"

YAB Dato' Seri Anwar Ibrahim.

Prime Minister of Malaysia.
Pejabat Perdana Menteri Malaysia.
Blok Utama, Bangunan Perdana Putra,
Pusat Pentadbiran Kerajaan Persekutuan,
Putrajaya, Malaysia.

YAB Dato' Seri,

With the greatest respect and in the best interest of the Malaysian public and the medical
profession, we, the undersigned medical associations, submit this memorandum to express
our grave concern over unresolved issues that have severely impacted the private primary
healthcare sector. These issues include the extension of Act 723 (Price Control and Anti-
Profiteering Act 2011) to the healthcare sector and the enforcement of the Medicine Price
Labelling Order 2025 without proper engagement, the stagnation of general practitioner (GP)
consultation fees for more than three decades and the unregulated operations of Third-Party
Administrators (TPAs) within the healthcare ecosystem.

1. Concerns Over the Implementation of the Price Control and Anti-Profiteering Act
2011 (Act 723) and the Medicine Price Labelling Order 2025 on the healthcare sector.

While the medical associations fully support the principle of transparency in medicine
pricing, we strongly object to how the Price Control and Anti-Profiteering (Medicine
Price Labelling) Order 2025 is being enforced on private clinics under Act 723 without
consultation and engagement with the affected medical fraternity, especially GPs .

. Also, many queries were raised as to why Act 723 is being used and on its implementation
and enforcement. However, this promise has not been honoured and all the queries raised
remain unanswered. The policy was implemented on 1st May 2025 with a gazette
announcement only one day earlier on 30th April 2025. There was no dialogue, despite
repeated requests for stakeholder engagement and a separate request to meet the Ministry of
Domestic Trade and Cost of Living by MMA remains unanswered till now.

More importantly, doctors, clinics and the medical associations strongly argue that the
regulation of medicine transparency and display in private clinics must fall under the Private
Healthcare Facilities and Services Act 1998 (Act 586) - not the Price Control and Anti-
Profiteering Act 2011 (Act 723), which is inappropriate for regulating clinical service
environments. Act 5 86 was specifically enacted to regulate private healthcare facilities,
ensuring a balance between clinical governance, patient safety, and fair pricing.

Enforcing a pricing display under a commercial law designed for price control by traders is
ill-suited to the nuanced needs of patient care and could lead to unintended consequences,
such as patients making decisions based on price alone, rather than professional medical
advice.
2. Unrevised Private GP Consultation Fees Since 1992

At an advocacy meeting by the Ministry of Health in February 2025, the Health Minister
clearly and openly stated that any enforcement of medicine price transparency for GP clinics
would only occur after the long-overdue revision of consultation fees is carried out

Consultation fees for private GPs were proposed by the Malaysian Medical Association
(MMA) in 1992 and later adopted into law under the Private Healthcare Facilities and
Services Act 1998 (Act 586) when it was gazetted in 2006. The fees were fixed between
RMlO to RM35 under Schedule 7. Since then, they have remained unchanged for over 33
years. These rates have not reflected the realities of rising operational costs, inflation,
increasing staff salaries, technology adoption, regulatory requirements and the escalating
expectations for documentation and digitalization.

General practitioners play a pivotal role as frontliners in community healthcare, especially in

providing healthcare services. Yet, it remains the only professional sector in Malaysia whose
fees have been frozen for more than three decades. This long-standing neglect has eroded
morale and threatens the sustainability of the clinics, particularly those in rural and semi-
urban areas.

Despite years of appeals by the medical associations, there has been no implementation of a
revised fee schedule. This is unjust and places an unfair burden on private practitioners who
continue to serve the rakyat diligently.

3. Urgent Need for Regulation of Third-Party Administrators (TPAs)

The unchecked operations of Third-Party Administrators (TPAs) continue to place enormous

strain on the private healthcare sector. These entities act as intermediaries between
employers/insurers and GPs, and for years: •

• Arbitrarily impose high administrative fees on clinics;

• Fix low consultation rates, often towards the lower end of the Schedule 7 rate of RM
I 0-35;
• Cause delays in payment of claims, affecting clinic cash flow and operational
sustainability;
• And now, more alarmingly, have begun outsourcing long-term medication
prescriptions to third-party pharmacies via e-prescriptions, bypassing the attending
doctors.

This last practice is especially troubling. It is not aligned with evidence-based clinical
management and threatens patient safety by removing continuity and exposing patients to
increased rates of complications of non communicable diseases.

Since 2015, medical associations have repeatedly raised these issues with the Ministry of
Health and other agencies. Yet, despite the mushrooming of these TP As, there is no specific
legislation or regulatory framework to govern TPA operations in Malaysia's private
healthcare landscape. The continued inaction has emboldened TP As, resulting in the ongoing
commercialisation of healthcare, which compromises ethical practice and threatens patient-
centred care.
4. Foreign Equity Concerns in the Malaysian Healthcare System

There is growing concern regarding the increasing foreign equity ownership in Malaysia's
healthcare sector. While foreign investment brings capital, technology, and expertise, it also
poses risks to national health sovereignty, affordability, and equitable access. The key
concerns are:

Access and Affordability - Foreign-owned private facilities often target medical tourists and
high-income patients, potentially diverting resources from the local population and inflating
healthcare costs.

Regulatory Oversight - A higher presence of foreign entities may complicate regulatory

enforcement, particularly in ensuring compliance with national healthcare priorities and
standards.

Profit-Driven Models - Foreign investors may prioritize profitability over public health
outcomes, risking reduced investments in unprofitable but essential services.

Conclusion and Appeal

YAB Dato' Seri, the Medical Associations and societies as below appeals to your good office
and the Government to urgently:

I. Remove the private clinics from the provisions of Act 723. All policies on
healthcare should be and only be under the ambit of Act 586, which is the
specific Act for the private healthcare facilities and services. As a professional
service playing its role as the guardian of the healthcare of the country, the
i,iedical fraternity demands that it not be grouped as a retail business nnder the
enforcement of the Ministry of Domestic Trade and Cost of Living. The medical
profession stands ready to engage with the Ministry of Health to do what is best
for patients' rights, including price transparency, under Act 586.

2. Direct the Ministry of Health to implement the long-overdue revision of GP

consultation fees nnder Act 586, with the rates being reflective of current
economic realities of operating clinics and the fact that they have remained
unchanged for 33 years.

3. Immediately initiate a national framework to regulate TPAs, including oversight

on their fee structures, administrative practices, and clinical outsourcing. The
commonly given answer by the Health Ministry of it being not under their
domain should not hold and new regulations and/or amendments be made to
regulate them

4. Reassess foreign equity caps in private healthcare facilities, especially in critical

service areas.
 5. Ensnre that all future policies affecting the private healthcare sector, including
pricing and service delivery, is channelled through the proper legal framework
(Act 586) with full stakeholder consultation.

Our healthcare system cannot thrive without a robust and fair private primary care sector.
GPs are not merely service providers; they are partners in public health. But we need fair
policies, appropriate legal frameworks, and meaningful engagement from the government to
continue our role effectively. The closing of clinics, which number around 11,000 presently,
will have a long term effect on primary healthcare in the country and put further strain on the
already overburdened public healthcare facilities.

We trust in your wisdom and leadership to address these long-standing matters and safeguard
the integrity of Malaysia's healthcare system.

With highest respect and sincerity,

Yours faithfully,

Dato' Dr. Kalwinder Singh Khaira

President
Malaysian Medical Association (MMA)

Coo
Assoc. Pr .
President
Academy of Family Physicians of Malaysia (AFPM)

Dr. Shanmuganathan Ganeson

President
Federation of Private Medical Practitioners Associations, Malaysia (FPMPAM)

Dr. Par
President
Malaysian Association of Advancement of Functional and Interdisciplinary Medicine
(MAAFIM)
President
Malaysian Private Dental Practitioners Association (MPDPA)

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President
Medical Practitioners Coalition Association of Malaysia (MPCAM)

Pre • ent
Pertubuhan Doktor-Doktor Islam Malaysia (PERDIM)

President
Society of Private Medical Practitioners Sarawak (SPMPS)

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Dr. Devadas Ramankutty
President
Association of Private Practitioners Sabah (APPS)

President
Private Medical Practitioners Association of Selangor and Kuala Lumpur (PMPASKL)

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Dr Suresh Rajoo
President
Society for the Advancement of Hormones and Healthy Aging Medicine (SAHAMM)