MOH reduces penalty for doctor who made non-compliant MediShield Life claims

SINGAPORE: The Ministry of Health (MOH) has reduced the penalty it meted out to a doctor and her two clinics for making non-compliant MediShield Life claims.
The two-month reduction in suspension of MediShield Life and MediSave accreditation comes after the Ministry agreed to accept and consider belated representations made by Dr Teo Ching Ching Melissa.
Dr Teo and her two clinics – The Surgical Oncology Clinic and Melissa Teo Surgery – had their accredition suspended for a period of six months in August.
On Aug 5, MOH announced that it had taken enforcement action against six doctors, including Dr Teo, for making inappropriate MediShield Life claims.
“Severe non-compliance” was detected in a MediShield Life claim submitted on Jul 14, 2023 for a surgery Dr Teo had carried out.
The bill she submitted involved six Table of Surgical Procedure (TOSP) codes for procedures which were adequately covered by two codes, MOH said.
This resulted in additional payments from insurance and the patient’s MediSave.
Dr Teo had previously been warned by MOH about similar non-compliances found in her claims, the Ministry said. 
Prior to the announcement, MOH had on Jul 1 notified Dr Teo of its intention to suspend her accreditation and that of her clinics. She was also invited her to submit her representations by Jul 15. 
She did not do so and was served a second notice on Jul 29, informing her of the suspension on Aug 5. 
“Dr Teo and her clinics acknowledged receipt of the notices and did not submit any representations,” MOH said.
However, Dr Teo wrote to MOH requesting for an opportunity to submit belated representations on Aug 19, two weeks after the suspension took effect.
MOH agreed to Dr Teo’s request and received her representations on Sep 6.
Upon “careful consideration” of Dr Teo’s representations, MOH said that it remains of the view that a suspension of Dr Teo and her two clinics is necessary and appropriate in view of her inappropriate coding practices.
“However, in view of additional information disclosed in Dr Teo’s representations, MOH is prepared to reduce the suspension of Dr Teo and her two clinics by two months, provided that Dr Teo successfully completes the mandatory training arranged by MOH to familiarise herself with the guidelines and requirements.”
Dr Teo had provided information on a meeting conducted on Jun 9, 2023 between her and representatives of MOH regarding the TOSP guidelines.
“Having reviewed Dr Teo’s account of the meeting, MOH is prepared to accept that, based on Dr Teo’s account, there is a possibility that she may have misunderstood that it could be appropriate to use multiple TOSP codes in certain situations, in spite of this being against the TOSP coding guidelines.”
The Health Ministry also noted that based on Dr Teo’s submissions, the fees which were directly attributable to her non-compliance were not included in MOH’s announcement on Aug 5.
MOH said that the total hospital bill submitted was S$170,000 (US$123,000) and that S$90,000 were inappropriate claims.
Of that S$90,000 claimed for the four inappropriate TOSP codes, around S$54,000 was certified as surgeon fees – comprising Dr Teo’s personal fees and that of her assistant surgeon – and another S$10,800 was certified as anaesthetist fees by Dr Teo.
The remainder comprised hospital-related fees.
The mandatory training that Dr Teo has to undertake to reduce her suspension will include a proficiency test that she must pass “to ensure that she properly familiarises herself with MOH’s claim submission requirements”.
“MOH will also be closely monitoring Dr Teo and her clinics for future claims,” said the ministry.
The ministry reiterated that “it is inappropriate for doctors to submit multiple TOSP codes where there is an existing TOSP code that sufficiently describes the procedure performed” and that it “takes a serious view against doctors who make inappropriate or wrongful financial claims”.
“Such actions result in higher payouts from MediShield Life, premature depletion of MediSave account balances and additional charges for patients, all of which contribute to escalating claims and insurance premiums.
“The costs are ultimately borne by the wider pool of policyholders.”
MOH said that it will continue to take strict enforcement actions against inappropriate claim behaviour as part of its broader efforts to ensure that the increase in healthcare costs is effected in a sustainable manner, and that insurance premiums remain affordable for all Singaporeans.