modernizing government regulations program philippine

Modernizing Government Regulations Program

PHILIPPINE HEALTHCARE

INDUSTRY

Regulatory Review

December 2018

LIST OF ACRONYMS BHDT Bureau of Health Devices and Technology

DAP Development Academy of the Philippines

DENR Department of Environment and Natural Resources

DOH Department of Health

FDA Food and Drug Administration

FGD Focus Group Discussion

HFSRB Health Facilities and Services Regulatory Bureau

HHRDB Health Human Resource Development Bureau

HMO

IRR

Health Maintenance Organization

Implementing Rules and Regulations

KII Key Informant Interview

LGU Local Government Unit

MDG Millennium Development Goals

MGRP Modernizing Government Regulations Program

NDHS

NHIP

National Demographic and Health Survey

National Health Insurance Program

NEDA National Economic and Development Authority

PHA Philippine Health Agenda

PHIC Philippine Health Insurance Corporation

PITAHC Philippine Institute of Traditional and Alternative Health Care

RIA Regulatory Impact Analysis

SDGs Sustainable Development Goals

SDN Service Delivery Network

TAHC Traditional and Alternative Health Care

TLSM Traffic Light Score Methodology

TAT Turn Around Time

TM Traditional Medicine

UHC Universal Health Coverage

WHO World Health Organization

TABLE OF CONTENTS INTRODUCTION ........................................................................................................................................................ 1

Industry Background ............................................................................................................................................. 1 Industry Subsector Profile ................................................................................................................................. 3

Current performance of the industry ................................................................................................................ 4

Growth potential of the health industry............................................................................................................ 4

Regulatory environment of the Health Industry .................................................................................................... 5 Health Regulatory Thrust and Priorities of the Health Sector ............................................................................ 6

Regulations in the Health industry .................................................................................................................... 6

Regulatory Terminologies in the Context of the Health Industry ....................................................................... 7

Initial issues/concerns in Health Regulations .................................................................................................... 8

OBJECTIVES OF REGULATORY REVIEW ...................................................................................................................... 9

SCOPE OF THE STUDY ............................................................................................................................................... 9

Coverage: ............................................................................................................................................................. 9 Focus Areas for the Case Study ............................................................................................................................. 9

LIMITATIONS OF THE STUDY ................................................................................................................................... 10

RESEARCH QUESTIONS ........................................................................................................................................... 11

STUDY FRAMEWORK .............................................................................................................................................. 12

RESEARCH DESIGN AND METHODOLOGY................................................................................................................ 13

Sampling ............................................................................................................................................................. 13 Data Collection ................................................................................................................................................... 13 Data Management and Quality Assurance Processes .......................................................................................... 14 Data Processing and Analysis .............................................................................................................................. 14

RESULTS AND FINDINGS OF THE STUDY .................................................................................................................. 15

Results of Public Consultations ........................................................................................................................... 15 Results of the Health Industry Perception Survey Results ................................................................................... 20

PRIORITIES FOR RECOMMENDATION AND CONCLUSION ........................................................................................ 30

CASE STUDIES ..................................................................................................................................................... 31 CASE STUDY 1: RIA ON LICENSING OF BIRTHING HOMES................................................................................. 31

CASE STUDY 2: Licensing by Network .............................................................................................................. 38

VALUE STREAM MAP: STARTING A BIRTHING HOME .......................................................................................... 43 ANNEXES ................................................................................................................................................................ 46

Bibliography ....................................................................................................................................................... 46 Annex B. Data Collection Tools ............................................................................................................................... 47

BI. Draft Survey Tool ........................................................................................................................................... 47 BII. Draft KII/ FGD Tool ........................................................................................................................................ 55 Annex C. List of Respondents for Survey Method, KIIs and FGDs ......................................................................... 58

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INTRODUCTION

Industry Background

Health regulation is one of the vital components of the Philippines health system. The health system is a broad umbrella term, which includes the formalized health care systems, which are formalized; legally regulated financing; and the provision of health (medical) services, inclusive of preventive, curative and palliative interventions provided by trained health personnel. It covers health care of a specific population in a defined geographic location id being demanded, delivered, financed, organized and utilized. (WHO 2000, The World Health Report Health Systems: Improving Performance).

DOH is the lead agency and the technical authority of the Philippine Health Sector and the LGUs as the administrative authority and stewards of the local health systems. Given this, the DOH with its regulatory clusters as the regulatory management, serves as the focal, technical authority that develops and enforces standards for health services, health providers, and health devices, etc. Similarly, the local government units, under the Local Government Code of 1992, have regulatory functions as well in terms of ensuring quality and accessibility of health services given to the population. Both the DOH and LGUs perform regulatory function in the health industry for the public and private sector.

The Philippine Health Agenda (PHA) (Figure I) captures the current health industry framework, which encompasses regulatory thrusts of the Nation’s health system. The Philippine Health Agenda aims to ensure the best health outcomes for all, without socio-economic, ethnic, gender, and geographic disparities; promote health and deliver healthcare

through means that respect, value, and empower clients and patients as they interact with the health system; and protect all families especially the poor, marginalized, and vulnerable against the high costs of healthcare. It is guided by the values that all actions that shall be done by the health system shall be implemented in accordance with the values of equity, quality, efficiency, transparency, accountability, sustainability, and resilience. The PHA guarantees that health system shall implement population- and individual level interventions for all life stages that promote health and wellness, prevent and treat the triple burden of disease, delay complications, facilitate rehabilitation, and provide palliation. Improve access to health interventions through functional Service Delivery Networks and strengthening financial protection when accessing these interventions through Universal Health Insurance. Research agendas shall be aligned to the PHA goals and attainment of the SDGs; and results of the researches shall be utilized as basis for policy directions and support.



The PHA framework for attaining universal health care is the FOURmula One Plus. The FOURmula One Plus for

health now integrates five pillars (Figure II): heath financing, health service delivery, health regulation, good

governance, and the cross-cutting pillar that is performance accountability.

Figure 1: Philippine Health Agenda Framework

Figure 2: FOURmula One Plus Components

UHC

FinancingService Delivery

Regulations Governance

Performance & Accountability



Industry Subsector Profile Regulation in the health industry plays a vital role not only in influencing behavior in the industry both in the supply side and demand side but also addressing policy gaps. Mandated regulatory agencies in health can utilize regulation as a means in which to ensure Universal access of all Filipinos specifically the poor to quality and accessible healthcare services.

The main agency in charge of this work is the Department of Health (Figure III). Under it is various departments that have specific regulatory functions. The Health Facilities and Services Regulatory Bureau (HFSRB) set standards to regulate and license health facilities and services such as hospitals, clinics, birthing facilities, laboratories and other health establishments. The Bureau of Health Devices and Technology (BHDT) is responsible in the development of standards for radiation facilities and devices used in medicine, dentistry, veterinary medicine, industry, education, research, anti-crime, military, and consumer applications. The Food and Drugs Administration (FDA) formerly Bureau of Food and Drugs is in charge of four major areas: (1) Center for Drug Regulation and Research, (2) Center for Food

Regulation and Research, (3) Center for Cosmetics Regulation and Research and (4) Center for Device Regulation, BHDT is now under FDA. The Philippine Institute of Traditional and Alternative Health Care (PITAHC) mandated to develop policies, standards and guidelines for the practice of various traditional medicine (TM) modalities and the manufacture, marketing and quality control of TM products. PhilHealth regulatory mandate is on accreditation of health facilities and professionals and protect the National Health Insurance Program (NHIP). For Health personnel regulation the Philippine Regulation Commission administers, implements and enforces the standards. PRC also administers examinations to certify medical professionals and has the capacity to revoke license.

Figure 3: Organizational Structure of the DOH



Current performance of the industry

The National Demographic and Health Survey Report 2017 (NDHS) showed gradual enhancement on specific health indicators. The NDHS report is done every three years and is designed to provide indicators on fertility, fertility preferences, family planning practice, childhood mortality, maternal mortality, maternal and child health, knowledge and attitude regarding HIV/AIDS, and violence against women. The results are utilized in policy making and program planning for the attainment of Sustainable Development Goals (SDGs). Based on World Ranking in healthcare conducted by WHO, the Philippines ranked 60 behind Senegal and South Korea. This has been the country’s rank since 2000. Based on the Philippine Statistics Authority, health expenditure increased by 10.3%. Although, the bulk of the expenditure is still from out of pocket payments of households. Equitable health financing is a major indicator in measuring improvements in health systems and eventually health outcomes. The NDHS 2017 report stated that 66% of population is covered by PhilHealth. This data differs on rural and urban areas and also by type of membership. In terms of health services the Philippines met the MDG criteria on infant and child mortality but failed to accomplish the standard for maternal mortality, which at the moment is the focus of intervention and strategy in enhancing mother and child programs as well as family planning.

Giving value to patient rights, patient participation and respectful/compassionate care was the focus of the Philippine Health Systems Review WHO 2011. The Philippine Constitution of 1987 declares that The State shall protect and promote the right to health of the people and instill health consciousness among them. (Sec 15, Art II, 1987 Constitution); although there are various policies that clearly defines patients’ rights to appropriate information and choice the study states that this had been more than a concept than a practice specially for poor patients.

Growth potential of the health industry

The National Economic and Development Authority (NEDA) identifies health as a major component in the growth and development of the country. The

Ambisyon 2040 sets goals in health emphasizing the quality of healthcare is equal to long life where Filipinos can realize their full potential. This shall be done through promotion of healthy lifestyle choices, the development and utilization of new products and processes that are safer cleaner and promote good health. This is also in harmony with Goal 3 of the Sustainable Development Goals, which states that countries should ensure healthy lives and wellbeing for all and for all ages.

Present reforms in the health sector are potential for enhancement of its regulatory mechanisms in health in all levels of engagement in the health system. These include the following:

1. Continue to pursue Universal Coverage (improvement of PhilHealth core processes and regulation of health financing).

2. Integration and harmonization of regulatory mechanisms.

3. Updating the medical act of 1959 4. Updating of the Cheaper Medicines Act

(addressing issues in generic medicine) 5. Strengthening the DOH licensing Authority 6. Development of mechanism in taxing sin

products and non-essential, unhealthy food products.

7. Development of restriction of harmful marketing and targeted sales

8. Creation of a sector-wide price regulation 9. Mandating health impact assessment 10. Enhance the role of local government units

in health regulation (working in harmony with national agencies)

The crucial role of the health industry in improving the quality of life of Filipinos towards the achievement of, not only of economic, but also of social development is evident and essential. Given the gradual improvement in health reforms, addressing gaps and issues in the health sector should be amplified and purposive.

Reforms and enhancement in the regulation of the health industry is an essential component of addressing issues in the healthcare industry. Standards of healthcare and health service delivery, and pricing are part of regulatory functions of not only the Department of Health but also the local government units.



Regulatory environment of the Health Industry

The framework below best sums the regulatory direction for health (Figure IV). Regulatory clusters of the DOH, along with its sister agencies (e.g. PhilHealth, PITAHC, etc.) and the LGU, are the main governing bodies of health regulation.

Efficient regulation involves the development and maintenance of a clear regulatory structure with an adequate understanding of regulatory jurisdiction. The units of this structure are to enforce quality standards and equitable operations of medical services, facilities, human resource, devices & products, and financing. In order to do this, systems are processes for regulations are to be streamlined and harmonized amidst the different regulatory units and agencies. Further regulatory improvements involve the monitoring and evaluation of regulations towards regulatory management, regulatory quality improvement, and deregulation.

The assurance of a business-friendly and yet equitable health regulatory environment can in turn contribute to responsive, efficient, and effective regulatory reform towards better health and economic outcomes. Below is the regulatory framework of the health sector which presents the relationship of regulation on specific components and function of the health sector. It explains that regulation is an integral part of the health systems structure, the products and services it produce for the public and the processes and systems it utilize to ensure that its mandate in enhancing health outcomes for all Filipinos specially the poor is met.

Figure 4: Regulatory Framework of the Health Sector



Health Regulatory Thrust and Priorities of the Health Sector

In accordance with the PHA, the main thrust for health regulations is to ensure the safety, quality, affordability, and accessibility of health products, devices, facilities, and services, especially those commonly used by the poor. In doing so, the DOH employs two main strategies: I) the harmonization and streamlining of regulatory systems and processes, and II) the development of innovative regulatory mechanisms.

In the attempts harmonize and streamline processes and systems for regulations regulatory units of the DOH is undergoing the following:

1. The establishment of mechanisms for automation especially for data-sharing

2. Advocacy for the expansion and strengthening of DOH’s regulatory mandate

3. The review and management of conflicts of interest in regulations

4. Compliance and harmonization with ASEAN and other international standards

5. The conduct of information and education campaigns for consumers on the quality, safety, and pricing of health goods and services (e.g. through sentrong sigla, food labeling, and the publishing of prices).

In the attempts to develop innovative regulatory mechanisms, the DOH is banking on the following action points:

1. Capacity building of regular staff 2. The development of a national fee to

regulate health prices 3. Licensing by networks 4. The implementation of risk and outcome-

based regulations 5. Regulation of production and distribution of

health human resource to ensure equity, and 6. The institutionalization of HTA.

Regulations in the Health industry

The following illustrates the different agencies involved in health industry regulation as well as their respective jurisdiction. Each agency has their respective issuances pertaining to regulatory standards, requirements, and processes relative to their jurisdiction.

Table 1: Health Regulatory Agencies and their Jurisdiction

Business Process Lead Government Agencies/type of

regulation Facilities/ Devices / Medicines

Starting a business and

operating a business

Department of Health

1. Health Facilities and Services

Regulatory Bureau (certification

of need/ license to operate)

• Hospitals

• Birthing facilities (public and private)

• Health Centers

• Ambulatory Care Clinic

• TB DOTS clinic

• Dental Clinic

2. Food and Drug Administration (FDA)

• Processed food and pharmaceutical products including supplements, vaccines etc.

3. Bureau of Health Devices and Technology (BHDT)

• medical equipment’s supplies and devices

4. PITAHC • Traditional and Complementary Medicines



Business Process Lead Government Agencies/type of

regulation Facilities/ Devices / Medicines

Starting and Operating

a business

Local Government Units • Mayors permit to operate

• Sanitation permit

• Various Health ordinances

Licensing Health

human Resources

Philippine Regulation Commission

(license)

• Health personnel(doctors, nurses, midwives, dentists, veterinarians, radiologist etc

Health Human Resource Development

Bureau (HHRDB)

• Licensing HHR as a requirement in providing a license of health facilities

PhilHealth

• Accreditation of health professionals as a requirement in accreditation of the health facilities

Other certifications

that ensures quality

healthcare services

Department of Health (facility

certification)

• MilkCode Implementation

• Mother-Baby Friendly Initiative

• TB DOTS

• Anti smoking

Department of Environment and

Natural Resources (DENR)

• Environmental Compliance

Paying fees and taxes Bureau of Internal Revenue

Regulatory Terminologies in the Context of the Health Industry

There are many types of regulatory outputs identified through regulatory terminologies that may vary in context per industry. The following defines and provides nuances to these terminologies based on the current context of the health industry:

1. Licenses- Licenses are mandatory requirements for business operations. Obtaining a license translates in the full compliance to industry standards. These standards are usually set by the Department of Health. The DOH provides, for example, licenses to operate, which means that a facility is compliance with all standards needed in the conduct of business operations.

2. Accreditation- Accreditations are non-mandatory but it signifies the recognition of your business by a regulatory agency. In essence, your service is recognized by said regulatory agency and thus, can avail the benefits of recognition. For example, if a health facility is PhilHealth accredited it mean this facility is recognized by PhilHealth and thus, can avail its health financing subsidy benefits. It is non-mandatory, however, accreditation is pursued by most, if not all, health service providers and facilities given the effect of the benefits on business operations and gains.

3. Permits- Permits are usually the jurisdiction of the local government unit. It typically allows a business to operate within a local government area given that you comply with the local government’s requirements (e.g. business permit, sanitation permit).

4. Certificates- Certificates are testimonies of the accomplishment of something. It certifies compliance to a particular direction or rule of a regulatory body. For example, Food Safety certificates means that a business has accomplished all food safety requirements, e.g. they are using food safe handling methods, storage methods, etc.



Initial issues/concerns in Health Regulations

In 2010 an article in health regulation by the Asian Institute of Management presented issues and concerns in health regulation:

1. Despite the laws and standards in quality assurance and efficient investment, some health facilities remain to be substandard and fragmented: This attributes to lack of enforcement and monitoring capacity of agencies involved in the regulation process.

2. Lack of health human resource, technical capacity and staff to enforce regulation: Human resource for health and regulation of licensed facilities and monitoring these facilities for compliance needs to be addressed.

3. FDA’s failure to regulate unethical and intensive marketing practices which led to asymmetry of information where the consumer has less knowledge of the products they are availing.

Other important concerns that need to be address include:

1. Lowering cost of health care to include professional fees and medicines among others.

2. Regulating alternative, integrated and complementary medicine: To date there is mushrooming of complementary medicine providers and ensuring compliance to health standards remain to be a challenge for both facilities and health human resource.

3. Other facilities that need continued, appropriate standards development, and regulating are the hospice facilities, rehabilitation centers, and geriatric facilities.

4. Equitable health financing and high out of pocket remain an issue to date. There is also the need to reduce out of pocket expenditures and the need to revisit and potential regulate HMO’s role in financing health.

5. Need to review and enhance Health Systems and Regulatory processes like third party accreditation, public partnership with private sector and involvement of the civil society in ensuring quality and equitable health care delivery systems.



OBJECTIVES OF REGULATORY REVIEW

1. Review existing regulations with the view to streamline unnecessary rules and reduce compliance costs. Specifically, vis-à-vis objective I, the study aims to:

a. Provide a regulatory map and profile for the selected industries to understand the rationale behind each regulatory measure

b. Determine the issues confronting the private and public sector in their compliance to and enforcement of regulations, respectively; and

c. Determine the “costs and benefits” of the regulations currently governing the specific industry. 2. Propose sound, actionable, business-friendly and citizen-focused regulatory changes; specifically, through:

a. Estimating the projected benefits, compliance cost savings, and lead-time reduction arising from the proposed regulatory change; and

b. Providing a realistic assessment of the likely rate of compliance with the proposed changes in regulations

SCOPE OF THE STUDY

Coverage: Private and government health businesses will be included in the study. Regulations governing management, standards, and transactional processes will be mapped. Business experiences pertinent to health from Luzon, Visayas and Mindanao will be captured to see nuances or differences in the regulatory atmosphere vis-à-vis geographic location in terms of regulatory burden, implementation efficiency, etc. Regulator and regulatee perspectives will be captured to allow for realistic, practical, and contextually appropriate regulatory reforms that will benefit the regulated entity while ensuring that the improvements are feasible for the regulatory bodies.

Focus Areas for the Case Study

1. Health Facilities Turn Around Time for birthing facilities

The focus of this case study is to determine the economic and temporal aspects of each step in the licensing turn-around time for private and public birthing facilities. It will encompass both licensing processes for initial start-up of said facilities as well as their renewal.

2. Licensing by Service Delivery Network

Currently, there is no administrative order standardizing the licensing of facilities in the context of a health service delivery network. A health service delivery network is the juxtaposition of health workers, facilities and the capacity and capability of care providers

at different levels of care within a defined geographic location (e.g. province wide, etc.).

Licensing through this approach is the current direction of the health sector given that it is more systemic and theoretically more efficient in terms of licensing operations given that service delivery systems are regulated and not merely individual facilities and health workers. The current approach is licensing and accreditation per facility, however there is no regulation for systemic facility licensing. The case study aims to explore the potential efficiency of this approach in relation to the current approach used and its effect on public health outcomes as well as health business operations.



LIMITATIONS OF THE STUDY

Given the temporal delimitations of the study (i.e. there is only an allotted three months for data collection), mapping data may be delimited to key informant reports and secondary data from the conducted desk reviews. Key informant reports may have delimited accuracy due to recall bias amidst others. The latter may delimit the depth of data gathered with regard to the burden of regulations on businesses depending on the availability of data obtained, given that the proponents will be exploring secondary data (i.e. data not initially generated for the purpose of the research).

Further, as a result of temporal constraints, the scope of the study is delimited in terms of case study and value mapping coverage. There are two case study areas as mentioned in the previous section. In terms of health facility licensing turn-around time (TAT), the covered facilities will only involve birthing facilities from the public and private sector. Licensing TAT for both renewal and initial facilities will be included.

The priority areas for the case study are the first two aforementioned topics (i.e. Turn-around-time for birthing facility licensing and licensing thru the service delivery network. Inclusion of the third as well as the depth of the third is subject to the temporal delimitations of the research.

With regard to the value-mapping component of the research, major regulatory areas to be mapped are as follows:

• Health facility regulations of birthing facilities, which are administrative orders that outline licensing processes and requirements (i.e. AO 12s 2012 obtained from HFSRB); as specifically pertains for value mapping the birthing facility regulation requirement which has direct effect on maternal and child health, health outcomes.

Other aspects of health regulation such as:

1. Pharmacology accreditation regulations obtained from the FDA

2. Medical device and product accreditation also obtained from the FDA, specifically from the BHDT;

3. Human resource licensing standards and processes, wherein said administrative orders are obtained from HHRDB;

4. Health Financing Accreditation standards and processes obtained from PhilHealth circulars; and

5. Food safety certification standards and processes obtained from administrative orders from the FDA.

shall be part of the discussion and partial analysis but shall not be part of the value mapping because of the aforementioned limited time to develop the study.

The aforementioned components of the health industry are the regulations that relatively affect common, voluminous, and major business operations, thus they have been the primary focus of the value-mapping component. Delimiting focus will allow for more comprehensive, quality value maps given the temporal delimitations of the study; which in turn can yield more strategic regulatory recommendations offering potentially higher economic and social impact. Further, the aforementioned regulations have established standards and procedures that have been implemented for a long time and may potentially require revisiting and assessment to see points for improvements. These operations given that they affect basic needs of the people (i.e. health care, medicines, food, etc.) are also high-impact for both the consumer and the service provider or business owner/ operator.



RESEARCH QUESTIONS

The following are the formulated research questions for the study:

1. Which government agencies are included in regulating the setting up, regular operations and closing down of businesses under this industry type?

2. How do these agencies regulate this industry/sector? 3. What specific regulatory policies/laws/legal issuances govern this industry? 4. What are the rationale, purposes and intents behind these regulatory policies/laws/legal issuances? 5. Do the industry players understand the rationale behind the specific regulation and the meaning of their

compliance? 6. What regulations related to the acquisition of materials and services from suppliers, the flow of information

required by the business, the delivery of goods and services to customer, and the flow of funds to and from the business affect the industry?

7. What are the regulatory issues related to the setting up, operations and closure of businesses under this industry?

8. What is the current level of compliance? How is compliance to these regulations monitored? What are the repercussions for violators?

9. What are the “costs and benefits” of the regulations currently governing the specific industry? 10. Are there non-regulatory alternatives to the regulations that are suggested to be removed? 11. Are regulations regularly reviewed by concerned agencies? Are there improvements instituted to the ease

of doing business? 12. Should changes be introduced, what is the likelihood of compliance? 13. What benefits may be derived from the proposed changes?



STUDY FRAMEWORK

The figure below (Figure V) illustrates the framework of the study for the health industry.

Figure 5: Health Industry Study Framework

As seen in the figure, the main methodologies to further unpack the regulatory atmosphere of the health industry involve the conduct of key informant interview, focus group discussions, a survey, and a comprehensive desk review.

Various forms of health regulations from different levels of the regulatory hierarchy will be reviewed, mapped, and profiled. The study also aims to unpack the perceptions, awareness level and experiences of both the regulator side and the regulated with regard to these regulations for a holistic picture of their strengths and weaknesses better regulatory recommendations and directions.

Analysis of the obtained data shall mainly involve the conduct of RIA and TLSM so as to determine empirically the costs and benefits as well as the effects (intended or unintended) of these regulations with respect to the time and economic investment of the consumers, the public and the regulating agencies.

The outcome of which is to unpack the current level of regulatory efficiency and equitability of the health industry as well as recommended directions for its improvement. In the context of this study, regulatory efficiency has economic and temporal components for both regulatory enforcement/ implementation and compliance processes, respectively. In essence it aims to unpack the level of regulatory burden (in terms of time, resource and monetary costs), as well as movements to reduce this.



Given that the health industry attempts to balance both equitable service aside from health business sustainability and economic profit, another outcome is to describe and improve the equitability of health regulations, meaning that the services although are economically sustainable from the business owner and provider perspective, are still accessible, affordable, and quality assured for the consumers who will avail said services and products.

In essence, there is a balance between equity and efficiency as facilitated by regulations and non-regulatory alternatives.

RESEARCH DESIGN AND METHODOLOGY

Sampling

The participants included in the study are sampled purposively. Key informants and FGD participants are selected based on their expertise and experiences in either regulating or complying to health regulations. A list of possible participants for key informant interviews and FGDs are outlined in Annex D.

Survey participants are sampled purposively also, complying with the minimum number of participants prescribed by DAP (i.e. n>50). A list of different types of businesses within the health industry was outlined based on desk review (e.g. types of facilities or businesses regulated by DOH). A representative from Luzon, Visayas, and Mindanao from each type of business establishment, who is familiar with regulations and regulation compliance for business start-up, operations maintenance, and closure, respectively will serve as the survey respondents. A list of possible survey participants can be seen in Annex D. Based on the list a total sample of n=68 participants will be involved in the study.

A list of participants with contact details can also be seen in Annex D.

The selection of regulations and case study focus areas are also purposive and are determined based on the concerns and issues voiced out through public consultations with stakeholders both in the regulator (e.g. DOH, PHIC, PITAHC, etc.) and regulatee (hospital personnel, health providers, etc.) side. The focus areas are the ones with the most potential impact to health industry regulations. Issuances selected are administrative orders on health facility licensing, specific to birthing hospitals (e.g. AO 2012-0012, etc.), and administrative orders governing foreign donations. Given that there are many administrative orders pertaining to licensing, standards, and quality regulations for both the case study and value-mapping component, a better outline of these issuances will be provided after the desk review.

Data Collection Collection methods for the study will involve a comprehensive desk review of regulatory documents that provide standards, processes and other stipulations with regard to the start-up and maintenance amidst other components of health businesses.

Health regulations and policies will be profiled and reviewed through value stream mapping, which will capture temporal and economic aspects of regulatory enforcement and compliance.

Information and experiences from stakeholders of the demand and supply side will be captured through key informant interviews, FGDs, industry dialogues,

and public consultations, as well as the conduct of an industry survey. These will provide better insight on the consumer’s experience on regulatory efficiency and burdens when it comes to compliance for business operations and development. It can also provide ideas on regulatory recommendations to address the gaps and further enhance the strengths of health regulations.

Public consultations will also serve as a data quality procedure for validation of the collected data. The data collection tools as prescribed by DAP can be seen in Annex B.



Data Management and Quality

Assurance Processes

The research associates and enumerators will capture data collected through the data collection tools and templates. Qualitative data will be encoded in electronic form via MS word. Quantitative data, particularly, frequencies for stakeholder backgrounds (e.g. type of business, capitation, etc.) will be encoded in STATA 13 and/or excel sheets.

Research associates shall ensure the completeness of survey forms as well as the documentation of qualitative data obtained through the various data collection methods such as KIIs. Data quality checks by the lead consultant/ researcher will be conducted semi-monthly to further ensure data quality.

Given that quality data procedures also encompass ethical considerations, informed consent will be obtained prior to data collection. Adequate safeguards to maintain participant confidentiality and comfort will be conducted. When relevant, codes or aliases will be used to protect participant privacy. All collected data will be stored appropriately. In essence, hard copies will be kept in organized folders stored in cabinets with lock and key, and soft copies will be password protected. Data collected will be used solely for the DAP study towards the improvement of the health regulatory atmosphere.

Validation through Key Informants Interview and FGDs will also be conducted to ensure that an accurate and relatively complete picture of the health industry regulatory experience was captured by the study.

Data Processing and Analysis

Regulations, particularly those for the case studies, will mainly be analyzed through Regulatory Impact Analysis (RIA), which is a “systematic approach to critically and empirically examining the positive and negative effects of proposed and existing regulations and non-regulatory alternatives” (Organization for Economic Co-operation and Development, 2014). It generally involves the following: I) identification and description of the regulatory problem, II) conduct of the proportionate analysis of the regulatory problem and its proposed direction, III) conduct of cost-benefit

analysis of the regulatory, non-regulatory or mixed options for the regulatory problem area, and IV) the crafting of the regulatory impact statement with recommended actions.

Traffic light score method will also be used to complement the RIA analysis, ex-facto. “It provides a simple, practical and systematic qualifying tool, which recommends action courses on regulation, derived from the analysis of its real impacts” (APEC, Traffic Light Score Method Workshop, 2017).

Excel will be utilized to facilitate the conduct of RIA, especially for the cost-benefit analysis. Frequencies and other quantitative descriptors will also be generated through excel.

Qualitative data obtained through KIIs and FGDs will be documented and summarized using MS word. Thematic analysis will be used to cluster responses into themes, which can provide insight on regulatory burdens, in/efficiencies, strengths, and gaps as well as possible recommendatory directions to address these.

Regulations will also be subjected through value stream mapping, which outlines the requirements and processes for all the steps in business operations (i.e. from start-up, to maintenance, to closure). Value stream mapping can flesh out processes, which add unnecessary burden to the business owner, duplicative procedures, etc. It can also identify the time and costs allotted per requirement and procedure. Data analysis tools follow the DAP tools and templates for conducting value stream mapping, RIA and TLSM.



RESULTS AND FINDINGS OF THE STUDY

Results of Public Consultations

Key issues raised by the industry and public sector

Three public consultations were done mainly in Luzon, Visayas and Mindanao out of these consultations common issues were raised by the respondents with regards to health regulation. Major themes that surfaced during the public consultations are in line with restrictions brought about by over regulation in the health sector. Participants of the said consultations are both from the health regulatory bodies in the national levelheaded by the Department of Health and PhilHealth. National and regional agencies engage in health regulation such as the Department of Environment Natural Resources, Department of interior and Local Government were also present during the consultations. Apart from the major health regulators stakeholders in the health sector were also present to share their thoughts and experience regarding health regulation and its

implication to the services they render. These stakeholders came from different sides of the health sector starting with the pharma industry, public and private hospitals owners and administrator, representatives from the medical societies, birthing homeowners and staff and also consumers of health products and services.

The presence of various stakeholders during the consultations and focus group discussions enable the team to get inputs on a holistic level and in consideration also of geographic location these consultations were done in the three main Island groups (Luzon, Visayas and Mindanao). Results of the activities are utilized as part of the study results together with the perception survey and key informant interviews.

Table 2: Key Issues Raised by the Industry and Public Sector

INDUSTRY THEMES ISSUES1

INFORMATION EXCHANGE

• No updated, easily accessible repository or information database for policies or documents pertaining to regulatory processes and requirements

• No standard information on regulations within one agency and across agencies relevant to the health industry. (E.g. there are regional deviations on the regulatory requirements. One regional focal person will give different information on the same regulatory process)

• Difficult to get information access unless you have a “friend on the inside” or you have human resource to serve as a focal person for monitoring regulatory updates

• Informal coordination remains. Even updates are sent thru informal means (e.g. no letter heads, no provision of official documents, no face validity to the information flow)

• Inadequate consultation processes (sometimes consultations are not representative of operations and businesspeople, consultation inputs are not always integrated in the formulated regulation or policy so the stakeholders wonder how the policy stipulations were formulated)

PROBLEMATIC REGULATIONS AND ITS ENFORCEMENT

• No rationalization behind policies. Enforces forget the rationale of a regulation, which affects standard quality enforcement that is contextually appropriate to the business type and its unique geo-cultural circumstances

• Volatile, unpredictable regulations, which affect compliance (suddenly standards will change with no rationale and transition of instruction so stakeholders find it hard to comply)

1 Issues were taken from initial desk review, industry dialogues, and initial key informant interviews with health industry regulators and regulatees



• Presence of standards or requirements that increase operations costs without due relevant impact (e.g. nursing staff is based on # of beds of a facility not average occupancy rate so you incur more costs for unnecessary human resource or in the case of public hospitals, average occupancy surpasses number of beds but the standard limits acquisition of needed human resource)

• No policy manual or IIRs available to adequately ensure standard compliance for the business owners

• No continuity or alignment of regulations at different levels of the regulatory hierarchy (i.e. law should take precedent over the regulations developed but sometimes there is no alignment)

• Policy interpretation is not standard within one agency so their enforcement of requirements varies each time across different geographical areas.

• Enforcement is inadequate since there is not enough human resource and capacity for monitoring and evaluating regulations

• No sunset clauses. There are a lot of irrelevant policies created before that still applies today.

• Different agencies that regulate the same thing have different, competing standards. (E.g. LLDA have different requirements on environmental sanitation than DENR which has added costs). There is no inter-agency alignment with regulatory requirements

• Need for regulatory transparency. (What is the rationale behind the regulations? How were they developed? How were the costs computed?)

• Regulations do not take into consideration sustainability of small and local businesses and enterprises, mostly macro, transnational firms.

HINDRANCES TO BUSINESS OPERATIONS2

STARTING A BUSINESS

• Obtaining the Permit to Construct (PTC) is difficult due to regulatory requirements that are not standardized (e.g. facility design will be evaluated multiple times, sometimes by the same architect. The architect will disapprove even if the design was made by them. Further, sometimes they will approve the PTC with facility design then after construction, will ask the business owner to change aspects of the building, which incur costs)

• Overlapping requirements with different agencies that incur additional costs MAINTENANCE OF BUSINESSES

• Sudden change in standards that may not be appropriate to the business (e.g. sudden requirement of an ambulance for a birthing facility, which is not business sustainable especially for smaller scale birthing facilities)

• No standard turn-around time within and across different regulatory agencies. (TAT for PHIC reimbursements or claims processing can have a span of two weeks to 6 months)

• Additional compliance costs and administrative burdens due to attempts at automation even though the automated capacity is still inadequate (e.g. PHIC claims submission is online but the online system is not always functional this adds delays for the business owner’s compliance which may even result to the nulling of claims for reimbursement)

• Policies are released when the agency is not ready for its implementation, which hinders the compliance of business owners.

2 Hindrances in business operations have economic repercussions to business sustainability. It pertains to the economic side of the health industry. Standard quality and relevant impact pertains to true social gains as the health industry is not only a viable economic operation but it has social mandates and responsibilities for the populace



HINDRANCES IN ENSURING STANDARD QUALITY AND RELEVANT IMPACT

• Distribution of facility and business acumen of operators are not taken into consideration in regulations, which affect health service access and business sustainability. Not all health providers are business people and vice versa.

• Collaboration with private sector in terms of aiding government owned health businesses or facilities is inadequate thus health access and health resources are not fully maximized.

• Ensure appropriate fees for the standard quality of medicines, drugs and products, especially for the FDA.

• Inadequate police power of regulations that compromise quality of care. “Policies with no teeth”, which can lead to deviant businesses and corruption venues.

Apart from public consultations done in the three major Island groups focus group discussions were also done and common themes regarding regulations in health and issues were also raised as well as recommendations. There were common themes that surfaced from the activities from the feedback of stakeholders. They stated that regulatory agencies should explain to end user the rationale behind the regulation in order to provide end users guidance and entice compliance. There is also a need to standardize requirements on licensing and accreditation (different standards per region). Policy on regulation in relation to licensing should consider level of business i.e requirements for private birthing facility should not be like a requirement for a private hospital).

If the end users are informed and engage in the rationale and use of regulation it will enhance predictability that shall result in compliance with the said health regulation. There was also a suggestion to make the license to operate of the DOH for three years. Other relevant comments from the group are the following:

• Review standards that increase cost: i.e. requirement on the building of excessive number of ramps for PWDs.

• Repetition of requirements Quezon City requires Annual Physical Exam for service

providers (APE) of birthing facilities (look into regulation as income)

• Nursing staffing based on number of beds and not on based on average occupancy rate

• Open up point of care to private healthcare providers

• Bidding process should include distribution

• Tapped the private sector to contract out including facility

• Law should be precedent from any policy regulation

• Strengthen the role of Food and Drugs Administration (FDA) to support regulatory and enforcement function

• FDA to look into the calculations of variable fees

• Impact assessment that has been done by the FDA/ compare filing fees in other countries

• Most PhilHealth circulars contains no transition of instructions

• Regulation should look into small enterprise/ how to strengthen the multiply policy for these enterprises are different from big facilities and make sure that these facilities exists in the industry.

• Implement the Universal Coverage to lower the cost of medicines

• Regulators should improve transparency in all aspects



On the Case study 1: Birthing home issues for consideration:

• Laws take precedence need to Rationalise laws - Remove redundancy (proceed to Environmental Management Bureau (EMB)

• Implementing IRRs should converge toward a mother health policy- MNCHN

• A comment - Operating a birthing home is a social enterprise. No economies of scale among 2 bed facilities therefore inefficient

• Look into Midwifery law, RA7392, sec. 23 (Philhealth)- (MOA)

• RA 9288 NewBorn Screening law (Philhealth) - birth certificate requirement

• Holidays

• Separate system for Birthing homes

• OT for small Philhealth claims (birthing homes), others operate only during office weekdays

• LGU and concerned agencies: o EMB o PD 1586: Phil Environment Impact

Statement System o RA 9275: Phil Clean Water Act of

2004 o RA 6969: Toxic Substances,

Hazardous and nuclear wastes control act

o DAO 2014-02 Revised Guidelines for Accreditation of PCOs

o PD 856, Sanitation Code DoH (Is there a need for this)?

On Case study 2: Common themes regarding licensing by network

• MGRP and Universal Healthcare based on FourMula 1 Plus

o MGRP support UHC in terms of ensuring efficient health regulation

• Regulatory (licensing by network)

• Health Industry Profile o Issues Confronting the health

sector o Vision, mission, goals, core values

• Study Framework Licensing by SDN

• Health Industry Regulatory Framework

• Value stream map

What is your perception on the licensing by network?

• I license facilities by network

• Services defined and support services including programs

• Blood network/HIV network testing/ ABCT / Mental Health/ MBHFI

What should be included in the Licensing by network (LBN)?

• Network blood/pharma/ birthing facilities/ hospitals

• Health financing (ensuring financial access) and financing the system ( prioritizing benefits, paying for services)

• Human Resource System

What legal instruments are needed to implement the LBN?

• Creation of DOH administrative order (integrate to UHC law)

• Creation of ordinance/Resolution integration of licensing by network

• Utilization

• Creation of MOA DOH RO 7 with health facilities

• Payment method dependent on the timeliness of payment and payment terms with partners

• Mental health medicine procurement (bidding/ VSMC)/ Community based mental health program supported by other regions lodged initially in hospitals

• Trained doctors in district hospitals in mental health

• 40 indigent patients for 3 months (once a month shot)

• Continuity hospital in mental health LGU has specific designated hospital beds partnered with GLOBE i.e. Pinamunahan

• Start in Bugo under Bugo ILHZ Basameda / Bantayan Island /Camotes Island

• Joan Santiago to develop a concept note (legal instruments , process)

• Inclusion in the PhilHealth package

Other Comments and suggestions:

• Deployment of HR staff ( deploy 1 nurse per 5,000 pop) proposal HFIDP

• Among the provinces Cebu already established SDN lacks governing body /



management (cluster SDN because of geographical issues) with sub APEX in each coordinate (tatak PGH deployment of doctor specialist mainly anesthesiologist) upgrade facility through existence of MOA

• Governing body (LGU, PHO, PhilHelath, MLGP, DOH)

• Advocacy strategy health promotion start first with (wellness) personal family health, individual, preventive, curative.

• Include network normal time and time of disaster and emergency (quick response in disaster) same on the responders (management and services for cares)

• Substance abuse in mental health

• Monitoring and Evaluation, data collection record keeping and reporting

• Capacitate licensing officers of DOH regional office (lack of staff and training)

o Needs to check SOP of each program

o Develop SOPs

• For now individual licensing what we can do is mayor or governor take lead local health board/ individual facility payment (upgrading of health facilities)

• License look into service capacity of facilities to determine intervention and improvement in terms of systems (DOH provide general specialist) VSMM as end referral facility in the future establishment of specialty center (eye center, renal center, trauma etc.)

• Jumpstart categorization of service capacity of facilities, started in maternal health m and e for MNCHN to expand to other programs

• RHUs to be licensed for preventive programs and PhilHealth

• Through the SDN we develop standard of payment using PhilHealth/ sharing percentages develop into ordinance, DOH order (technical) at first and then ordinance by LGU to secure resource allocation and accountability of the LGUs to institutionalize the system

• More on the investment is the infrastructure (cleanliness can be done even if we have low budget)

• Problem on demoralization of health workers reason is (PhilHealth sharing) because of the disparity in the sharing schemes.

• Motivation of service incentivization on getting share from PhilHealth

• LGU case the benefit PhilHealth reimbursement does not come back to the facility and health workers

• Regularization/ Standardization of human resources (problem) some hospital staff is on job order basis

• Most participants are willing and amenable to Licensing by Network

• Back to pre-devolution centralize healthcare services

• DOH to look at how LGU share PhilHealth sharing

• Can APEX hospital be led by DOH? Direct payment sa hospital facility

What should be included in LBN?

• Incentive for performance

• Health financing / health financing mechanism for utilization sharing and policy

• Favorable LBN with APEX and sub hospitals (sharing of resources and services) ideally public hospitals

• Human Resource requirement for network of health service providers

• LNB good because there is no redundancy and resources of network is maximized (leaders management authority)

• Equitable resources sharing of PhilHealth (sharing training, incentive)

• Can we pressure

Legal Instruments to implement LBN?

• Health facilities organized and each has his own responsibility

• Can all facilities under the network follow VSMC i.e. VSMC provider to LGU Liluan (xray, provider radiologist)

• Framework itself without political issues and problems is doable and ideal can be barrier or positive

• LBN VMC will have control of the sharing of PhilHealth

If that is the case can it be palatable in other DOH retained hospital

• As long as may prototype kayang gawin / prototype can be a standard



• Role naming is not just carrying them in terms of licensing but also to identify what the critical equipment’s should be

• Human Resource as problems: companies are ready to provide outsourcing contracting i.e. radiology radio tech services

• It may be ok initially, but the ultimate goal is to be the APEX (first capacitate these hospitals but eventually they will be the one to take care of developing the hospital)

• LBN will strengthen gate keeping i.e. cardio clinic basic services/ pathologic in lower level hospital

• Standardize service package in defined facility

• VMSC accredit Family Med doctors MHO doctors i.e Siargao to capacitae Siargao hospital no doctors put doctors initially second to improve the trust and confidence to use the hospitals (family med, surgeon) evreyt ime na nadun lang tao ng VSMC

• Mag apply Sotto pero I deploy sa Siargao VMSC accredit as fellow

• Application of accreditation of fellowship is in VSMC

Results of the Health Industry Perception Survey Results

Note: A total of 72 respondents answered the perception survey on the impact of regulations on businesses for the Health industry. However, not all respondents provided responses for all questions. For each “major item”, the sample size of respondents is indicated.

Description of Respondents

Types of Businesses. A total of 71 respondents provided information on the type of business they own. Majority of the business types are corporations (41 respondents; 57.7%), while 20 are sole proprietorships (28.2%).

Table 3: Types of Businesses

Type of Business Frequency

Corporation 41

Sole proprietorship 20

Partnership 3

Government 1

Medical 1

Non-stock, Non-profit organization 2

NGO 1

Pharmaceutical Industry Association 1



Figure 6: Types of Businesses

Figure 7: Location of Businesses

Business Locations. Majority of business owners are located in Luzon (63.9%. 46 respondents out of 72). 19.4% (14 respondents) are located in Mindanao; and 9.7% (7 respondents) are located in Visayas. 6.9% (5 respondents) have multiple locations all over the country.

Type of Business by Capitalization. Of the 70 respondents that provided their business capitalization, 18 businesses qualify as microbusinesses with a capitalization of up to Php 3, 000, 000; 12 are small businesses with a capitalization of Php 3,000,001 to Php 15, 000,000; 18 are medium businesses with a capitalization of Php 15, 000, 0001 to 100, 000, 000; and 22 are large businesses with a capitalization of Php 100, 000, 001 and above.

Table 4: Type of Business by Capitalization

Frequency

Micro 18

Small 12

Medium 18

Large 22



Figure 8: Type of Business by Capitalization

Of the 71 respondents who provided an answer, majority of the businesses have been operating for more than 10 years (49 respondents), 29.6% have been operational for two to 10 years (21 respondents), and 1.4% (one respondent) reported being operational for less than two years.

Figure 9: Length of Operation

18

12

18

22

Micro Small Medium Large

Type of Business by Capitalization

Frequency



Interaction with Regulatory Agencies

Listed below are the regulatory agencies, which businesses deal with the most. The agencies are arranged in terms of importance to the business owners (n=69).

1. DOH 2. PHIC 3. FDA 4. BIR 5. LGU 6. DENR 7. City/ Provincial Health

Offices 8. PRC 9. PDEA 10. BFP

11. LLDA 12. DSWD 13. SEC 14. DTI 15. BFAD 16. BOQ 17. BOC 18. DOLE 19. National Privacy

Commission 20. CDA

21. SSS 22. Pag-ibig 23. PNRI 24. BPLO 25. Mapecon 26. X-ray regulatory board 27. Newborn screening

center 28. NPC

Top 10 agencies are cross-cutting amidst all businesses. Those listed below were mentioned by only approximately 15% of the respondents. The agencies from 18 and onwards were only mentioned by one business and are listed as the “least impactful” agency dealt with.

Reasons for Interaction. Top 5 reasons for interaction with said agencies are as follows I) Registration and renewal of permits (n=68 out of 72 respondents), II) Inspection of products/ premises (n=56), III) accreditation of products/ services/ personnel, etc. (n=54), IV) provision of required regulatory information (n-54), and V) remittance of government shares (n=40).

Interaction Frequency

Table 5: Number of Businesses who Reported their Interaction Frequency per Year by Type of Interaction

Interaction frequency per Year Inspection/ Audit Information Submission

Once a year 8 respondents 33 respondents

Twice/ Two to three times a year 9 7

More than twice/ 4-6 times a year 50 11

More than 6 times a year -- 21

Not applicable 3 --

Registration and renewal of permits

Inspection of products/ premises

Accreditation

Provision of regulatory

informationRemittance

Figure 10: Major Reasons for Regulatory Agency Interaction



Figure 11: Perception of the Respondents on the Interaction with the Regulatory Agents

As seen in the figure above, major issues with regard to regulations is with regard to consultation and mutual

regulation understanding, which is affected by the volatility and unpredictability of policies. Lack of consultation can

lead to regulations that are dissonant with industry context, which delimits rationale understanding an in turn affects

compliance efficiency. Lack of mutual understanding can also be due to untimely announcements of changes,

rendering the regulations unpredictable, which again influences compliance efficiency and ease. Interaction with the

regulatory agencies seems to be imbued with communication and information exchange issues. Perceptions on

Regulatory information will be discussed in the succeeding section.

Perception on Regulation Information

With regard to regulation awareness, 69 respondents provided answers. 20 of the respondents are very familiar with

industry regulations, 28 reported being familiar with the regulations, and 21 reported being only moderately familiar

with said regulations.

Industry opinion is considered

during regulation development

Regulation requirements

are clearly communicated

Timely announcement

of regulation changes Regulation rationale is

clearly communicated

30%

41%

29%

REPORTED REGULATION FAMILIARITY OF RESPONDENTS

Moderate Familiar Very Familiar

Figure 12: Regulation Familiarity of Respondents



Table 6: Perceptions on Regulation Information

Information Characteristic

Agree Neither Agree nor

Disagree

Disagree

Information is readily available 47 6 18

Regulation rationale are easy to understand 42 14 14

Businesses are aware of the citizen’s charter 37 19 14

Regulatory agencies are aware of the citizen’s charter 37 23 16

Answers are clearly provided to queries of businesses 19 23 28

Regulatory agencies respond within the indicated time in the

citizen’s charter

26 23 22

More respondents have positive perceptions on the nature of the regulation information in terms of their availability,

timeliness, etc. although the increase is marginal relative to the number of respondents who disagree or have

relatively negative perceptions and those who have neutral perceptions.

Regulation Impact and Compliance

Table 7: Types of Regulations and their Perceived Impact

IMPACT

TYPE OF REGULATION

TAX CUSTOMS INFRA TECH

HEALTH

&

SAFETY

EMPLOYMENT ENV. ADMIN.

LOW (Business as

Usual)

3 11 8 8 4 2 3 4

MODERATE (Non-

compliance may

lead to penalties

25 8 20 25 17 6 26 17

MAJOR (May lead

to end of

business)

40 18 41 26 48 7 38 47

NA 2 33 -- 10 1 -- 3 2

All regulations, when considered applicable to the context of the business, have major impact since failure to comply

may lead to the end of the business.

Table 8: Ease of Compliance

COMPLIANCE

TYPE OF REGULATION

TAX CUSTOMS INFRA TECH HEALTH &

SAFETY EMPLOYMENT ENV. ADMIN.

EASY 43 21 29 30 46 11 29 47

HARD 26 34 38 31 21 2 35 19

More respondents perceive tax, health, employment, and administrative regulations as easy to comply with, while

customs, infrastructure, technological, and environmental regulations as difficult to comply with. Difficult

regulations pertain to infrastructure or facility requirements, human resource requirements, fire safety

requirements, and environmental requirements about safe disposal.



Major issues due to difficulty of regulation compliance is due to policy volatility or unpredictability (i.e. there are fast

changes, which the owners have difficulty tracking and the regulator end has insufficient capacity to implement

these changes as well). There is also limited human resource to monitor and implement regulations, which creates

backlogs and makes compliance difficult. Thus, turn-around-time serves as a major issue, which hinders compliance.

Further, there are additional requirements, which business owners deem unnecessary, laborious or hinder business

efficiency. There is also inter-agency overlap of requirements, which makes compliance redundant, confusing or

laborious. These are made even more difficult due to the inaccessibility of agencies (e.g. because there is limited

human resource to tend to the needs of the business owners as well the location of some agencies).

All these issues lead to the predominant perception (33 out of 63 respondents) that regulations are inadequately

enforced.

Information Submission Compliance. One of the major trends in addressing administrative burden is through

automation (i.e. the online transactions for regulatory information). Based on the survey, majority of the participants

utilize online forms, granted that they are available (Lack of online forms is the main reason why not all respondents

utilize this).

Figure 14: Usage of Online Forms

Majority of the respondents (77%; 54 out of 70) claimed that online forms (assuming that online portals are fully

functional and that hybrid models (i.e. those that have online portals but still require hardcopies) are highly effective

since they reduce costs and make transactions smoother and easier. Provision of data also becomes easier across

agencies.

73%

27%

Usage of Online Forms

Yes

No

Unpredictable Policies

Backlog dueto limited human resource for

regulation enforcement

Turn-around-time issues

Unnecessary requirements

Inter-agency overlap Inaccessible agencies

Figure 13: Reasons for Difficult Compliance



Effectiveness is reduced however if the agency does not have the sufficient capacity to implement, maintain and

sustain the online forms or if they have hybrid models which makes the administrative burdens redundant.

Figure 15: Perceived Effectiveness of Online Forms

Cost of Compliance

There is a lot of variation in the reported estimate for the time spent annually (total workdays per year) in complying

with regulations. The reported mode (n=12 out of 56) is 30 days. The range of estimated working days for regulatory

compliance is from 3 days to 365 days. Average is 88. 64 days.

77%

23%

Perceived Effectiveness of Online Forms

Effetive

Ineffective

No sustainable automation

capacity

Software or technological

glitches

Hybrid models

Unsure if documents are received and

checked

Figure 16: Major Reasons for Reduced Effectiveness of Online Forms



Figure 17: Perceptions on Regulatory Compliance Costs

Majority of the participants (n=38) agree that regulatory breakdowns are clear and relatively transparent. They (n=31) also perceive the costs as reasonable. 21 out of 67 respondents claim that there are other fees collected for regulation compliance other than what is published, while the rest claimed they have not encountered such fees. There was no mention on what these fees are and the rationale behind them.

Figure 18: Perception on Overall Regulatory Environment

61% of the respondents (39 out of 64) claimed that the overall regulatory environment is fairly regulated; 27% (17) claimed it is over regulated, while 12% (n=8) claim that it is weakly regulated.

Majority claim that regulations are necessary, relevant, and beneficial to business (i.e. its benefits outweigh its cons) since it provides standards and quality assurance measures, however regulatory consistency amidst regulatory agencies can be improved.

12%

61%

27%

Perception on Overall Regulatory Environment

Weakly regulated

Fairly regulated

Over reglated



Figure 19: Perceptions on Regulations

Other issues and rooms for improvement are as follows: most regulations are not conducive to business expansion and growth, especially due to overregulation, duplication of labor, unpredictable policies, long turn-around-time, and inter-agency overlap. It is recommended by the respondents that although regulations are highly important given that they assure and certify the quality of a business, which aids the business become trust worthy for consumers, it has to reduce the burden of compliance and enhance its efficiency.

Nevertheless, majority of the respondents claim that regulations are highly beneficial to the health industry.

Figure 20: Perceived Effect of Regulation to Industry

75%

25%

PERCEIVED EFFECT OF REGULATION TO INDUSTRY

Beneficial Not Beneficial



PRIORITIES FOR RECOMMENDATION AND CONCLUSION

The results of the study indicates the need to revisit regulations for the health industry and utilize the use of RIA in other aspect of the health industry not included in the study. Example of this is the regulation of the pharmaceutical industry. Regulation that covers health maintenance organizations and also regulation regarding the use of alternative medical services and medicines among other.

Current developments in the health sector specifically on the Implementation of the Universal Healthcare law should be considered in rationalizing and developing additional policies in regulation as well as revisions of existing regulation that are repetitive and costly. There is also a need for comprehensive and further study on health sector regulations and its implication to the goal of the Department of Health as the lead steward of Health of the country in achieving its primary goal of enhancing health outcomes and improvement in the quality of life of all Filipinos.

Looking at the results of the consultations and perception survey priorities for recommendation were formulated. On the regulatory aspect, one is that there is a need to develop policy on first revision of administrative order (AO) & Circular on birthing homes towards deregulation (i.e. PHIC becomes M&E, LGU for continuous M&E) and second is that there is a need to Develop an administrative order (AO) & UHC IRR for Systems/Network accreditation.

Also, among the recommendation is to work on nonregulatory alternatives to entice compliance and also answer the quality and income generation aspect of the regulation. One way is through capacitation &

education campaigns for service providers. Another is to develop a prestige mechanism to ensure compliance and essential in assuring improvement in the system is to strengthen automation capacity and support for service provider through system enhancement and development of appropriate IT infrastructure and communication strategy. A mixed approach in regulation and non-regulation is also recommended. Starting with the combination of policy development (in phases) and non-regulatory initiatives as presented above.

The recommended regulations are aligned based on the findings of all collection and analysis methods from VSM to RIA, from consultations to the survey. Undergoing the proposed recommendations have policy coherence: both bank on UHC Law towards social and economic efficiency. Both are also aligned with the recently passed UHC Law as well as other international commitments



CASE STUDIES

CASE STUDY 1: RIA ON LICENSING OF BIRTHING HOMES

Title: AO 0012 s2012 Annex C: Licensing Requirements for Birthing Homes Type of regulation: AO Lead department or agency: DOH Stage: Existing Regulation for Review Key Contents of Regulation: The AO stipulates licensing requirements for both private and public birthing homes. Licensing requirements provide standards for the following:

1. Service capability 2. Personnel requirements 3. Necessary equipment and instruments 4. Infrastructure (i.e. the physical facility) 5. Health care waste management

DOH, specifically the Health Facilities and Service Regulatory Bureau (HFSRB) is tasked to monitor the compliance to this issuance. Lack of compliance can lead to non-licensing of the facility, which prevents business operations. Non-compliance during continuous monitoring processes can also lead to closure of facility or inability to continue operations PROBLEM:

Inadequately distributed number of continuously compliant birthing facilities, which leads to gaps in the provision of quality maternal health care

Possible causes:

• Cumbersome, inappropriate licensing requirements which vary in interpretation amidst the regulatory institutions and their respective levels

• Lack of policy enforcement, further weakened by inadequate M&E initiatives of the regulatory agents

• Inappropriate licensing considerations done by regulator

Problem Analysis: Rationale for Improvement

Motherhood is a beautiful experience, which is plagued by various health complications and risks-- complications with their respective social and economic burdens for both the household and the community. Complications for both the mother and her child due to inadequate care can lead to greater, riskier and more severe morbidities, and even mortalities. Both can incur debilitating hospitalization costs and burial costs, respectively. Maternal and child morbidities and mortalities during pregnancy can have physical, mental and psycho-social effects

on the family, which in turn affects community participation in terms of social relations and economic productivity.

Given the effects of proper maternal and child care to social and economic development, addressing this public health issues had been a global thrust as reflected in the SDGs (Goal 3, specifically 3.1).

Access to proper medical attention and hygienic conditions during delivery can reduce the risk of complications and infections that may lead to death or serious illness for the mother and/or baby (Van Lerberghe and De Brouwere 2001; WHO 2006). This finding has been translated through action, initially, via former Secretary Ona’s thrust to enhance facility capacity, inclusive of staff competency, via prompting facility-based delivery (FBD) attended by a skilled birth attendant (SBA). The national target is to achieve 100% FBD.

Maternal mortality still remains an issue in the Philippines, as reflected in its inability to meet the MDG stipulation on maternal health, as well as national targets, including FBD and SBA targets. There



are also regional discrepancies with FBDs, which in turn can have its effect on maternal mortality. Currently, only 78% of live births are facility-based, wherein 84% is attended by a SBA although these figures have been relatively, statistically plateauing for the last three years. This figure, although high nationally, have great fluctuations regionally and geographically amidst other demographic characteristics, wherein urban areas have higher percentages compared to rural ones; and NCR has the highest percentage compared to ARMM, which has the lowest. Further, higher income mothers have a higher percentage of undergoing FBDs attended by SBAs compared to lower income mothers (NDHS, 2017).

Factors that contribute to these discrepancies is a matter of health literacy influenced by socio-demographic characteristics, as well as barriers to access and affordability. There is an inadequately distributed number of birthing facilities who meet and continuously comply with quality standard. Licensing of facilities is part of DOH’s mandate, while its accreditation is dependent on PHIC- both regulatory agents for quality facility capacity. There is a need to harmonize and streamline birthing facility licensing to ensure there are adequate facilities with its respective competent providers, and that these facilities maintain quality service provision and business operations.

To surmise, despite the importance of facility-based delivery, not all mothers are able to avail of quality facility-based delivery given the inadequacy of facilities compliant to licensing standards. Inability for facilities to get licensed not only have economic costs in terms of hampering business operations, but also social costs given its impact on maternal and infant health.

Licensing issues for facilities include, but are not delimited to: I) Difficult licensing processes and procedures, and II) varying interpretations and enforcement of licensing standards at different levels of the regulatory institutions.

Result of Proportionate Analysis

Description of Groups Affected & their Respective Impacts

• Consumers, the family, and the community. Improved access to quality maternal and neonatal care, wherein quality involves the respectful encounters with proficient service

providers offering contextually appropriate care.

• Regulatory Institution.

• DOH streamlines processes, assures quality care, lowers maternal mortality, service in the un-served

• PHIC. Accredited facilities, more payment for services, reduces out of pocket,

• LGU. As program implementers, they are able to have good health outcomes for the populace which it serves. Also allows for sustained business for LGU-ran facilities

• Service Provider. Added income, ability to conduct business and become economically productive

Description of Impact

• Reduction of maternal mortality costs and burdens on the family and community

• Increase economic productivity of birthing facilities

• Reduction of out of pocket expenditures due to increased number of accredited facilities

• Quality care guaranteed

Level III: Quantification of Effects

• Effects of inadequate policy will contribute to stagnation in maternal health outcomes, which have social and economic costs on the individual, family, and community level.

• Ensuring quality care through appropriate birthing facility licensing can limit hospitalization costs, opportunity costs, etc. due to maternal and child morbidities and mortalities due to a lack of access to quality birthing facilities.

Level IV: Partial Monetizing

• Direct Licensing Costs: transport, food, greater hospitalization costs due to more severe morbidities, mortality

costs, etc.

• Indirect Licensing Costs: Opportunity cost for the consumer and the service provider. The latter is due to delayed, halted or discontinued business operations.

• Days allotted for Licensing Compliance due to cumbersome licensing



requirements can also increase indirect costs.

Level V: Full Monetizing

• Impact costs to families with maternal mortalities and more severe morbidities are debilitating in nature. WHO estimates that 40% of expendable income is spent on hospitalization

related to maternal care. Household operations are hindered, which impacts not only the patient but also the patient’s caregivers.

• Impact costs to Community: Hindered economic development due to halted businesses as well as incapacity of consumer to economically and socially participate due to illness.

Table 9: Proportionate Analysis

CRITERIA SCALE RATING VALUE

Importance/Urgency Very High 5 Significant importance with ample groups affected

Impact Medium 3 Major (60%)

Level of Certainty High 4 Highly Certain

Time Available for Policy Development High 4 More than adequate

TOTAL High 16 CONDUCT COMPLETE RIA

Objective: To increase the number of continuously compliant birthing home facilities providing quality maternal care for mothers within three years

Specifically:

• To streamline licensing processes for public and private birthing facilities within three years via deregulation

• To improve synchronization of licensing regulations by regulatory institutions within three years

Policy Direction Rationale:

• Deregulate and render PHIC and LGU as main enforcers so as to ensure true quality of service, remove duplication of labor and regulations, as well as standardize process

o Cost-effective o Logical or coherent o Holistic

Identification of Alternatives

Option 1: Do Nothing

• Lack of quality facilities and service providers that can cater to mothers’ and infants’ needs

• Hindrance to business operations of lying-in facilities

• Continuation of varying standards and cumbersome licensing processes

Option 2 non regulatory option:

• Voluntary Education and Capacitation Initiatives o Capacitate and educate service providers with regard to licensing and accreditation sustainability

for continuous business operations

• Prestige mechanisms towards facility compliance o Education and capacitation as well as voluntary incentive mechanisms are cost-effective initiatives

that cater to behavioral change which can affect licensing compliance

Option 3: Regulatory Option



• Revise existing administrative order in terms of: o Streamlining processes through inter-agency and intra-agency coordination and synchronization o Enhancing coordination mechanisms within regulatory institutions o Enhance police power of policy o Ensure appropriate licensing considerations to truly affect health outcomes o Capacitation and augmentation of PHIC & LGU personnel into becoming regulatory managers o Enhance Policy M&E capacity of regulatory agents

• Policy improvement institutionalizes enforcement initiatives

Option 4: Mixed

• Combination of Regulatory and Non-regulatory Initiatives previously mentioned

• More cost-effective, caters to awareness and capacities of various players and stakeholders, which increases compliance while said initiatives are cemented and enforced/ institutionalized thru policy

Evaluation of Alternatives

Table 10: Status Quo costs: Narrative

Cost of Provider Cost of Consumer Cost of Regulator

Naturally occurring cost for start-up and

licensing compliance to varying

requirements

• 1,500,000 start-up cost

• Compliance to unnecessary

requirement can go up to 1,280,000

MMR Costs of illness:

• 0.46 million dollars for

maternal deaths

• 7.36 million maternal

morbidity

• Cost of burial

• Economic

halting/Productivity Loss

=Loss of 51 million per year

Government spending on

illness

Loss of investment come

closing of facility due to lack of

business acumen

234.6 dollars/ person/facility

due to inadequate facility care

Table 11: Mixed Approach Costs: Approach


Naturally occurring cost

(Savings of 1,280,000 due to reduction

of unnecessary requirements)

NO INCREMENTAL COST Twenty million budget for

additional enforcement

operations

Administrative burden cost: (1,500 unit

cost per report) for financial and

business sustainability annually

1,800,000 for additional

Administration costs



Table 12: Cost Estimates

Status Quo Mixed Approach

Administrative Burden 2,500 Negligible cost: 1,000 unit cost

Substantive Compliance Cost

• Start up: 1,500,000

• Yearly licensing renewal: 26,000

• Compliance to additional non-

standard requirements: 1,280,000

Administration & Enforcement

Cost

• Enforcement: ₱1,500,000

• Admin: ₱25,000,000

• Enforcement Cost: Twenty

million (initial)

• Admin Cost: 250,000

TOTAL 115,956,000 18,081,000

Table 13: Cost and Benefits Analysis: Narrative

STATUS

QUO MIXED APPROACH

Benefit 1 • Continuous and increased cost savings due to illness prevention and burial

costs

• Continued economic productivity

Benefit 2

• Added sustainable income for providers

• Savings due to removal of non-standard, additional unnecessary

requirements

• Reduction in licensing compliance costs to standard requirements

Benefit 3 • More cost-effective quality assurance operations for regulators

• Preventive benefits and decrease in hospitalization subsidy cost for

increased maternal morbidity and mortality

Table 14: Benefits: Estimates

STATUS QUO MIXED APPROACH

Benefit 1 17,280,000,000 1, 280,000 savings/ facility

Reduction in start up cost

Benefit 2 Non-quantified 4.97 dollars/person/ year

122 dollars/live birth per year

Benefit 3 40,805,600 51 million productivity savings per year

TOTAL 17,204,619,600 17,281,305,000



Table 15: Benefits: Cost Benefit Analysis


Social Discount Rate 10% 10%

NPV 7,401,953,737 76,235,412,538

AV 1,952,616,749 12,406,962,318

Assumptions/ Caveats for CBA:

No attributable probability of policy effect to delimit corresponding change in maternal mortality and its reduced costs. (i.e. there are parallel interventions that may contribute to the benefit, the policy being one of them, however the latter cannot be isolated.

Quantification of cost of illness was lifted from literature covering low income countries such as Africa, conditions may differ in the Philippines. Use of these estimates are due to delimitations in the

information available. Costs and benefits are dynamic thru the 10-year period. Refer to excel sheet on CBA for better breakdowns of costs and benefits.

Interpretation:

Although both initiatives have positive NPVs, which mean both are economically viable options, mixed approach implementation has higher yield and is more cost-effective than the existing regulatory environment.

Stakeholders Analysis:

The result of the stakeholders analysis indicates that that the major implementers in the management and regulation of birthing facilities as a service provider such as the Department of Health, PhilHealth, LGHUs, PRC and the midwives societies should be manage closely in terms of policy making and operationalization of these policies. DENR on its part as a national agency involved in the regulation of environmental safety should be complied by stakeholders. As for the NGS’s/CSOs and mothers and their families information with regards to the services and privileges as well as the responsibilities of the consumers should always be in p[lace and updated.

Figure 21: Stakeholders Analysis



Consultative Mechanism:

As for the consultative mechanism the team conducted key informant interviews with policy makers in DOH and PhilHealth and results of the consultations were presented to stakeholders and policy makers. Below is the table of the consultation and stakeholders of the activity.

Table 16: Consultation Mechanism

Enforcement, Compliance, and Monitoring Mechanism

Enforcement Agency:

• PHIC shall serve as the overall enforcement head.

• Collaborations with LGU as co-regulators can be considered in the M&E plan of the policy for continuing quality control and enforcer HR augmentation

Policy in Monitoring and Evaluation:

• A Policy M&E manual will be developed to identify and operationalize indicators

• A randomly sampled 10% of the facilities will be monitored by PHIC per year, all facilities within a region shall annually be inspected by LGU

• Mid-term assessment after 3 years, full policy evaluation after 5 years (outsourced)

• Monitoring levels: national, regional, local (from LGU)

Compliance Mechanism:

• Non-provision or removal of license

• Prestige incentives for motivation: E.g. Best birthing homes, Best LGU health quality

Process

• Conduct of consultations and policy refinement

• Release of circulars, relevant issuances at national, regional and local levels

• Conduct of policy information forums for stakeholders

• Conduct of orientations for regulators & regulatees

• Annual monitoring

• Evaluation after 5-years

• Conduct of automation capacitation initiative



CASE STUDY 2: Licensing by Network

Title: Public Health Service Delivery Accreditation Type of regulation: UHC IRR, then AO & AO IRR Lead department or agency: DOH Stage: To be developed, NO policy yet

PROBLEM

Lack of integration towards a more effective health care system

Problem Analysis/ Rationale for improvement:

Provision of the UHC Law defines the network of health facilities that shall render health services to specified clients and in different levels of care depending on the case of the patient/client. Health facilities shall be the main provider of care per catchment area. The Administrative Order on Service Delivery Network “AO 2014-0046 Designing the SDN for Universal Health Care” (UHC ) provides guidelines for the establishment of SDN to efficiently and effectively cover the needs of priority groups and the general population for UHC programs and projects. As support another AO was developed “AO 2017 – 0014 Framework for Redefining Service Delivery Network” which provides new guidelines on the establishment of SDN. The function and services of public and private health facilities is a major component of the referral system function of the service delivery network.

The development of SDN is a response to the fragmented health service delivery system and facility. Service delivery network, as defined by the Responsible Parenthood and Reproductive Health (RPRH) Law, refers to the network of health facilities and providers within the province- or city-wide health system, offering core packages of health care services in an integrated and coordinated manner. Furthermore, it specified that service delivery network should be established and organized by LGUs in coordination with DOH to effectively deliver reproductive health care services to priority population.

Rule 5 of the Implementing Rules and Regulations (IRR) states that the Department of Health shall develop specific guidelines for these sections: (a) identifying needs of the priority population within the SDN (5.10); (b) mapping the available facilities in the SDN (5.09); (c) designating of population to facilities

(5.11); and (d) monitoring and evaluation of the SDN (5.20).

Also, quality health service provision from health facilities are part of international commitments on meeting the sustainable development goals. It is in this context that improving policy on licensing of health facilities can contribute to business continuity, competitiveness, and economic productivity of the health care service providers and consumers through illness reduction for the latter.

Proportionate Analysis

Description of Groups Affected & their Respective Impacts

• Consumers, the family, and the community. Improved access to quality health care, wherein quality involves the respectful encounters with proficient service providers offering contextually appropriate care.

• Regulatory Institution.

• DOH streamlines processes, assures quality care, lowers health morbidities and mortality, service in the un-served

• PHIC. Accredited facilities, more payment for services, reduces out of pocket,

• LGU. As program implementers, they are able to have good health outcomes for the populace which it serves. Also allows for sustained business for LGU-ran facilities

• Service Provider. Added income, ability to conduct business and become economically productive

Description of Impact

• Reduction of illness costs and burdens on the family and community

• Increase economic productivity of all health facilities from all levels



• Reduction of out of pocket expenditures due to increased number of accredited facilities

• Addresses HR and other logistical resource concerns due to better resource pooling at a systems level

• Quality care guaranteed

Level III: Quantification of Effects

• Effects of inadequate policy will contribute to stagnation in health outcomes, which have social and economic costs on the individual, family, and community level.

• Ensuring quality care through appropriate public health network licensing can limit hospitalization costs, opportunity costs, etc. due to morbidities and mortalities due to a lack of access to quality facilities and providers

Level IV: Partial Monetizing

• Direct Licensing Costs: transport, food, greater hospitalization costs due to

more severe morbidities, mortality costs, etc.

• Indirect Licensing Costs: Opportunity cost for the consumer and the service provider. The latter is due to delayed, halted or discontinued business operations.

• Days allotted for Licensing Compliance due to cumbersome licensing requirements can also increase indirect costs.

Level V: Full Monetizing

• Impact costs to families with health afflictions and other morbidities that can be debilitating in nature. Household operations are hindered, which impacts not only the patient but also the patient’s caregivers.

• Impact costs to Community: Hindered economic development due to halted businesses as well as incapacity of consumer to economically and socially participate due to illness.

Objective: To develop systems for an integrated health care delivery network accreditation

The figure below presents the Universal; Health Care Integration (UHC) between levels of care from the basic or primary up to the unified health network based on provinces and cities.

Integration

Primary Care

Hospital

ILHZ Municipal & Province/ City wide

Unified Health Network Province

/City

Figure 22: Universal Health Care Integration



Identification of Alternatives

Option 1: Do Nothing

• Lack of quality facilities and service providers that can cater to needs and inequitable access

• Hindrance to business operations of health facilities and providers

• Continuation of varying standards and cumbersome accreditation processes and understanding of the policy

• Crowding at various levels of care due to inadequate resources and gatekeeping failure

Option 2: Non-Regulatory Option

• Voluntary Education and Capacitation Initiatives o Capacitate and educate service providers with regard to licensing and accreditation sustainability

for continuous business operations

• Prestige mechanisms towards facility compliance o Education and capacitation as well as voluntary incentive mechanisms are cost-effective initiatives

that cater to behavioral change which can affect licensing compliance

Option 3: Regulatory Option

• Develop UHC Law IRR: Local Health Systems Integration and systems accreditation

• Policy development for the systems integration and systems accreditation for a more efficient and effective health care delivery systems: non fragmented, access, quality and safety and institutionalizes enforcement initiatives

Option 4 Mixed Approach

• Combination of Regulatory and Non-regulatory Initiatives previously mentioned

• More cost-effective, caters to awareness and capacities of various players and stakeholders, which increases compliance while said initiatives are cemented and enforced/ institutionalized thru policy

o Reduce cost: Money, HR and Systems o Initial cost: develop integration and hubs: Information systems, Capacity Building, local policy

development and modeling/ piloting/Advance implementation of UHC

Evaluation of Alternatives

Table 17: Status Quo: Cost Narrative


Individual investments for both

Licensing and Accreditation

DOH and LGU costs: Management

of health care delivery and ensuring

access and equity

Incurred cost for medical and non-medical

interventions

DOH and LGU cost



Table 18: Mixed Approach: Cost Narrative


Systems Integration strat up costs:

Local policy, Systems enhancement,

CB and Communication

Access to Medical Care Province wide/citywide

management

Unified systems cost Paid services especially for the poor and

marginalized sector

Navigating, Coordinating cost Gatekeeping

Evaluation Alternative: Leyte Model

Table 19: Cost Estimates


Administrative Burden 350,000.00 800,000.00

Substantive Compliance Cost 2,550,000.00 500,000.00

Administration & Enforcement Cost 3,825,000.00 500,000.00

TOTAL 6,375,000.00 1,800,000.00

Table 20: Benefits

STATUS QUO MIXED APPROACH

Benefit 1 Continuous and increased cost savings due to illness prevention and burial costs, continued economic productivity

Benefit 2

• Added sustainable income for providers

• Savings due to removal of non-standard, additional unnecessary requirements

• Reduction in licensing and accreditation compliance costs to standard requirements

Benefit 3 • More cost-effective quality assurance operations for regulators

• Preventive benefits and decrease in hospitalization subsidy cost for increased morbidity and mortality, Gatekeeping complied



Table 21: Consultation Mechanism

Consultation Strategy

• Conduct of key informant interviews with policy makers in DOH, PhilHealth, LGU: Province & City and direct health providers and facility managers

• Presentation of consultation results to stakeholders and policy makers

Enforcement Compliance and Monitoring Mechanism

Enforcement Agency

• PHIC shall serve as the overall enforcement head for Accreditation, DOH for Licensing.

• Collaborations with LGU as co-regulators can be considered in the M&E plan of the policy for continuing quality control and enforcer HR augmentation

Policy M&E

• A Policy M&E manual will be developed to identify and operationalize indicators

• A randomly sampled 10% of the facilities will be monitored by PHIC per year, all facilities within a region shall annually be inspected by LGU

• Mid-term assessment after 3 years, full policy evaluation after 5 years (outsourced)

• Monitoring levels: national, regional, province/City (from LGU)

Compliance Mechanism

• Non-provision or removal of license

• Prestige incentives for motivation: E.g. Network Accreditation, Best LGU health quality

Process

• Conduct of consultations and policy refinement

• Release of circulars, relevant issuances at national, regional and local levels

• Conduct of policy information forums for stakeholders

• Conduct of orientations for regulators & regulates

• Annual monitoring

• Evaluation after 5-years

• Conduct of automation capacitation initiative



VALUE STREAM MAP: STARTING A BIRTHING HOME

Part of the case study output is the value stream mapping of the process of starting a birthing facility up to the actual licensing approval and eventual start of operation of the birthing facility. The first figure shows the step by step procedure of the process and the agencies and institutions that the business owner should engage with to comply with the licensing requirements. Included in the figure are marks where there are duplication on the process for example SEC registration and DTI registration both requires article of incorporation. The second figure is the computation of reduction of requirements on the process if duplication is removed and process is rationalized.

Figure 24: Licensing of Birthing Homes

Starting a Birthing FacilityBirthing Home located in Pasig City

I. SEC Registration

1. Registration Data Sheet

2. Articles of Incorporation

3. Treasurer’s Affidavit

4. Audited Financial

Statements

5. Bank Certificate of Deposit

II. DTI Registration

6.Barangay Clearance


8.Contract of lease

11. Fire Safety Cert.

III. Business Permit

15. SEC Registration


12. FireCertificate

IV. Permit to Construct

19. DTI Registration

20. 3 Sets of Site Development Plan

and Floor Plan


V. Licensing Requirements

21. Business Permit


23. DTI Registration

Licensing Requirements

Continued

25. MOA Ambulance

10. Barangay Clearance

24. Waste Disposal Plan

13. Sanitary Permit

14. Environmental Certificate

16. Locational clearance

9. two Valid IDs

1

X

X

X

17. Contract of lease

28. Certificate of training• Lactation

Management• BEMONC • FPCBT 1• Environmental

Officer training

26. Certificate as newborn screening

27. Manual of operations/ SOP

X

X

X

X X

X

X X

Starting a Birthing Facility

2

• License to operate Certificate

• Performance Commitment

Figure 23: Starting a Birthing Facility



Figure three and four presents the length of time and distance needed to acquire license per agency starting with

getting a barangay clearance until finally release of license from the DOH and accreditation from PhilHealth which

will take almost 55 days or two months. Figure four shows the length of time and distance for renewal of license

and accreditation from PhilHealth.

Figure 25: Value Stream Map for Birthing Facility Licensing



Figure 26: Value Stream Map for Renewal of Accreditation of Birthing Homes and Possible Closing due to Non-compliance



ANNEXES

Bibliography

Department of Health, A.O. 2017-006. Redefining Service Delivery Networks, Manila, 2017

Department of Health, A.O. 2017-0012. Guidelines on the Adoption of Baseline Primary Health Care Guarantees

for All Filipinos, Manila, 2017

Department of Health, A.O. 2016-0038. Philippine Health Agenda 2016-2022, Manila, 2016

Department of Health, A.O. 2014-0046. Defining of SDNs for UHC. Manila, 2014

Department of Health, A.O. 2014-0044. Guidelines for SDN’s

Department of Health(A.O.) No. 2012-0012 Amendment to Administrative Order entitled “Rules and Regulation

Governing the New Classification of Hospitals and Other Health Facilities in the Philippines”

Department of Health Circular: 2015-0392Additional Clarification on the Requirement of a License to Operate

(LTO) a Birthing Facility Pursuant to Administrative Order No. 2012-0012 known as “Rules and Regulations

Governing the New Classification of Hospitals and Other Health Facilities in the Philippines”

National Demographic and Health Survey. (2017).

National Economic and Development Authority. (2017). Philippine development Plan

World Health Organization. (2011). Philippine Health Systems Review. PDF,

Huntington, D., Banzon, E., and Recidoro, Z. Systems Approach to Improving Maternal Health in the Philippines.

Bulletin of the World Health Organization, 90:104-110.

Lavado, R.F., & Lagrada, L.P. (2008). Are Maternal and Child Care Programs Reaching the

Poorest Regions in the Philippines? Philippine Institute for Development Studies Discussion Series 30. Retrieved on

December, 2016 from http://dirp3.pids.gov.ph/ris/dps/pidsdps0830.pdf

NEDA (2015). Philippines 5th Progress Report on the Millennium Development Goals. Retrieved on December,

2016 from http://www.neda.gov.ph/wp-content/uploads/2014/08/MDG-Progress-Report-5-Final.pdf

Ross, C.E., Masters, R.K., & Hummer, R.A. (2012, November). Education and the Gender Gaps in Health and

Mortality. Demography, 49(4), 1157-83

United Nations. Sustainable Development Goals Indicators. Retrieved on April 11, 2018 from

https://unstats.un.org/sdgs/indicators/indicators-list/



Annex B. Data Collection Tools

BI. Draft Survey Tool

Perception Survey on the Impact of Regulations

on Businesses in the Philippines

Good day! Your business is invited to participate in a survey, entitled “Perception Survey on the

Impact of Regulations on Businesses in the Philippines.” This is being conducted by the

Modernizing Government Regulations Program Office of the Development Academy of the

Philippines (DAP) for five (5) industries: tourism, healthcare, construction, renewable energy, and

consumer goods.

We would like to request the survey respondent to be someone familiar with the activities done

by your business related to complying with government regulations such as reportorial

requirements and renewal of permits. The purpose of this study is to determine the outlook of the

industry toward government regulations in terms of their perceived ease and/or difficulty in

complying with regulatory requirements.

Your participation in this survey is voluntary. You may decline to answer any question and you

have the right to withdraw from participation at any time. There are neither known risks nor costs

to participating in this activity. Your responses will remain confidential and anonymous. Any

information gathered will only be used for the purpose of our study and reported as a whole.

If you have questions, please contact us at (02) 631-2163 or send an email to [email protected].

Thank you!

CONSENT

I have read the foregoing information. I understand that I may withdraw my consent and

discontinue participation at any time without penalty or loss of benefits to which I may otherwise

be entitled. Should I elect to discontinue participation; any information already collected will be

discarded. I have had the opportunity to ask questions and all questions have been answered to

my satisfaction. I consent voluntarily to be a participant in this study.

Signature of Participant

Contact No: Date:

Section A: Background

A1. What type of business do you represent?

☐ Sole proprietorship ☐ Partnership ☐ Corporation



A2. Where is your business located?

☐ Luzon ☐ Visayas ☐ Mindanao ☐ Multiple

locations

A3. What is the capitalization of your business?

☐ Micro

(Up to

Php3,000,000)

☐ Small

(Php3,000,001–

15,000,000)

☐ Medium

(Php15,000,001–

100,000,000)

☐ Large

(Php100,000,00

1 above)

A4. How long has your business been operating?

☐ Less than two years ☐ 2-10 years ☐ More than 10 years

NOTE FOR SUCCEEDING SECTIONS: For the purpose of this questionnaire, the term “regulatory

agencies” may refer to any national government agency (NGA) or local government unit (LGU) with

regulatory functions (e.g. accreditation, clearance, certification, inspection, licensing, permitting).

Section B: Interaction with Regulatory Agencies

B1. Who are the regulatory agencies that you most deal with? If more than one, please list in the

order of importance on your business.

1

2

3

4

5

B2. Which of the following describe the nature of your interaction with the regulatory agencies?

(tick all that apply)

☐ Providing information required by a regulation

☐ Accreditation of product/service/personnel

☐ Remitting government share in sales/taxes

☐ Inspection of products/premises

☐ Registration/renewal of permits/license

☐ Others (please specify)

B3. How often do you have to submit information to the regulatory agencies that you most

regularly deal with?

☐ Once a year ☐ 2-3x a year ☐ 4-6x times a

year ☐ More than 6x a year



B4. How frequently have your business been inspected and/or audited by regulatory agencies in

the past 3 years?

☐ Once ☐ Twice ☐ More than twice ☐ Not applicable

B5. Please tick the box on the rating column that best corresponds to your answer.

Never Sometime

s

Often Always

a The opinion of the industry is taken into account

when regulations are being developed ☐ ☐ ☐ ☐

b The reason for the regulation is clearly

communicated to the industry ☐ ☐ ☐ ☐

c The requirements of a regulation are clearly

communicated to the industry ☐ ☐ ☐ ☐

d Changes in regulation are announced before

implementation ☐ ☐ ☐ ☐

Section C: Information about Regulations

C1. How familiar are you with government regulations that affect your business?

☐ Moderately familiar ☐ Familiar ☐ Very familiar

C2. Please indicate to what extent you agree or disagree with the statements below:

Statements Strongly

disagree Disagree

Neither

agree

nor

disagree

Agree Strongly

Agree

a Accurate information is readily

available at the regulatory

agencies or through their

websites

☐ ☐ ☐ ☐ ☐

b The objectives and purpose of

the regulations are easy to

understand

☐ ☐ ☐ ☐ ☐

c Businesses are aware of the

Citizen’s Charter of the

regulatory agencies

☐ ☐ ☐ ☐ ☐



d Regulatory agencies are aware

of their own Citizen’s Charter ☐ ☐ ☐ ☐ ☐

e Regulatory agencies give clear

and sure answers to queries of

businesses

☐ ☐ ☐ ☐ ☐

f Regulatory agencies respond

within the indicated time in their

Citizen’s Charter

☐ ☐ ☐ ☐ ☐

Section D: Compliance with Regulations

D1. Rate the impact of the following regulations to your business?

Regulation

Not

Applicable

Low

Impact

Business

as usual

Moderate

impact

Non-

compliance

may lead to

imposition of

penalties

Major

Impact

Non-

compliance

may lead to

end of

business

operations

a Tax regulations

(e.g. business tax, indirect taxes,

etc.)

☐ ☐ ☐ ☐

b Customs regulations

(e.g. import/export permits, etc.) ☐ ☐ ☐ ☐

c Infrastructure/facilities

regulations

(e.g. building permit, locational

clearance, land-use permit, etc.)

☐ ☐ ☐ ☐

d Technological regulations

(e.g. intellectual property

regulations, product

registrations, etc.)

☐ ☐ ☐ ☐

e Health and safety regulations

(e.g. food safety certification,

sanitation certification, etc.)

☐ ☐ ☐ ☐

f Employment regulations

(e.g. occupational health

regulations, social security

regulations, etc.)

☐ ☐ ☐ ☐

g Environmental regulations ☐ ☐ ☐ ☐



(e.g. wastewater discharges

regulation, pollution control

policy, etc.)

h Administrative regulations

(e.g. Mayor’s permit, barangay

clearance, etc.)

☐ ☐ ☐ ☐

D2. Are the following areas easy to comply with?

Regulation YES NO

a Tax regulations

(e.g. business tax, indirect taxes, etc.) ☐ ☐

b Customs regulations

(e.g. import/export permits, etc.) ☐ ☐

c Infrastructure/facilities regulations

(e.g. building permit, locational clearance, land-use

permit, etc.)

☐ ☐

d Technological regulations

(e.g. intellectual property regulations, product

registrations, etc.)

☐ ☐

e Health and safety regulations

(e.g. food safety certification, sanitation certification,

etc.)

☐ ☐

f Employment regulations

(e.g. occupational health regulations, social security

regulations, etc.)

☐ ☐

g Environmental regulations

(e.g. wastewater discharges regulation, pollution

control policy, etc.)

☐ ☐

h Administrative regulations

(e.g. Mayor’s permit, barangay clearance, etc.) ☐ ☐

D3. What specific regulations are the most difficult to comply with (kindly cite at least three)?

1

2

3

4

5

D4. Do you think that regulations are appropriately enforced?

☐ YES ☐ NO

D5. If NO, why (tick all that apply)



☐ Requirements for compliance are unclear

☐ Enforcement is inconsistent across businesses

☐ There are not enough inspections or audits

☐ Access to regulatory agencies is difficult

☐ Others (please

specify)

D6. In your experience, are you required to provide the same information to a number of different

regulatory agencies?

☐ YES ☐ NO

If yes, please give details

D7. Do you use online forms for submitting information to regulatory agencies?

☐ YES ☐ NO

If no, why?

D8. Are online forms effective in reducing the difficulty in submitting information to regulatory

agencies?

☐ YES ☐ NO

If so, why?

Section E: Cost of Complying with Regulations

E1. Estimate the time spent annually in complying with regulations.

___ Total workdays per year

E2. Please tick the box that best corresponds to your answer.

Strongly

disagree Disagree

Neither

agree

nor

disagree

Agree Strongly

Agree



a Regulatory agencies provide

information on the breakdown

of fees

☐ ☐ ☐ ☐ ☐

b Government charges for

permits, licenses and other fees

are reasonable

☐ ☐ ☐ ☐ ☐

E3. Are there other fees collected in complying with regulations beyond what is published?

☐ YES ☐ NO

Section F: Impact of Regulations

F1. Rate the overall regulatory environment in your industry

☐ Weakly regulated ☐ Fairly regulated ☐ Overly regulated

F2. Do you agree or disagree with the following statements?

Strongly

disagree Disagree

Neither

agree

nor

disagree

Agree Strongly

Agree

a Regulations are relevant and

necessary ☐ ☐ ☐ ☐ ☐

b Regulations are beneficial to

business ☐ ☐ ☐ ☐ ☐

c Regulations are consistent and

don’t overlap with other

regulatory agencies

☐ ☐ ☐ ☐ ☐

F3. Do you think that the benefits outweigh the costs to comply with government regulations?

☐ YES ☐ NO

Why or why not?

F4. Have government regulations been a critical factor in your decision to grow and expand your

business?

☐ YES ☐ NO



Why or why not?

F5. Have government regulations helped in the development of your industry?

☐ YES ☐ NO

Why or why not?

Thank you for completing our survey!



BII. Draft KII/ FGD Tool

For the Regulatees: Good day!

You have been purposively selected due to your unique expertise and experience to be part of a study conducted by the Modernizing Government Regulations Program Office of the Development Academy of the Philippines (DAP).

If you agree to participate, you will be required to answer some questions as part of a key informant interview. The questions mainly revolve around your experience on health business regulations, e.g. your issues and concerns with the current regulations, the typical activities you undergo with various government agencies with regard to regulation compliance, etc.).

Your participation in this survey is voluntary. You may decline to answer any question and you have the right to withdraw from participation at any time. There are neither known risks nor costs to participating in this activity. Your responses will remain confidential and anonymous. Any information gathered will only be used for the purpose of our study and reported as combined total.

If you have questions, please contact us at (02) 631-2163 or send an email to [email protected]. Thank you!

CONSENT FORM

I have read the foregoing information. I understand that I may withdraw my consent and discontinue participation at any time without penalty or loss of benefits to which I may otherwise be entitled. Should I elect to discontinue participation; any information already collected will be discarded. I have had the opportunity to ask questions and all questions have been answered to my satisfaction. I consent voluntarily to be a participant in this study.


Contact No:

Date:

QUESTIONS:

1. What agencies are involved in regulating the setting up, regular operations and closing down of your health business?

2. What are your transactions with these agencies?

3. Are you aware of any regulations pertaining to your health business? If so what are they and what do they require?

4. What do you think is the rationale, purposes and intents behind these regulatory



policies/laws/legal issuances?

5. What regulations related to the acquisition of materials and services from suppliers, the flow of information required by the business, the delivery of goods and services to customer, and the flow

of funds to and from the business affect your operations?

6. What are your main concerns or issues with regard to the current regulations for your business?

7. What are some initiatives or processes, which the agencies implement so as to make your transactions with them more efficient and convenient?

8. Are you compliant to the regulations? If yes, what facilitates compliance? If no, what are some obstacles to the regulatory requirements for your business?

9. Do you have any recommendations for the improvement of the regulations affecting your health business?

For the Regulators:

Good day!

You have been purposively selected due to your unique expertise and experience to be part of a study conducted by the Modernizing Government Regulations Program Office of the Development Academy of the Philippines (DAP).

If you agree to participate, you will be required to answer some questions as part of a key informant interview. The questions mainly revolve around your experience and expertise on health business regulations, e.g. your issues and concerns with the current regulations, the typical activities you conduct with regard to regulation implementation and enforcement, compliance concerns etc.).

Your participation in this survey is voluntary. You may decline to answer any question and you have the right to withdraw from participation at any time. There are neither known risks nor costs to participating in this activity. Your responses will remain confidential and anonymous. Any information gathered will only be used for the purpose of our study and reported as combined total.

If you have questions, please contact us at (02) 631-2163 or send an email to [email protected]. Thank you!

CONSENT FORM

I have read the foregoing information. I understand that I may withdraw my consent and discontinue participation at any time without penalty or loss of benefits to which I may otherwise be entitled. Should I elect to discontinue participation; any information already collected will be discarded. I have had the opportunity to ask questions and all questions have been answered to my satisfaction. I consent voluntarily to be a participant in this study.




Contact No:

Date:

1. What is your agency’s role in regulating health industry businesses?

2. What are the other agencies you collaborate with for regulatory implementation and enforcement? How do these agencies regulate this industry/sector in relation to your agency?

3. What specific regulatory policies/laws/legal issuances govern this industry?

4. What are the rationale, purposes and intents behind these regulatory policies/laws/legal

issuances?

5. Do you think the industry players understand the rationale behind the specific regulation and the meaning of their compliance, especially those being regulated?

6. What regulations related to the acquisition of materials and services from suppliers, the flow of information required by the business, the delivery of goods and services to customer, and the flow of funds to and from the business affect the industry?

7. What are the regulatory issues related to the setting up, operations and closure of businesses under this industry?

8. What is the current level of compliance? How is compliance to these regulations monitored? What are the repercussions for violators?

9. What are the “costs and benefits” of the regulations currently governing the specific industry?

10. Are there non-regulatory alternatives to the regulations that are suggested to be removed?

11. Are regulations regularly reviewed? Are there improvements instituted to the ease of doing business?

12. Should changes be introduced, what is the likelihood of compliance?

13. What benefits may be derived from the proposed changes?



Annex C. List of Respondents for Survey Method, KIIs and FGDs

Responders SURVEY

A representative from Luzon, Metro Manila, Visayas, and Mindanao operations will be involved

hence n=4 per business type

Mercury 4

Generics Pharmacy 4

Therapeutic Massage Clinic 4

Private Birthing Home 4

Private Hospitals Level 1 4



Private TAHC provider 4

Water Station 4

HMO 4

PMA 4

PHA 4

PNA 4

IMAP 4

PDA 4

Optometry 4

Dialysis Center 4

TOTAL 68



Identified Survey Participants with Contacts *The above table are the ideal business or agency distribution per region. The actual facilities and respondents per type of business or agency is seen below.

Responders Facility Name Respondent

Name Designation Contact/Email Contact Number

LUZON

Private

Infirmary

DR. WILFREDO G. CORTEZ

HOSPITAL, INC.

DR. WILFREDO G.

CORTEZ

Medical

director [email protected] 045-361-2132 / 09189185830

Private

Infirmary

JESUS OF NAZARETH GENERAL

HOSPITAL

DR. REMY ROSA

G. GARCIA

Medical

director

[email protected]

om

(044) 794-1202

Private

Hospitals Level

1

Dr. Cecilia Tobillo BOT [email protected] 09175009028

Private

Hospitals Level

1

AGOO FAMILY HOSPITAL DR. JOSE E.

ASPIRAS, JR.

medical

director docjoe1959@ yahoo.com (072)607-2708

Private

Hospitals Level

1

Mission Hospital DR. ROEL TITO A.

MARCIAL

Medical

Director

[email protected]

m 565-2851 / 655-4337

Private

Hospitals Level

2

UHBI - PARAÑAQUE DOCTORS

HOSPITAL, INC.

DR. LOIDA S.

PONIO

Medical

Director

parañ[email protected]

m.ph

776-0288 / 776-0644 / 776-

0648 / 831-1340

Private

Hospitals Level

2

COMMONWEALTH HOSPITAL

AND MEDICAL CENTER

JUAN A.

LAGUNZAD, MD

Medical

Director [email protected] 930-0000

Private

Hospitals Level

2

LOS BAÑOS DOCTORS

HOSPITAL AND MEDICAL

CENTER

DR. ROWENA A.

PUA

medical

director [email protected] 536-0100

Private

Hospitals Level

3

THE MEDICAL CITY

COMPOUND, ORTIGAS

AVENUE,

DR. Benito

Bengzon

President &

CEO

[email protected]

/ [email protected] 988-1000 loc 6314 & 6294

Private

Hospitals Level

3

Mary Johnston Hospital

DR. EVANGELINA

C. DURAN

Medical

Director

maryjohnstonhospital@yahoo

.com.ph 245-4021 to 25

mailto:[email protected]




mailto:para%C3%[email protected]

mailto:para%C3%[email protected]








Private

Hospitals Level

3

DE LA SALLE UNIVERSITY

MEDICAL CENTER

DR. GARY N.

CARLOS

Medical

Director [email protected] (046) 481-8000

Private Birthing

Home

Bet-Nori Health Care Systems,

Inc.

Dr. Godwyn

Bernardo Owner [email protected] 09175031902

Private Birthing

Home

BLESSED MERCY BIRTHING

HOME CLINIC

MERCY V.

BAUTISTA Clinic Head

blessedmercybirthinghomeclin

[email protected]

0927-6204146

Private Birthing

Home

CRESILDA BIRTHING HOME

CLINIC

CRESILDA R.

KILALA LABAON Owner

[email protected]

om.ph

09065237044

Private Birthing

Home

WELL CARE MATERNITY

MEDICAL & PEDIATRIC CLINIC

INC.

LENIELYN F.

JOSEPH, RM Clinic Head

wellcare_midwife_clinic@yah

oo.com

6976092

Ambulatory

Surgical Care

Clinic

AMBULATORY HEALTH CARE

INSTITUTE, INC.

DR. ACHELLE C.

RONQUILLO

medical

director

[email protected]

m

633-6597; 633-5747

Private Stand

Alone Clinic Dr. Cecilia Bacani Owner [email protected] 09285032262

Private Clinic Dx Dr. Condrado

Quebael BOT 09428091089

Private

Practioner Dr. Edu Borja

Pedia,

Greenhils

[email protected]

m

Private Hospital Dr. Ferdinand

Macababad Owner 09175133166

Private Dx Clinic Dr. Rafael Yu Owner 09178555428

Private OFW

Provider Dr. Ralf Sison Owner 09173164275

Private

practitioner

pharma

Dr. Jody

Dalmacion

Pharma

Consultant [email protected]

IMAP Patricia Gomez BOT, Former

President

[email protected]

[email protected] 09054979705

Optometry Mildred [email protected] 09175497692




















Private Dialysis

Clinic

NEPHROLOGY CENTER OF

MANILA

REY B. JAIME B.

TAN, MD

Medical

director [email protected] 5365108

HMO Value Care Health

Systems, Inc. website: http://www.valucare.

com.ph/

HMO PhilhealthCare,

lnc.

website: https://www.philcare

.com.ph/ hotline: (02) 462 1800

HMO

Pacific Cross

Health Care, lnc.

(Formerly

Bluecross)

website: http://www.pacificcr

oss.com.ph/ hotline: +63 2 899-8001

HMO Life & Health

HMP, Inc.

http://lifeandhealthhmp.com

/

hotline: 742-9750/ 781-9682/

732-4415/ 411-0555/ 4116384

HMO

Kaiser

International

Healthgroup, Inc.

website: http://www.kaiserhe

althgroup.com/contact.php

HMO Insular Health

Care, Inc

website: https://www.insularh

ealthcare.com.ph/

HMO Fortune

Medicare, lnc

website: http://www.fortunec

are.com.ph/

HMO Caritas Health

Shield, Inc.

website: http://www.caritash

ealthshield.com.ph/

VISAYAS Private

Infirmary

REINHARD WIRTGEN

MEMORIAL HOSPITAL

DR. GILBERTO F.

MAGALLON

Medical

director

[email protected]

m

(032) 476-8028 / (032) 476-

7101 / (0916) 920-5475

Private

Infirmary

MITIONG-DODING MEMORIAL

HOSPITAL

DR. BIENVENIDO

C. MOLINA JR.

Medical

director [email protected]

(038) 530-6602 / (0916) 892-

8445

Private

Hospitals Level

1

STA. ROMANA-YSON

MEMORIAL HOSPITAL

JULIUS CAESAR Y.

STA. ROMANA

Medical

Director

staromanaysonmemhospital@

gmail.com

91613088431











Private

Hospitals Level

1

PAULINA LIM MEMORIAL

HOSPITAL

DR. PAULINE L.

RAMOS

Medical

Director

[email protected]

m

(038) 510-0299 / (0999) 366-

9822

Private

Hospitals Level

1

JULIO CARDINAL ROSALES

MEMORIAL HOSPITAL

DR. GENALYN B.

LABADAN

Medical

Director

[email protected] /

[email protected] (032) 484-8601

Private

Hospitals Level

2

Dr. Susan Aspiras Owner [email protected]

Private

Hospitals Level

2

ST. ANTHONY COLLEGE

HOSPITAL

SR. MANILEÑA A.

LIBO-ON , DC Administrator [email protected] (036) 621-0434/ 621-6004

Private

Hospitals Level

2

CEBU NORTH GENERAL

HOSPITAL

DR. ROBERTINO L.

ESPLANADA

Medical

Director

cebunorthgeneralhospital@ya

hoo.com

(032) 343-7777

Private

Hospitals Level

2

HOLY CHILD HOSPITAL DR. KENNETH T.

COO

Medical

Director [email protected]

(035) 225-0510 / (035) 421-

0991

Private

Hospitals Level

3

ILOILO DOCTORS HOSPITAL DR. ROLANDO R.

PADILLA

Medical

Director [email protected] 337-7702 TO 06

Private

Hospitals Level

3

ADVENTIST MEDICAL CENTER-

BACOLOD, INC.

DR. HECTOR G.

GAYARES, JR. Administrator [email protected] 433-4831

Private

Hospitals Level

3

DIVINE WORD HOSPITAL DR. CESAR A.

AQUITANIA

Medical

Director dwhospital2gmail.com 321-4228

Private Birthing

Home Dr. Marietta Hao Owner 09176278532

Birthing Home JKL Birthing Home JAZMIN LAURE-

KAPUNAN, MD Clinic Head [email protected] 3917122














Birthing Home CFC Birthing Center CATALINA B.

CATUBAC, RM Clinic Head [email protected] 033-5003214

Birthing Home IMAP LYING-IN CLINIC, INC.-

SANDINGAN BRANCH EMMA S. PLAZA Clinic Head [email protected] 0916-7197808

Ambulatory

Surgical Care

Clinic

MEDICUS AMBULATORY

HEALTHCARE CENTER

DR. JAIME

MANILA

medical

director

medicus_iloilo-

[email protected]

5085488

Private TAHC

provider MotherBles Birthing Clinic Sis. Eloisa David BOT [email protected] 09178532775

Dialysis Center METRO CEBU KIDNEY DIALYSIS

CENTER, INC.

DR. KAREN

ROSARIO C.

LICUANAN

Medical

director

[email protected]

m

(032) 254-4715 / (0917) 709-

7778

MINDANAO ARMM Private

Infirmary

OROQUIETA COMMUNITY

HOSPITAL

DR. ANDREA P.

MANCAO

Medical

director [email protected] (088) 531-1858

Private

Infirmary

TIBUNGCO DOCTORS

HOSPITAL

JOSE

DOMINADOR

QUITAIN, MD

Medical

director

tibungcodoctorshospital@yah

oo.com

(82) 2380774

Private Hospital

1 Dr. Rashid Chin BOT 09173006689

Private

Hospitals Level

1

JANUARIA MARCIAL

MEMORIAL HOSPITAL

DR. NEREO A.

OCSIO

Medical

Director [email protected] 9189480269

Private

Hospitals Level

1

MIDSAYAP COMMUNITY

DOCTORS HOSPITAL

DR. EMILY C.

DIZOR

Medical


Private

Hospitals Level

1

R. O. DIAGAN COOPERATIVE

HOSPITAL

DR. RENATO G.

DIAGAN

Medical

Director [email protected] (083)552-3942

Private

Hospitals Level

2

METRO DAVAO MEDICAL AND

RESEARCH CENTER, INC.

YVETTE YENCO-

TAN, MD

Medical

Director [email protected] (082) 2877777


















Private

Hospitals Level

2

DIGOS DOCTORS' HOSPITAL,

INC.

RODRIGO P.

NAVARRO, MD

Medical

Director

[email protected]

om

(82) 5533584

Private

Hospitals Level

2

CAGAYAN DE ORO MEDICAL

CENTER, INC.

DR. EDNA E.

RICARTE

Medical

Director [email protected] (08822) 711-874 to 76

Private

Hospitals Level

3

MARIA REYNA- XAVIER

UNIVERSITY HOSPITAL, INC.

DR. RAUL

WINSTON

ANDUTAN

Medical


Private

Hospitals Level

3

ADVENTIST MEDICAL CENTER-

ILIGAN CITY, INC.

DR. BABY

DARLENE LL.

DELA CRUZ

Medical


Private

Hospitals Level

3

SAN PEDRO HOSPITAL OF

DAVAO CITY, INC.

MARCELO L.

DAHINOG, MD

Medical


Birthing Home DBM PAANAKAN AND FAMILY

PLANNING CLINIC

COSME M.

MABINI, RM Clinic Head [email protected] 9357910121

Birthing Home GRACE ANNE MATERNITY AND

FAMILY PLANNING CLINIC

FREDESMINDA J.

ANDUYAN, MD Clinic Head [email protected] (82) 2985227

Birthing Home ST. THERESE BIRTHING HOME MS. HERMINIA A.

TELARMA Owner

sttheresebirthinghome@yaho

o.com 9483142507

Ambulatory

Surgical Care

Clinic

SURIGAO HEALTH

SPECIALISTS', INC.

DR. ROY N.

YCONG

medical

director

surigaohealthspecialist@yaho

o.com

086 8266200













Name of Agency National Luzon Visayas Mindanao Total

KII ( Individual or during Forum)

Department of Labor and Employment (DOLE) 1

Department of Interior Local Gvernment (DILG) 1

Department of Health

Dr. ROLANDO ENRIQUE D. DOMINGO, DPBO

Undersecretary of Health

Health Regulations Cluster

[email protected]

(632) 651-7800 local 2901, 2916, 2917

1

Dr. MARIO C. VILLAVERDE, MPH, MPM, CESO I

Undersecretary of Health

Health Sector Reform Cluster

[email protected]

(632) 651-7800 local 2901, 2902, 2903, 2904,

2919 ; TF: 711-0780

1

DR. LYNDON L. LEE SUY, MPH

Assistant Secretary of Health

Health Regulations Cluster

[email protected]

1

DR. KENNETH G. RONQUILLO, MPHM, CESO III

Director IV

Health Policy Development and Planning

Bureau (HPDPB)

[email protected]

[email protected]

651-7800 local 1326-1331, 4203-4204, 4250-

4251

1

DR. MA. THERESA G. VERA, MSc, MHA, CESO

III

Director IV

Health Human Resource Development Bureau

[email protected]

[email protected]

651-7800 local 4226, 4225

1




DR. MYRNA C. CABOTAJE, MPH, CESO III

Director IV

Disease Prevention and Control Bureau

1

ATTY. NICOLAS B. LUTERO III, CESO III

Director IV

Health Facilities and Services Regulatory Bureau

(HFSRB)

651-7800 local 2503, 2500, 2505

1

R. FERDINAND S. SALCEDO, MPH, CESO IV

Director IV

Bureau of Quarantine (BOQ)

[email protected]

527-4678, 320-9103

1

MS. NELA CHARADE G. PUNO, RPh

Director General

Food and Drug Administration (FDA)

[email protected]

(632) 857-1999

1

MARIA LOURDES C. SANTIAGO, MSc, MM,

CESO II

Deputy Director General for Field Regulatory

Operations Office

Food and Drug Administration

[email protected]

857-1999

1

DR. ANNA MELISSA S. GUERRERO

Program Manager

Pharmaceutical Division

1

DR. CORAZON I. FLORES, MPH, CESO IV

OIC-DIRECTOR IV, NCR 1

MARLYN W. CONVOCAR, MD, MPH, CESO III

DIRECTOR IV Region 6 1

NIMFA B. TORRIZO, MD, MPH

DIRECTOR IV Region 10 1




ANNABELLE DE GUZMAN, MD, FPAFP, MHA,

MA MED, CESE

Director General

376-3067 (TF), 376-30-68

[email protected]

Philippine Institute of Traditional and

Alternative Health Care (PITAHC)

Matapang St East Avenue Center Compound,

Diliman, Q.C.

1

Hospitals

EAST AVENUE MEDICAL CENTER

EAST AVE., QUEZON CITY

EMMANUEL M. BUENO, MD, FPCS, FACS

Medical Center Chief II

928-0611 local 201, 928-0611 to 24, 426-4405

(TF)

[email protected]

1

TONDO MEDICAL CENTER

BALUT, TONDO, MANILA

DR. MARIA ISABELITA M. ESTRELLA


(02) 865-9000, Emergency Room: (02) 865-

9035, Alagang Pinoy Kiosk : Globe-

09773370546 / Smart-09395222095 / Sun-

09430614987

[email protected]

[email protected]

1

PHILIPPINE CHILDREN'S MEDICAL CENTER

QUEZON AVE., QUEZON CITY

DR. JULIUS LECCIONES

Executive Director

588-9900, 924-6001 to 02, 924-0836 , 924-0840

(F)

[email protected]

1

PHILIPPINE HEART CENTER

EAST AVE., QUEZON CITY

DR. JOEL ABANILLA

Executive Director

1





925-2402 to 50 , 922-0551 (TF)

[email protected]

AMANG RODRIGUEZ MEMORIAL MEDICAL

CENTER

MARIKINA CITY

DR. IMELDA M. MATEO


948-1263 Local 106, 570-2776, 941-5854, 941-

3441 (TF)

[email protected]

1

WESTERN VISAYAS MEDICAL CENTER

MANDURRIAO, ILOILO CITY

DR. JOSEPH DEAN NICOLO


(033) 321-2841 to 50 Local 134, 321-1797, 321-

2802 , 321-1797, 321-2802

[email protected]

1

CORAZON LOCSIN MONTELIBANO MEMORIAL

REGIONAL HOSPITAL

BACOLOD CITY

DR. JULIUS DRILON


(034) 433-2697, 435-1591

[email protected]

[email protected]

1

VICENTE SOTTO MEMORIAL MEDICAL CENTER

CEBU CITY

DR. GERARDO AQUINO


(032) 253-9891 to 99 , (032) 382- 5514

[email protected]

1





EASTERN VISAYAS REGIONAL MEDICAL CENTER

TACLOBAN CITY, LEYTE

DR.JOVITO SALINAS

OIC, Medical Center Chief II

(053) 321-3129, 321-3363 , (053) 321-8724

[email protected]

1

NORTHERN MINDANAO MEDICAL CENTER

CAPITOL CMPD., CAGAYAN DE ORO CITY

DR. JOSE CHAN


Tel. No. (08822) 726362, 723735 local 607,

728829 , (0882) 721794 (TF)

[email protected]

[email protected]

1

SOUTHERN PHILIPPINES MEDICAL CENTER

DAVAO CITY

DR. LEOPOLDO VEGA


(082) 227-2731, 221-7029 (F)

[email protected]

1

PhilHealth

BASA, RUBEN JOHN A.

Executive Vice President and Chief Operating

Officer Office of the Executive Vice President

and Chief Operating Officer (02) 637-6448

1

PARGAS, ISRAEL FRANCIS A. Concurrent OIC-

Vice President and Head Executive Assistant

Corporate Affairs Group and Office of the

President and Chief Executive Officer (02) 638-

1682

1

ASPRER, LEILANI V.

OIC, Senior Manager Accreditation Department

(02) 637-6265

1

ALONTO, MASIDING JR. M. Regional Vice

President and Concurrent Area Vice President

for Mindanao PhilHealth Regional Office X and

Office of Area Vice President for Mindanao

1




DIOCSON, LOURDES F.

Regional Vice President

PhilHealth Regional Office VI (02) 441-7444 loc.

5401

1

Provincial Hospital Iloilo 1

Provincial Hospital Misamis 1

Professional Regulation Commission 1

Veterans Memorial Medical Center 1

Philippine Council for Health Research and

Development 1

Civil Service Commission 1

Development Academy of the Philippines 1

Philippine Charity Sweepstakes Office 1

Total 36 2 7 5 50



FGD (5-7 pax) Luzon Visayas Mindanao Total

PHO Iloilo 1

PHO Misamis 1

QC Health Department 1

Barangay Dona Imelda Health Center 1

Iloilo City HO 1

Miagao RHU 1

CDO CHO 1

Total Participants 10 15 10 35

*Assuming there are 5 participants per FGD; lower limit of estimated participants was used

‘Resources needed for KIIs and FGD:

1. Token for participants

2. Transportation cost

3. Meals, if necessary



Public Forum Participants

National Private Forum (July 6 and Nov. 7)

NAME OFFICE POSITION ADDRESS CONTACT # EMAIL

Mr. Rhais

Gamboa

Mt. Grace

Hospital Inc.

BOT, Chief Operating

Officer

2/F Bayanihan Center

Annex 132 Pioneer St.

Mandaluyong City

1550

(632)

9175763362;

7302203,

7194821

[email protected],

[email protected];

[email protected]

Atty. Joey Ochave UNILAB VP Pioneer St.

Mandaluyong City

1550

09178359443 [email protected]

Ms. Daisy

Cembrano

Pharmaceautical

and Healthcare

Association of the

Philippines

(PHAP)

Health Policy Advicor,

Regulatory

09178882633 [email protected]

Ms. Patricia

Gomez

Integrated

Midwives

Assosiation of the

Phil.

Chief Executive Officer Pinaglabanan cor. Dr.

A. Ejercito St.

San Juan City, Metro

Manila

09988599869

(02) 7275225/

Fax 02 7244849

[email protected]

[email protected]

DR. HUBERTO F.

LAPUZ

Phil. Hospitals

Association

President for Luzon Nueva Ecija 09178601957 [email protected]

Dr. Godwyn

Bernardo

Bet-Nori Health

Care Systems,

Inc.

BOT, Owner Cavite, City 09175031902 [email protected]

Midwife Birthing Home Owner MetroMla

Ms. Teresita

Panganiban

Friendly Care

clinic

president chief

executive

401-5210 and

722-2986/ 0977-

2744874

[email protected]






Public Forum Luzon (Tentative Participants)

Office Participants and Contact

DOH NCR

MA. PAZ P. CORRALES, MD, MHA, MPA

DIRECTOR III

531-0032 local 103, 535-4538 (F)

DOH CAR

AMELITA M. PANGILINAN, MD, MPH, CESO IV

DIRECTOR III

(074) 442-8096, 442-8097 (TF)

[email protected]

DOH RO 1 RLED and FDA

DOH RO !!

RIO L. MAGPANTAY, MD, PHSAE, CESO III

DIRECTOR IV

(078) 304-6523 (TF)

[email protected]

DOH RO III

RUBEN SIAPNO, MD, MPH, CESO IV

DIRECTOR III

(045) 861-3428 Local 118

DOH RO IV A RLED

DOH RO V FDA RLED

DOH RO IV B FDA RLED

DOH Hospitals

ILOCOS TRAINING AND REGIONAL MEDICAL CENTER DR. EDUARDO M. BADUA III

SAN FERNANDO, LA UNION OIC-Medical Center Chief II

(072) 607-6418, 607-6422

[email protected]

BATAAN GENERAL HOSPTAL DR. GLORY V. BALTAZAR

MANAHAN ST., TENEJERO, BALANGA, BATAAN Medical Center Chief II

(047) 237-1274, 237-1275 (TL), 237-3635 (TF)

[email protected]



Office Participants and Contact

JOSE B. LINGAD MEMORIAL REGIONAL HOSPITAL DR. MONSERRAT S. CHICHIOCO

SAN FERNANDO, PAMPANGA Medical Center Chief II

(045) 961-3921, 961-3544

[email protected]

OSPITAL NG PALAWAN DR. MELECIO N. DY

PUERTO PRINCESA CITY Medical Center Chief I

(048) 434-2148, 434-8339

[email protected]

Public Forum Visayas (Tentative Participants)

ORGANIZATION NAME/POSITION CONTACT NUMBER EMAIL ADDRESS

DOH RO VI MARLYN W. CONVOCAR, MD,

MPH, CESO III

DIRECTOR IV

(033) 321-3673 local 126, 321-

1036 (TF)

[email protected]

MA. JULIA Z. VILLANUEVA, MD

OIC-DIRECTOR III

(033) 321-3673 local 132, 321-

1036 (TF)

DOH RO VI RLED, FDA

DOH RO VII SOPHIA M. MANCAO, MD

OIC-DIRECTOR III

(032) 418-7130; 254-0109

DOH RO VII RLED, FDA

DOH RO VIII Exu Sabaldarino RLED

CORAZON LOCSIN MONTELIBANO

MEMORIAL REGIONAL HOSPITAL

DR. JULIUS DRILON

BACOLOD CITY Medical Center

Chief II

(034) 433-2697, 435-1591 [email protected]

[email protected]

DON JOSE MONFORT MEDICAL

CENTER EXTENSION HOSPITAL DR.

MARIANO HEMBRA

(033) 361-2009, 361-2011 [email protected]




ORGANIZATION NAME/POSITION CONTACT NUMBER EMAIL ADDRESS

BAROTAC NUEVO, ILOILO OIC-

CHIEF OF HOSPITAL II

WESTERN VISAYAS MEDICAL

CENTER DR. JOSEPH DEAN NICOLO

MANDURRIAO, ILOILO CITY


(033) 321-2841 to 50 Local 134,

321-1797, 321-2802 , 321-1797,

321-2802

[email protected]

WESTERN VISAYAS SANITARIUM

DR. GARY U. ONG

BRGY. INANGAYAN, SANTA

BARABARA, ILOILO OIC - Medical

Center Chief I

(033) 523-9331, 523-9885, 523-

8617, 523-9515 (F) (Office of MCC)

[email protected]

VICENTE SOTTO MEMORIAL

MEDICAL CENTER DR. GERARDO

AQUINO

CEBU CITY Medical Center Chief II

(032) 253-9891 to 99 , (032) 382-

5514

[email protected]

DR. JOHN EDWARD M. COLOMA


(053) 321-3129, 321-3363 , (053)

321-8724

[email protected]

Public Forum Mindanao (Tentative Participants)

ORGANIZATION NAME/ POSITION CONTACT NUMBER

DOH RO IX EMILIA P. MONICIMPO, MD, MPH

DIRECTOR IV

(062) 992-2745; 991-3380 (F)

DOH RO X NIMFA B. TORRIZO, MD, MPH

DIRECTOR IV

(088) 858-7123 local 219 ; Fax No.: 991-3380

DOH RO X FDA

DOH RO X RLED

DOH RO XI Fda RLED

DOH RO XII ARISTIDES C. TAN, MD, MPH, CESO III

DIRECTOR IV

(064) 421-4726 Local 202 ; (064) 421-2373 (TF)






ORGANIZATION NAME/ POSITION CONTACT NUMBER

DOH RO CARAGA JOSE R. LLACUNA, JR., MD, MPH, CESO III

DIRECTOR IV

(085) 342-5208 Local 124, 225-2970, 225-2970 ; (085)

341-2579 ; Fax: (085)225-2970

ARMM KADIL M. SINOLINDING, JR., MD, DPBO

SECRETARY OF HEALTH

Fax – (064)-421-6842 TL: (064) 421-7703, 421-3988,421-

6889, 552-0110, 552-0118, 552-0095, 552-0160

MAYOR HILARION A. RAMIRO SR. REGIONAL AND TEACHING

HOSPITAL DR. JESUS MARTIN SANCIANGCO III

OZAMIS CITY Medical Center Chief I

(088) 521-0022

NORTHERN MINDANAO MEDICAL CENTER DR. JOSE CHAN

CAPITOL CMPD., CAGAYAN DE ORO CITY Medical Center Chief II

(08822) 726362, 723735 local 607, 728829 , (0882)

721794 (TF)

AMAI PAKPAK MEDICAL CENTER DR. LUZ A. SABER

MARAWI CITY, LANAO DEL SUR OIC-Medical Center Chief II

(063) 352-0070, 352-0274, 0918-9325-120

CARAGA REGIONAL HOSPITAL PONCIANO S. LIMCANGCO, MD, MBA,

CEO VI

RIZAL STREET, BRGY. WASHINGTON, SURIGAO CITY Medical Center

Chief I

(086) 826-2459

PhilHealth ALONTO, MASIDING JR. M. Regional Vice President and Office of the

Area Vice President

Concurrent Area Vice President for Mindanao for Area IV

(02) 441-7444 loc. 6201

PhilHealth ALBERTO, ROMEO D. Regional Vice President PhilHealth Regional

Office IX

(02) 441-7444 loc. 6100

PhilHealth DEL ROSARIO, RODOLFO JR. B. Regional Vice President PhilHealth

Regional Office XI

(082) 295-0151

PhilHealth DONATOS, EUGENIO II C. OIC-Regional Vice President PhilHealth

Regional Office XII

(02) 441-7444 loc. 6400

PhilHealth GONZALES, EDUARDO S. OIC-Regional Vice President PhilHealth

Regional Office CARAGA

(02) 441-7444 loc. 6500

PhilHealth MACABATO, KHALIQUZZAMAN M. Regional Vice President PhilHealth

Regional Office ARMM

(02) 441-7444 loc. 6600

modernizing government regulations program philippine

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