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Competition of IP providers

Name and Constituency of Member of Parliament
Dr Tan Wu Meng
MP for Jurong GRC
Question No. 6017 
To ask the Minister for Health (a) whether the Ministry has studied the market structure of Integrated Shield Plan (IP) providers with the Competition and Consumer Commission of Singapore to assess if exclusion of pre-existing conditions at the point of applying for new Ips has led insurers to have dominant market position over their existing policyholders; and (b) whether an insurer’s implementation of panel doctor lists will be liable to scrutiny arising from market power over existing policyholders in the context of section 47 of the Competition Act 2004.
Written Answer
1     Competition Law, including Singapore’s Competition Act 2004, typically prohibits collusion amongst industry players, or a big market player abusing its dominance to the detriment of competition.  
2     MOH has consulted the Competition and Consumer Commission of Singapore. The practice cited by the Member is unlikely to fall within the prohibited practices under the Competition Act.  There has been no evidence of collusion by insurance companies in the Integrated Shield Plan (IP) market.  There are seven insurers and the largest insurer only has around one quarter market share and does not appear to be in a dominant position with the potential for abuse that stifles competition between industry players. 
3     What the Member raised is a separate problem altogether, which is that industry players are not actively competing for the segment of customers who have pre-existing conditions. This is because their probability of claiming is higher, which means insurers will likely compensate more than what they collect in premiums. Hence, insurers are not vying for their business. The issue is adequate social security for this segment of population, not a case of a lack of competition. 
4     Where the commercial market cannot cater, the Government will have to intervene appropriately. That is why we subsidise care in public healthcare institutions and ensure that every Singaporean is covered by MediShield Life, regardless of pre-existing conditions.  Those who still cannot afford their bills can apply for MediFund, which is the ultimate safety net. 
5     Separately, the Member also asked about the practice of having a panel of preferred doctors by insurers.  This is generally also not anti-competitive because it does not restrict insurers from competing on price, product features, or benefits for policyholders. Doctors also may individually decide whether to accept the fees and other terms offered by insurers in return for joining a panel. Patients are also able to choose their doctors, taking into consideration any differences in benefits should their doctor not be on their insurer’s panel. 

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