Overview of Voluntary Health Insurance Laws of Some Countries in the World and Suggestions for Vietnam

high but costly to manage due to the complex management process to limit abuse.

* Case-based payment: Case-based payment is a method of payment to service providers based on treatment standards.

In the Philippines, health care costs are paid for using a fee-for-service model, which shifts financial risks to PhiHealth members by requiring patients to pay the remaining balance (balance billing). The payment model in Thailand is a capitation model, which has ensured cost containment and shifted financial risks to the service provider. Because capitation payments can lead to inadequate service provision, unit costs and service utilization rates must be closely monitored, and people can change their health care provider annually if they are not satisfied with the services of their previous provider [22, pp. 9-19].

- The Unemployment Health Insurance Fund is a collection of monetary contributions to form a centralized monetary fund to pay for Unemployment Health Insurance beneficiaries when Unemployment Health Insurance conditions arise. The Unemployment Health Insurance Fund is mainly formed on the basis of contributions from Unemployment Health Insurance participants. In addition, the Unemployment Health Insurance Fund is also formed on the basis of other legal sources of income such as profits from the fund's investment activities; aid and sponsorship from domestic and foreign organizations and individuals, etc.

The Unemployment Health Insurance Fund is often used to: pay for health insurance medical examination and treatment costs; management costs; invest to preserve and grow the Unemployment Health Insurance Fund; spend on reserves, large labor reserves; spend on reserves to limit losses.

Maybe you are interested!

etc. Thus, the fund's expenditures are very large, so to maintain the stability of the fund, the operation of the Unemployment Insurance Fund must be based on the basis of ensuring health care in terms of revenue and expenditure. That means, in addition to implementing revenue collection,

To effectively implement health insurance, the implementation of fund expenditures must also be carried out strictly to achieve high efficiency in fund use. In addition, it is necessary to have appropriate measures to encourage the majority to participate in health insurance, minimize the situation where only sick people participate in health insurance or thoroughly implement the principle of "the majority compensates for the minority".

In the Lao People's Democratic Republic, the source of contributions to the Unemployment Insurance Fund is mobilized from household contributions, with a fee reduction applied to households with large numbers of participants. Fees are collected monthly or quarterly, deposited in bank accounts and paid to hospitals that have signed a contract for the fund. Similar to other countries in the world, in Vietnam, the Unemployment Insurance Fund is formed mainly from contributions from insurance participants, profits from investment activities and other legal sources of income. This fund is mainly used to pay for medical examination and treatment costs for participants, in addition, the fund is also used for investment to increase the fund according to the principles of safety and efficiency; spending on management of the management apparatus and establishing a reserve fund for medical examination and treatment [22, pp. 9-19].

1.2.4. The role of voluntary health insurance law

The law on health insurance plays an important role in the economic, social and political life of each country. Especially in the trend of integration and general development, each country is increasingly aware of the role of health insurance in general and health insurance in particular in ensuring fairness and sustainable development.

From a social perspective, the law on health insurance is a clear concretization of human rights in society, a tool that contributes to improving the quality, efficiency and social justice in health care. From the recognition of the right to health protection and care in international legal documents, countries have stipulated in national legal documents with high validity such as constitutions, laws, etc. This is an important legal basis for each individual in the community to exercise their rights, while also demonstrating responsibility.

of the state towards citizens in ensuring the right to health care and protection.

In addition, the law on health insurance not only plays a role within the national scope but also has international significance, especially in the current trend of integration and development. Integration and development have become a common trend for all countries in the world towards common prosperity. In that trend, ensuring the right to health care for each citizen becomes an important criterion for assessing national development, progress and civilization. The assessment criteria are not purely based on economic development but also depend on how the country treats its citizens. The law on health insurance and health insurance clearly reflects the attitude and responsibility of the state towards its citizens, and is even an advantage of the country in the competitive market. This also reflects the reality of countries with a solid health insurance system and good service quality such as Denmark and Sweden, which always receive high support in the process of integration and sustainable development, or some countries after joining the European Union have reformed the health insurance system, increased budget spending on health insurance with the aim of creating prestige and competition in the market. On the other hand, with its humanistic values, the health insurance law is no longer limited to the national scope but also overcomes geographical and political barriers to receive the attention of all humanity.

From an economic perspective, as a part of the social security system, the law on health insurance also regulates wealth, reduces the gap between rich and poor, and inequality between groups of people in the face of negative impacts of the market economy. By stipulating that the participants are all people and stipulating a fair contribution rate with a common rate for all classes of people, the benefit level is not based on the contribution level but on the specific level of risk, making health insurance in general and health insurance in particular play the role of an important tool to ensure social justice.

From a legal perspective, the law on health insurance is the institutionalization of the national health insurance policy, so that the health insurance policy can be put into practice and become effective in real life. With specific regulations on health insurance participants, conditions for receiving health insurance, and health insurance regimes, competent state agencies, organizations, and individuals have a clear and specific understanding of the state's health insurance regime, enjoy their rights, and fulfill their obligations in the field of health care for the people.

1.3. OVERVIEW OF VOLUNTARY HEALTH INSURANCE LAWS OF SOME COUNTRIES IN THE WORLD AND SUGGESTIONS FOR VIETNAM

1.3.1. Voluntary health insurance law in Singapore [22]

Singapore is a small island nation in Southeast Asia with an area of 692.7 km 2 and a total population of about 5 million people. Singapore is a multi-ethnic country with many different cultures: 76.8% are Chinese, 13.9% are Malay, 7.9% are Indian, Pakistani, Sri Lankan, the rest are of other origins, but Singapore still establishes and maintains a general social security policy and health care that is among the best in the world. Singaporean law is always interested in regulating

to the issue of health care in general and health insurance in particular to bring about increasingly higher health protection for the community. In 1953, Singapore passed the Central Provident Fund Act (CPF) - a law that specifically regulates social welfare issues, including health insurance.

According to the Central Provident Fund Act 1953 on Health Insurance, in Singapore, employees can participate in health insurance either compulsorily or voluntarily, depending on the law. Singapore law implements compulsory health insurance for employees and their dependents. Employees aged 55 and below with an income of 50-6000SGD/month must pay compulsory health insurance through a health fund used to pay for medical treatment and purchase of health insurance.

Life health insurance is called Medisave. In addition to the subjects that are required to pay compulsory health insurance, Singapore's health insurance law also provides specific regulations on paying voluntary health insurance for those who are not required to pay health insurance. Accordingly, "a Singaporean citizen or a resident of Singapore who is not required to pay the fund may voluntarily pay the fund in the manner prescribed by the Minister" (Clause 1, Article 13B - Singapore Central Provident Fund Law). In fact, although it is not mandatory, many workers and self-employed people in Singapore have proactively participated in this fund to ensure the high cost of medical examination and treatment in Singapore and help them reduce part of their income tax because this health insurance contribution is not taxed.

When participating in health insurance, every month, workers in Singapore will pay a sum of money into the Singapore Provident Fund, which is a social welfare fund formed from contributions from workers, employers and state support. A portion of the monthly central provident fund contribution will be deducted from the medical account. The health insurance contribution level depends on the income and age of the worker.

For health insurance, the contribution level is determined as follows: "the voluntary contribution amount must not exceed 28,800 USD per year". In addition to this standard contribution amount, health insurance participants can make additional contributions. According to Clause 4, Article 7 of the Law on Central Reserve Fund, which stipulates additional contributions by employees, employees can voluntarily make additional contributions to the fund.

In case the employee wants to pay more than the prescribed rate, he/she must notify the employer in writing. Then, the employer will automatically deduct the additional amount from the employee's monthly salary and use this additional deduction to pay into the employee's fund. The employer also has the right to voluntarily pay more for the employee.

These additional voluntary contributions may not exceed $28,800 per year [22].

1.3.2. Voluntary health insurance law in the Philippines [22]

Since 1969, the Philippines has implemented the Health Care Program through the Health Insurance Scheme. In 1995, the Philippines enacted Law No. 7875, which is the first complete legal basis for the implementation of the Health Insurance policy. In 2004, the Philippine Government enacted Law No. 9241, amending several provisions of Law 7875. According to the provisions of the Philippine Health Insurance Law, the long-term goal of the Philippine Health Insurance Scheme is to implement universal health insurance. However, until that goal is achieved, the Philippines still maintains two forms of health insurance: compulsory health insurance and voluntary health insurance. Compulsory health insurance is applied to certain subjects working in the formal sector and subjects receiving state subsidies for medical examination and treatment. Voluntary health insurance is applied to subjects in the informal sector.

In general, health insurance participants in the Philippines are divided into 4 groups with different responsibilities and contribution levels as follows:

- The target group is salaried workers (formal sector) and retirees: these are state officials and employees; workers in enterprises with stable monthly income.

Philippine law stipulates that the contribution rate for wage earners in the formal sector is 3% of the employee's monthly salary, of which the employer contributes half and the employee contributes half.

½. The salary used as the basis for paying health insurance for this group of subjects is based on the basic salary with 15 levels, in which the minimum and maximum salary levels for paying health insurance are specified. For retirees, the Social Insurance will pay health insurance for them.

- The target group is the poor: Because the Philippines still has a high percentage of the poor population in the region, the central and local budgets are not enough to issue health insurance cards to all people.

belong to this group. The subjects in this group participating in health insurance are divided into two types: those who are subsidized by the state for medical examination and treatment and those who participate in voluntary health insurance. However, the group of poor people is still the subject of management and implementation of voluntary health insurance because people who are poor are only temporarily for a period of time, after a few years they will escape poverty and no longer be subsidized by the state for medical examination and treatment, they will participate in voluntary health insurance. Currently, only 5% of people in this group are eligible for health insurance cards according to regulations, the rest participate in voluntary health insurance. If they do not participate in voluntary health insurance, people must pay their own hospital fees when going to the doctor. If people in this group participate in voluntary health insurance, the health insurance contribution level is 1,200 Pesos/household/year. If they are subsidized for medical examination and treatment, the central budget will guarantee 70% of their health insurance, and the local budget will guarantee 30%.

- Overseas workers: Overseas workers can also participate in health insurance in the Philippines with a contribution of 900 pesos/year.

- Group of self-employed workers (informal sector): this group participates in the Unemployment Insurance. The contribution rate for this group is 1,200 Pesos/person/year, collected quarterly, 6 months or once a year.

Regarding the health insurance and unemployment insurance regime, according to Philippine law, the poor are entitled to benefits immediately after being issued a health insurance card, while other subjects are only entitled to benefits after 3 months from the date of payment of health insurance. If they participate intermittently, they must continue to wait after 3 months from the date of payment.

Law 7875 stipulates the rights of participants in health insurance and unemployment insurance as follows:

- The Health Insurance Agency only covers inpatient medical examination and treatment costs for participants when they visit any medical facility approved by PhilHealth.

(an organization established by the Philippine government to implement health insurance policies) assesses and issues certificates. The maximum treatment period covered by PhiHealth is 45 days/person/year for both the main beneficiary and dependent beneficiaries (spouse, parents, children under 21 years old). The payment level is determined for each type of medical service and for each type of hospital.

- The poor are entitled to additional benefits when examining and treating outpatients with the following services: outpatient examination and treatment; tests, diagnosis; medicines and biological products (according to the list prescribed by the Ministry of Health); advice on disease prevention, health maintenance; transportation in case of emergency.

Regarding payment methods for health insurance medical examination and treatment costs: PhilHealth will pay for medical examination and treatment costs in one of the following two methods:

- Payment to medical facilities: when the cardholder comes to see a doctor, the patient will pay the excess amount compared to the regulations; based on the medical records, PhilHealth will pay the medical facility according to the prescribed level.

- Direct payment to cardholders: when cardholders come to see a doctor without presenting their card and pay for the treatment costs themselves, PhilHealth will base on the documents to pay at the prescribed rate to the cardholder.

In short, learning about the Philippine Health Insurance Law, we can see that the country's Health Insurance Law still has two forms of health insurance: voluntary health insurance and compulsory health insurance. Regardless of which form of health insurance is used, the law clearly and flexibly stipulates the rights of cardholders in accordance with each subject regarding the number of days of hospitalization covered by health insurance in a year, the payment level for each type of illness, and the specific contribution level for each subject, etc.

1.3.3. Voluntary health insurance law in the Federal Republic of Germany The Federal Republic of Germany is one of the most successful countries

in the field of health insurance in the world and is the country that originated the model.