy, Medical

Excellence Japan (MEJ) was established under the support of the MEXT in order to

promote and expand Japanese health-care services. Additionally, at the G7 Ise-shima

summit in 2016, health – with a strong focus on health security – was one of the main

agenda items on which the Cabinet Office, MHLW, MOF and Ministry of Foreign

Affairs (MOFA) worked together closely.

The government regulates and controls nearly all aspects of the health system at three

levels: national, prefectural, and municipal, where service delivery and implementation

are mainly handled by prefectural and municipal governments. Several professional

organizations such as the JMA and the Japanese Nursing Association (JNA) are also

actively involved in health policy processes. The manner in which the MHLW interacts

with these professional organizations, including the private sector, care providers and

patients, is notably complex.

1.15.1.8 Overview of the Health System

Japan’s health system is distinctly characterized by universal health insurance, which

provides excellent health outcomes at a relatively low cost with equity (Ikegami N et al.,
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 40

2011; Murray CJL, 2011). By law, all residents of Japan (including foreign nationals with

a residence card) must be enrolled in a health insurance programme.

There are two main types of health insurance in Japan – the Employees’ Health Insurance

System and National Health Insurance (NHI) (previously called Community Health

Insurance). The Employees’ Health Insurance System is provided to employed workers

(company employees) and their dependents, while NHI is designed for self and

unemployed people (hence those not eligible to be members of Employees’ Health

Insurance) and is run by municipal governments (i.e., cities, towns and villages).

Patients’ co-payments for medical expenses must be paid at every visit to clinics and

hospitals. The nationally uniform fee schedule (i.e., amount of reimbursement, including

the patients’ co-payment) covers most healthcare procedures and products, including

drugs. The health insurance pays 70–90% of the cost while the remainder is paid by the

insured as co-payment. The co-payment rate as of March 2017 is as follows: pre-

elementary school3 = 20%; elementary school up to age 69 years = 30%; age 70–75 years

= 20%; and age 75 years or above = 10% (Ishii M, 2012).

1.15.1.9 Historical Background

The two health insurance schemes in Japan – Employees’ Health Insurance system and

NHI have different histories. As summarized in Chapter 1.3, the Employees’ Health

Insurance System started in 1922 for employed workers, while the CHI system, which

was later renamed “NHI,” was designed and enacted in 1938 for self-employed workers

(such as farmers, fishermen, and informal employees) (Hatanaka T et al., 2015).


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 41

Participation in these two insurance schemes was voluntary, so a substantial number of

individuals were not covered under either Employees’ Health Insurance or NHI.

In the aftermath of the Second World War, the growth of democratic movements and a

commitment to social solidarity gave rise to the impetus to achieve universal insurance.

After a transition from voluntary to mandatory enrolment in the NHI system, together

with the expansion of coverage of the Employees’ Health Insurance System, a universal

health insurance system was established in 1961 (although the service coverage was

limited and out-of-pocket (OOP) was still high at 50%) (Ikegami N et al., 2011). Thanks

to the economic boom after the Second World War, the government successfully

expanded its service coverage and reduced the OOP payment rate from 50% to 30%.

Moreover, the government introduced a monthly and an annual cap on the OOP payment

for individuals and households (see more details in Section 3.4.1) as well as free medical

services for the elderly in 1973. Although the latter ended in 1982 due to economic

stagnation, this framework has remained the foundation for the health-care system for the

elderly.

1.15.1.10 Regulation

Regulation of the health-care system has two dimensions: human and capital resources

are regulated by the Medical Care Act, and financing is regulated by the Health Insurance

Act of 1922. Regulatory bodies consist of a three-tier system, in which the Central

Government, prefecture governments and major city governments share different levels

of authority.
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 42

1.15.1.11 Financing

Japan’s health-care system is based on a social insurance system with tax subsidies and

some amount of out-of-pocket (OOP) payment. According to OECD data, total health

expenditure increased substantially and accounted for 10.9% of the GDP in Japan in 2015

(ranked 3 among 34 countries), about two percentage points above the OECD average of

9%. Healthcare in Japan is predominantly financed by publicly sourced funding. In 2015,

85% of health spending came from public sources, well above the average of 76% in

OECD countries. Direct OOP payments contributed only 11.7% of total health financing.

The health insurance coverage rate was nearly 100% while the share of household

consumption spent on OOP payments was only 2.2%, 0.6% less than the OECD average

of 2.8%. Despite the relatively low OOP payments, the key challenges in Japan are

population ageing, rapid increases in chronic illness, escalating medical expenditure,

contracting fiscal space, and pressures on the health-care workforce. Reforms of the

financing system and greater efficiencies in health systems will be necessary to sustain

good health at low cost with equity in the future.

The health insurance covers more than 5000 medical procedures, dental care and drugs.

Once every two years, the MHLW reviews the scope of coverage by the national

insurance scheme and the billing reimbursement conditions for each procedure, drug, and

medical device.

There are two major types of insurance schemes in Japan; Employees’ Health Insurance

and NHI. Employees’ health insurance covers those who are public servants or work in

companies, while NHI covers the self-employed and unemployed. Employees’ Health
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 43

Insurance is further divided into four major categories: Japan Health Insurance

Association (JHIA), Society Managed Health Insurance (SMHI), Mutual Aid

Association, and Seamen’s Insurance. Japan does not have a single insurance fund;

insurers are divided into approximately 3000 organizations.

Moreover, the premium rate largely differs from one insurance scheme to the next; this

fragmentation is a source of inefficiency in the system and 44 inequity in premiums.

Although there are several cross-subsidy systems among insurance schemes, mainly for

the financially weak NHI, financial sustainability and equity among insurance schemes

remain major challenges for the Japanese health financing system, especially when one

takes into account the rapidly ageing society.

1.15.1.12 Sources of revenue and financial flows

The Japanese health-care system is primarily funded through insurance premiums

subsidized by taxes. Both the Central Government and the municipalities levy

proportional income taxes and insurance premiums on their respective populations.

According to National Health Care Expenditure (NHCE), insurance premiums contribute

to 48.7% of financial contributions followed by public subsidies (38.8%) and patients’

copayments (11.7%) (Ministry of Health, Labour and Welfare, 2014a).

Thus, the researchers concluded that for the past decades, Japan has ranked high in a

range of population health metrics including the world’s longest life expectancy. Thanks

to its overall effectiveness of the health system and paralleled advances in technology,

Japan has for many years enjoyed increased life expectancy along with decreased

maternal and infant mortality and burden of communicable diseases. While this was
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 44

achieved through various socioeconomic factors, the health care system guided by the

principles of a universal health insurance system undoubtedly played a major role. Since

its founding in 1961, the universal health insurance system in Japan has provided

comprehensive coverage to all Japanese citizens.

Japan’s health system is characterized by universal insurance scheme through social

insurance premiums and tax subsidy, where participants are free to choose health care

facilities and good quality of care with comparably low price. However, as a greater

proportion of the population can expect to live a long life, in recent decades the incidence

of NCDs such as obesity and diabetes have increased significantly. This rise, along with

population ageing, continues to place strain on the national health system. Coupled with

over two decades of economic slowdown, Japan must now find policies that balance

universal coverage, support for the elderly, and financial sustainability.

The Ministry of Health, Labor and Welfare is the central leading institution in Japan’s

health system. The structure of the MHLW is complex, as well as the manner in which it

interacts with other ministries, insurance associations, the private sectors including health

care industries, care providers and patient and professional organizations such as the

Japan Medical Association and Japanese Nursing Association. Although one of the

unique attributes of Japanese health care system is that most of the services are provided

through private organizations, the government regulates and controls nearly all aspects of

the health system, 190 particularly a uniform fee schedule, at three levels national,

prefectural, and municipal. One of the characteristics of Japanese health care system is its

free access to health care facilities. Compared to other OECD countries, inpatient care in

Japan is characterized by longer average hospital stays with a greater number of inpatient
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 45

beds per capita with comparably low number of physicians. The number of physicians

and nurses per 1000 were 2.35 in doctors and 9.06 in nurses. Although its number of

nurses is higher than the 8.3 average in OECD, the number of physicians is below that of

OECD average of 3.02. This is likely to be caused by the ease of access to the health care

system at any point. This style of system has financial consequences that need to be

accounted for. Japan’s policy of tight control of health-care cost and a laissez-faire

approach to service delivery, with inadequate governance of provider organizations,

created a mismatch between need and supply of health-care resources and impeded

accountability for care quality.

Moreover, The goal of Japan Vision: Health Care 2035 is to build a sustainable health

care system that delivers better health outcomes through care that is responsive and

equitable to each member of the society and that contributes to prosperity in Japan and

the world. To attain this goal, the panel proposed three main pillars of reform: lean

healthcare (implement value-based healthcare), life design (empower society and support

personal choice) and global health leader (lead and contribute to global health). Bearing

in mind these transformations by 2035, reforms to the financing system and greater

efficiencies, with focus on outcomes, quality and efficiency, care and integrated

approaches across sectors, will be necessary to maintain a low-cost, equitable health

system in the future. (Sakamoto H, Rahman M, Nomura S, Okamoto E, Koike S,

Yasunaga H et al. Japan Health System Review. Vol. 8 No. 1. New Delhi: World Health

Organization, Regional Office for SouthEast Asia, 2018.)


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 46

1.15.2.1Conceptual Framework

Dependent Variable Independent Variable

Unwarranted Claims Private Employers who


are:
1. Non-Remitting
2 Under-Remitting
3 Delinquent
4. Non- Reporting

Intervening Variables

Members under these categories:

1. Indigents
2. Sponsored- Local Government
3. Senior Citizen
4. Lifetime member
5. Domestic Workers or Kasambahays

Figure 4.Conceptual Framework

Figure 4 shows the relationship of Dependent Variable, Independent Variable and Intervening

Variables to each other. With reference to the figure above, the Conceptual framework shows

that for benefit availment in both Accredited Private and Government Hospitals of Employed

members they are required to submit a form called Claims Form 1 or known today as Claims

Signature Form which will be certified by the employer. On the Part IV of the form, the

employer is certifying that his/her employee has the required 3/6 monthly premium contributions
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 47

plus at least 6 months contributions preceding the 3 months qualifying contributions within 12

month period prior to the first day of confinement (sufficient regularity) have been regularly

remitted to PhilHealth. The form was then revised on September 2018 and now called as Claims

Signature Form and the Employer Certification is now on the Part II of the form.

With reference to the eligibility requirement, consistent with the new guidelines on eligibility for

old members and in compliance with PhilHealth Circular No. 2019-0004, the circular defined the

parameters that will determine the sufficiency and regularity of premium payment. PhilHealth

Board Resolution no 209, s-206 declares that “… to establish sufficient regularity of payment,

members should have paid six (6) months contributions preceding the three (3) months

qualifying contributions within twelve (12) month period prior to the first day of availment…”

Further, the unwarranted Claims (Dependent Variable) are mostly billed to private employers

that are delinquent, under-remitting, non-remitting and/or non-reporting (Independent Variables)

because of certifying the Claims Signature Form of their employees knowing that they have

insufficient premium contributions to suffice the mandate of PhilHealth.

With reference to Section 18(d) of the Revised Implementing Rules and Regulations (RIRR) of

the National Health Insurance Act of 2013 on the Payment of Premium Contributions: “The

Failure of the employer to remit the required contribution and to submit the required remittance

list shall make the employer liable for reimbursement of payment of a properly filed claim in

case the concerned employee or dependent/s avails of Program benefits, without prejudice to the

imposition of other penalties as provided for in this rules.”

Relative to this, The Corporation issued PhilHealth Circular No. 0028- 2015 on the Quality

Procedures for the Recovery of Payments for Properly Filed Claims by Employed Members but
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 48

Without Qualifying Contributions (Unwarranted Claims). The coverage of the order shall apply

to claims duly paid for by PhilHealth for employee-members and/or their qualified dependents

but without qualifying contribution (unwarranted claims), whose employer is delinquent, under-

remitting, non-remitting and/or non-reporting. The order shall also apply to employers who

retain services of accounting firms which include, but not limited to payment and remittance of

PhilHeallth premiums in behalf of the employer and their employees and the submission of

corresponding reports.

Moreover, the information supplied by the member or his/her representative on Part I of the form

are consistent with the corporation’s available records As such, the corporation is obligated to

request for reimbursement of the amount of the benefit availed by the member or dependent/s.

It can also be observed that there are identified intervening variables that prevent the employers

from having Unwarranted Claims. The variables stated in the conceptual frameworkare

Indigents, Sponsored- Local Government, Senior Citizen, Lifetime member and Domestic

Workers or Kasambahays. Members under these categories are covered by the No Balance

Billing Policy.

1.15.2.2 No Balance Billing Policy

With reference toPhilHealth Circular No. 2017- 0006 and Section 43 of the Implementing

Rules and Regulation of Republic Act No 10606 (National Health Insurance Act of 2013)

re: No Balance billing Policy, relative thereto the policy covers members and dependents

of the categories, to wit:

 Indigent

 Sponsored
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 49

 Domestic Worker or Kasambahay

 Senior Citizen

 Lifetime members

The General Policies stated in the circular are:

A. Under the No Balance Billing Policy, no other fees or expenses shall be

charged or be paid for by qualified No Balance Billing (NBB) Patients above and

beyond the packaged rates.

B. Health Care Institutions shall be responsible and accountable for the care of

patients and in achieving the best outcome. They shall extend all medical and

financial support to qualified NBB members and dependents. They shall not deny

access to health services whenever necessary.

C. Health Care Institutions must give NBB Patients preferential access to their

social welfare funds or other sources for financing such as Philippine Charity

Sweepstakes Office (PCSO) and Medical Assistance Program (MAP), which may

be used to augment the benefit package provided in case of insufficiency to fully

cover all facility charges.

D. All Health Care Institutions shall ensure to deliver utmost quality of care and

provide complete medical and non-medical care, including but not limited to,

drugs, supplies (e.g., implants, plates, screws, pins, straps), diagnostics and other

medically necessary services like provision of adequate patients’ meals based on


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 50

prescribed therapeutic diet, nutritional status and dietary requirements, to achieve

the best possible outcome.

E. If the patients’ condition requires stay in the Intensive care unit, isolation room,

recovery room and other special accommodation, this shall be provided to the

patient and the NBB Policy shall apply.

Having stated this, The No Balance Billing (NBB) policy enables the vulnerable sectors

of the program such as the poor and the elderly to pay no more in excess of their

PhilHealth coverage when confined in government facilities. Further, they are intervening

variables since they do not need premium contributions in order to avail PhilHealth

Benefits in both Government and Private Hospitals which do not result to Unwarranted

Claims. Further, employers are not required to certify in the part IV of the form since

their membership category will already suffice for benefit availment.

Relative thereto, employers have the impression that since they are covered under the

policy they do not need to remit their employees’ premium contribution and not

deducting the same to their payrolls but with reference to the legal sanctions and penalties

of provisions stated in the IRR :

 “Section 178 on the Failure of Refusal to Register/Deduct Contributions- Any

employer or officer who fails or refuses to register/deduct contributions from

the employee’s compensation shall be penalized with a fine of not less than

Five Thousand Pesos (Php 5,000.00) multiplied by the total number of

employees of the firm.


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 51

 “Section 179 on the Failure or Refusal to Remit Contributions – Any

employer or officer authorized to collect contributions who, after collecting or

deducting the monthly contributions due from the employees, fails or refuses

to remit said contributions to the Corporation within thirty (30) days from the

date they become due shall be punished with a fine of not less than Five

Thousand Pesos (Php 5,000.00) but not more than Ten Thousand pesos (Php

10,000) multiplied by the total number of employees of the firm.”

Thus, employers and employee are mandated by law to deduct and be deducted on their

pay slip regardless of category as long as they are employed making them dual category

members.
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 52

CHAPTER 2

METHODOLOGY

This chapter will discuss the researcher’s method of gathering the necessary data. It will also

determine the type of research to be used that will be influential to the recommendations of the

research, also stating the location of the research conducted and the instrument used that is

needed for the interpretation of data.

2.1 Research Design

The type of research to be used in the study is both quantitative and qualitative. The quantitative

method will be used to quantify the total number and amount of Unwarranted Claims received

and also the number of employers affected to be able to provide a better perspective in drawing

out a statistical conclusion. The qualitative method will be descriptive based on the collected

data then an observation will be presented.

2.2 Research Locale

The research was conducted in Philippine Health Insurance Corporation Regional Office IX

located in BGIDC Corporate Center, Governor Lim Avenue, Zamboanga City. It will base on

Private Employers within Zamboanga City.

2.3 Research Instrument


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 53

The instrument to be used in the study was data extracted on Properly Filed Claims without

qualifying Contribution (Unwarranted Claims) from PhilHealth’s System through N-Claims

from Benefit Administration Section and through Interview Method within the premises of the

Office.

2.4 Respondents of the Study

The respondents will be from the Management, The Philhealth Accounts Management

Monitoring Officer, Employers with the most number of Unwarranted Claims and employees

who requests for certification of Claims Signature Form and the Employees requesting for

certification.

2.5 Data Gathering Procedure

The Philippine Health Insurance Corporations released Office Order No. 0028-2015 on the

Quality Procedures for the Recovery of Payments for Properly Filed Claims by Employed

Members but Without Qualifying Contributions (Unwarranted Claims). As such, these are the

following procedures to be followed when extracting data relative to Unwarranted Claims, to

wit:

1. The Benefit Administration Section will generate report/list of employers with

employees with properly filed claims but no qualifying premium contributions using the

N-Claims. The report will contain the details of the claim and the employer.

2. This generated reported will be forwarded to Collection Section.

3. The Collection Section will be responsible for the validation of premium contributions

of employers in the list thru PMAIS Treasury Database. This is also in coordination with
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 54

the Membership Section; it should be ensured that the actual employer at the time of

availment is properly identified.

4. If verified without qualifying contributions, the Collection Section will Draft billing

statement/ demand letter to be signed by the Regional Vice President with attached copy

of properly filed Claims Form 1 or Claims Signature Form and will be sent to the

employer.

Moreover, the Qualitative data will be gathered through Interview Method by endorsing a

request to conduct Interview within the premises of the office.

2.6 Statistical Treatment of Data

Upon the completion of data gathering, the researcher will sort and summarize the data. It will

clearly present the information for comprehensive analysis. Moreover, the researcher will

analyze these data through charts and give an interpretation based on the analysis of the result on

the conducted Interview.


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 55

CHAPTER 3

RESULTS

This chapter will present the analysis and interpretation of data that will be used to formulate the

recommendation. The results were gathered though data extraction on Properly Filed Claims

without qualifying Contribution (Unwarranted Claims) from PhilHealth’s System through N-

Claims from Benefit Administration Section. Furthermore, In giving an extensive analysis,

interview method was also used.

From 2012 to 2018, PhilHealth has received many Unwarranted Claims. As of September 2019,

the Unwarranted Claims in Zamboanga City has accumulated to a total of P 7,162,067.00 with

673 Claims from different private employers. Out of this amount, 71 claims amounting to

P742,940.00 have already been processed and billed to employers.

Hence, the researcher will be presenting statistics of the data of Unwarranted Claims of

Employers having the most number accumulated and the probable causes of their continuous

certification of Unwarranted Claims.


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 56

3.1 Presentation

No. of Unwarranted Claims


200
180
160
140
120 No. of Unwarranted Claims
100
80
60
40
20
0
2012 2013 2014 2015 2016 2017 2018

Figure 5. Number of Unwarranted Claims per Year (2012-2018)

Figure 5 shows the number of Unwarranted Claims through the years. As can be observed, the

most number of Unwarranted Claims accumulated was during 2017 with a total number of 189,

next in line are 2018 with 136 claims, 2016 with 162 claims, 2014 with 96 claims, 2015 with 88

claims and lastly 2012 and 2013 with only 2 claims each.
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 57

To be able to further understand the data presented. A pie chart will be shown to classify the

types of employers that contribute to the number of Unwarranted Claims.

No. of Unwarranted Claims


2% 1% 1% 1%

3% Security
3% Fishing
21% Manpower
4% Marketing
School
5% Canning
Shipping
Construction
6% Restaurant
Transportation
Hotel
7% Hospital
21% Manufacturing
Others

7%

18%

Figure 6.Number of Unwarranted Claims by Private Employers

Figure 6 shows the percentage of Private Employers relative to the number of Unwarranted

Claims in Zamboanga City. The data gathered has a total number of Unwarranted Claims within
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 58

Zamboanga City of 672. Out of the total number, Security Agencies consume most part of the

pie with 22% out of 100%. Next are the Fishing Companies with 21%, Manpower Agencies with

18%, Marketing Companies and School with 7% each, Canning Companies with 6%, Shipping

Companies with 5%, 4% goes to Construction Companies, Restaurants and Transportation

Companies with 3%, Hotel with 2% and lastly Hospitals, Manufacturing Companies and Other

companies such as Retail Businesses consume 1% of the Pie.

40

35

30

25
2014
2015
20
2016
2017
15 2018

10

0
Security Fishing Manpower Marketing School

Figure 7.Number of Unwarranted Claims by employer per yer

Figure 7 summarizes the data of the Top Employers with the most number of Unwarranted

Claims through the years. For 2014 and 2015 , the Fishing Companies garnered the most number

of Claims with a total of 18 and 13 claims, respectively. For 2016, Manpower Agencies were the
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 59

top with a total of 30 claims. For 2017, Security Agencies is on top with 36 claims and lastly for

2018, the Fishing Companies had the most with 23 claims.

3.2 Analysis and Interpretation of Data

To help explain further the data presented, an interview was made to be able to understand the

different perspectives of the cause of these Unwarranted Claims. The researcher’s respondents

include the person directly involved in the processing of billing the employers for Unwarranted

Claims, the PhilHealth Accounts Management Monitoring Officer, the PhilHealth Employers

Engagement Representatives of employers with the most number of Unwarranted Claims and

those employees who requests for certification of Claims Signature Form.

According to the Management, an employer certifying the Claims Signature Form should have

knowledge of the fact that his/her employee/s should have the required 3/6 monthly premium

contributions plus at least 6 months contributions preceding the 3 months qualifying

contributions within 12 month period prior to the first day of confinement (sufficient regularity)

have been regularly remitted to PhilHealth. Otherwise, they will be billed for reimbursement of

benefits availed by the employee.


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 60

Moreover, in preventing employers from under-remitting, non-remitting and not reporting their

employees of PhilHealth premium contributions, the corporation strictly adhere to Section 18(d)

of the Revised Implementing Rules and Regulations (RIRR) of the National Health Insurance

Act of 2013 on the Payment of Premium Contributions: “The Failure of the employer to remit

the required contribution and to submit the required remittance list shall make the employer

liable for reimbursement of payment of a properly filed claim in case the concerned employee or

dependent/s avails of Program benefits, without prejudice to the imposition of other penalties as

provided for in this rules.” Thus, billing employers for every employees they under-remitted, did

not remit and reported.

In response to the query on the duration of billing the employers for non-compliance to the

policies mentioned, they first visit the employer requesting for their books since they are

mandated by the law stated in Section 15.e of the Revised Implementing Rules and Regulations

(RlRR) of the National Health Insurance Act of 2013 on the Obligations of the Employer states

that "All government and private employers are required to allow the inspection of its premises

including its books and other pertinent records.” Also, Section 221 of the same RIRR on the

Visitorial powers of PhilHealth further states that “Any representative of the Corporation as duly

authorized by the President and CEO or by the concerned Regional Vice President shall have the

power to visit, enter and inspect facilities of health care providers and employers during office

hours, unless there is a reason to believe that inspection has to be done beyond office hours, and

where applicable, secure copies of their medical, financial, and other records and data pertinent

to the claims, accreditation, premium contribution and that of their patients or employees, who

are members of the Program.” Moreover, the PhilHealth Accouns Management Monitoring
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 61

Officer shall validate the employers’ books and shall be billed when there are discrepancies to

the remittances and reporting made by the employer.

Lastly, as far as their programs are concerned, the employers are much aware of these claims

since it is their main duty to market PhilHealth and spread awareness of its programs through

Information Education Campaign (IEC) throughout the Zamboanga Peninsula. Unfortunately,

even with the conduct of Information Education Campaign; employers still encounter these

claims since they fail to validate the employees’ PhilHealth contributions. It is the Corporation’s

mandate to always reach-out to employees and give the best service it can provide. Nevertheless,

the management still experience repercussions. Since these Unwarranted Claims affect the

Corporation’s budget which will result to a loss of funds.

Moreover, According to the PhilHealth Accounts Management Monitoring Officer, these

Unwarranted Claims are a result from Under-Remitting, Non-Remitting, Non-Reporting

employers. It is already understood that once you are under these categories you are

automatically certifying Unwarranted Claims. I have also asked the respondent regarding the

figures presented and they have mentioned that recruitment agencies are the ones who are

frequently certifying these Unwarranted Claims since most of the agents they have hired are

covered either under the special laws or are not reporting to duty. With the lack of knowledge

regarding this matter, the employers just certify. Lastly, I have also asked regarding the

accessibility of the Health Care Institutions regarding the matter on the endorsement of the

Claims Signature Form and they mentioned that the HCIs have limited access to contribution

history; they are instructed to let the employed-member fill-out the form since the responsibility

of validation is held by the employer as stated in the part II of the form.


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 62

According to one of the employers, whenever the PhilHealth section of the Health Care

Institution instructs their employee to let their employer certify the document; they trust that the

system has already validated the employees’ eligibility requirement thus their non-validation of

employees’ contribution. Other employers validate their employees by contacting their

PhilHealth Accounts Management Monitoring Officer and request for clearance of certification

to the document before submitting the latter to the Health Care Institution.

Moreover, they made mention of the impact of the claims to their business, they have discussed

with the employee who availed but should not have availed the benefits and have come to an

agreement of deducting the amount of claims availed directly to his/her payroll to compensate

the reimbursement Claim of the corporation yet for those who are already not with them, their

best option is to settle it internally which will incur loss to the company.

Unfortunately, most employers are not aware of the Legal Sanctions and they are only informed

through the billing statement they receive. Hence, their inability to inform their employees of its

impact.

Furthermore, most Employers hire services of Accounting or Bookkeeping Offices. They are not

updated of their remittances and reporting to the Electronic Premium Remittance System. Hence,

they are paying but they fail to monitor their remittances.

Lastly, according to the employees’ perspective, they only know that they are being deducted of

PhilHealth Premium Contributions but they fail to monitor their remittances through their payroll

officer. Whenever they avail of PhilHealth benefits, they only follow the mandatory

requirements since they are in dire need of the benefits thus the endorsement of the Claims

Signature Form to the Head of Agency for certication. In their knowledge, it is the responsibility
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 63

of the employer to validate the documents they are certifying. Whenever they receive the signed

document, they are relieved of the fact that they are eligible for availment. Most employees are

not fully aware of the repercussions in certifying the Claims Signature Form.

CHAPTER 4

DISCUSSION

4.1 Summary

The data presented shows that the private employers with the most number of Unwarranted

Claims are Security Agencies, Fishing Companies and Manpower Agencies.

With reference to the interview conducted with the PhilHealth Accounts Management

Monitoring Officer, most of the companies that commit to the certification of Unwarranted

Claims are recruitment agencies since most of the agents they have recruited are covered under

the special laws and others are not reporting to duty. With the lack of knowledge regarding this

matter, the employers just certify. He also added that employers under the categories of Non-

Remitting and Non-Remitting are automatically non-compliant thus any certification of

employees’ Claims Signature Form will result to Unwarranted Claims.Furthermore, the Health

Care Institutions have limited access to the members’ contribution history which is the reason for
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 64

their endorsement to the employed members of Claims Signature Form. The responsibility of

validation is held by the employer.

Moreover, the management mentioned that the amount of accumulated Unwarranted Claims

have made the corporation to report a loss since the companies who have certified these claims

are not reporting and remitting. Unfortunately, the employers and its employees fail to monitor

their remittances may it be to the accounting office they have requested for services or their

payroll officers, respectively.

4.2 Recommendations

Considering the problems stated,it is vital for the Private Employers and their employees to

monitor their remittances and reporting to prevent certification of Unwarranted Claims. The

impact of this certification are dealt with by PhilHealth through billing of reimbursement of

benefits availed by their employees per PhilHealth Circular No. 0028- 2015 re: Quality

Procedures for the Recovery of Payments for Properly Filed Claims by Employed Members but

Without Qualifying Contributions (Unwarranted Claims). In doing so, will require the employer

to plan a payment scheme. Since upon certification of the Unwarranted Claims, the corporation

has the authority to demand for the recovery of the loss incurred to replenish the budget it has

allocated for Health Care Delivery.

Thus, the researcher recommends for the improvement of the different systems involved in the

process. Firstly, the Electronic Premium Remittance System should be enhanced having the
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 65

function to notify its members of their payment lapses which will highly likely reduce the non-

remitting and non-reporting employers. Also, enhancements should also be done to the eClaims

or iCares Portal having the access to view the members’ contribution history for them to advise

members of their lapses before the form will be endorsed and certified. Improving both these

systems will likely result to a reduction of the certification of Unwarranted Claims.

Furthermore, as stated by the management of PhilHealth, they are continuously conducting

Information Education Campaigns and employer visits. These activities will inform the

employers and employees of the consequences and the impact of these claims which is the first

step in the prevention of the occurrence of the accumulation of Unwarranted Claims. Moreover,

any questions or hesitations in the certification of the document can always be directed to the

PhilHealth Regional Office, Local Health Insurance Offices or their designated PhilHealth

Accounts Management Monitoring Officer for validation and confirmation. Lastly, the

employers and its employees should always monitor their premium contributions and any

observations can always be addressed to the party concerned to prevent repercussions.


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 66
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 1

REFERENCES

National Health Insurance Act of 2013

PhilHealth Circular No. 2015-016

PhilHealth Circular No. 2017-005

PhilHealth Circular No. 2015-025

Koike S, Nomura S., Okamoto E, Rahman M , Sakamoto H, Yasunaga H et al. (2018). New

Delhi: World Health Organization, Regional Office for South-east Asia. Japan Health

System Review, (8)1.

PhilHealth Circular No. 2019-0004

Revised Implementing Rules and Regulations (RIRR) of the National Health Insurance Act of

2013

PhilHealth Circular No. 2015-0028

PhilHealth Circular No. 2017- 0006


ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 2

APPENDIX
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 3

ANNEX

January 30, 2020

EDGARDO F. FAUSTINO
Acting Regional Vice President
PhilHealth Regional Office IX
BGIDC Bldg., Gov. Lim Avenue
Zamboanga City

Dear Mr. Faustino,

Greetings!

I am currently enrolled in the College of Public Administration (CPADS) – Western Mindanao


State University taking PA 244- Seminar in Governmental Studies and one of our requirements
is to conduct a research in the Public Administration discipline. Hence, I am in the process of
doing a research on “Assessing Private Employers’ Certification of Employees’
Unwarranted Claims in Zamboanga City”

In this connection, I am asking for your permission to use materials of the office as my
references and also conduct an interview within the vicinity of the office. These are needed to
strengthen my study for the drafting of the recommendation since I am doing both Qualitative
and Quantitative Research Methods.
Further, the data gathered will be kept strictly confidential and for academic purposes only. The
respondents’ participation in the study will be completely voluntary and the responses will be
anonymous.
Attached for your review is the Interview guide and Interview questions.

Your approval to the conduct of this study is highly appreciated.

Sincerely,

Aldrich C. Tan
Researcher

Noted by:

Bernard Q. Suriaga
Research Professor
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 4

INTERVIEW GUIDE

BACKGROUND

With reference to the Revised Implementing Rules and Regulations (RIRR) of the
National Health Insurance Act of 2013 regarding the payment of Premium Contributions, "The
failure of the employer to remit the required contribution and to submit the required remittance
list shall make the employer liable for reimbursement of payment of a properly filed claim in the
concerned employee or dependent/s avail of program benefits, without prejudice to the
imposition of other penalties as provided for in this rules."

The Corporation then issued PhilHealth Circular No. 0028- 2015 on the Quality Procedures for
the Recovery of Payments for Properly Filed Claims by Employed Members but Without
Qualifying Contributions (Unwarranted Claims).The coverage of the order shall apply to claims
duly paid for by PhilHealth for employee-members and/or their qualified dependents but without
qualifying contribution (unwarranted claims), whose employer is delinquent, under-remitting,
non-remitting and/or non-reporting. The order shall also apply to employers who retain services
of accounting firms which include, but not limited to payment and remittance of PhilHeallth
premiums in behalf of the employer and their employees and the submission of corresponding
reports.
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 5

Statement of the Problem Questions


1. What is the impact of these Unwarranted For PhilHealth:

Claims to PhilHealth, Private Employers and 1. What will happen if the employer certified
the Claims Signature Form or Claims Form 1
its employees? and the Member or Dependent availed of
PhilHealth Benefits?

2. How does an employer become


Delinquent, Under-remitting, non-remitting
and/or non-reporting?

3. How long until the corporation bill these


employers for non-compliance to the
aforementioned policies?

4. Are the employers and its employees


aware of this type of claims and its Legal
sanctions? How?

5. In billing these Unwarranted Claims, what


type of companies have you observed with
the most number you have billed and
processed?

For Employers:

1. Are you aware of this type of claims and


its legal sanctions?

2 How do you settle the billings forwarded


by PhilHealth?

2. What is your Payment Scheme?

For Employees:

1. Are you aware of this type of claims and


its legal sanctions?
2. What can be done to avoid Unwarranted For PhilHealth:

Claims by the corporation, employers, and 1. How do you inform the employers of the
concept of Unwarranted Claims?
ASSESSINGPHILHEALTH’S UNWARRANTED CLAIMS 6

employees? 2. Even with the conduct of Information


Education Campaign, Why do employers still
certify the CSF knowing the impact of this
claims?

For Private Employers:

1. Before certifying the CF1/CSF, How do


you validate the employees’ PhilHealth
Contributions?

2. Are you aware of the Legal Sanctions and


penalties?

3. Who processes the Claims Signature


Form/Claims Form 1 of your employees who
will be availing of PhilHealth benefits?

4. Although you have knowledge of


Unwarranted Claims, Why did you certify in
the Claims Signature Form or Claims Form
1?

For Employees:

1. Once you will be instructed by the


PhilHealth Office in a Health Care Insitution
to fill up the Claims Signature Form, what do
you do?

2. Are you monitoring your remittances?


How?
3. How does this affect the corporation’s For PhilHealth:

funds? 1. How does this affect the Corporation’s


budget for payment of claims?

2. Will the payment of Unwarranted Claims


be reverted back to the corporation’s budget?

You might also like