Late health insurance data submission to face administrative penalties

01/10/2026 10:50 AM


This is one of the provisions in the draft Circular stipulating the application of information technology, digital transformation, and data sharing in the health insurance sector, which is being developed by the Ministry of Health and is open for public consultation until October 7, 2026.

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The Ministry of Health is drafting a Circular stipulating information technology application, digital transformation, and data sharing in the Health insurance (HI) sector. According to the draft, the scope of regulation includes common code sets applicable to HI-covered medical examination and treatment (MET); standards and formats for electronic data; digital signatures for authentication and transmission of data requesting payment of HI-covered MET costs; electronic transactions; information technology application, digital transformation, and data sharing in the HI sector.

The draft applies to HI-covered MET facilities, social security offices, and agencies, organizations, and individuals involved in the application of information technology and digital transformation in the HI sector.

One notable provision concerns the timing of electronic data submission. According to the draft, healthcare facilities must submit electronic data on HI-covered MET costs that have been authenticated with a valid electronic digital signature to the HI Assessment Portal “within a maximum of 03 hours from the time the patient’s MET visit ends,” except in cases permitted to submit data late under the regulations.

Within 15 days from the date the patient’s MET visit ends, the healthcare facility must verify and reconcile the submitted data with the actual data; submit the official data authenticated with a digital signature to request assessment and payment; and perform the procedure for submitting a request for assessment and payment of HI-covered MET costs. Data for which an assessment and payment request has been submitted shall be the final data and may not be replaced or adjusted, except otherwise stipulated.

The draft also stipulates the response responsibilities of the HI Assessment Portal. Within 15 days of receiving the HI claims payment request,  the HI Assessment Portal must provide the MET facility with a complete and detailed notification of the results of the assessment of electronic data on HI-covered MET costs. The results of the electronic data assessment must clearly show the amount agreed to be paid by the HI fund for each specific type of MET service provided to each patient; and the amount refused for payment, clearly stating the reasons and the specific legal grounds for each type of MET service.

The draft Circular also stipulates reminders, warnings, payment refusals, and the identification of errors when electronic data are submitted, responses are provided, or assessment results are notified later than the prescribed time limits due to subjective causes. Accordingly, the HI Assessment Portal must be equipped with functions to issue monthly reminders and warnings when MET facilities submit electronic data later than the time limit prescribed in this Circular, except for objective causes permitted late submission under the regulations.

In cases where the HI Assessment Portal has issued reminders and warnings but the healthcare facility still submits electronic data late, the social security office shall issue a written notice to the healthcare facility to issue a first and second warning.

In cases where the social security office  has issued a second written reminder but the healthcare facility continues to submit electronic data late for the same reason, depending on the nature and severity of the violation, the social security office shall impose administrative penalties or recommend that a competent authority impose administrative penalties in accordance with the law on administrative sanctions in the healthcare sector.

The draft also clearly stipulates cases in which payment is refused; the security and management of electronic data; and the responsibilities of relevant agencies, etc.

The draft Circular will be open for public consultation by the Ministry of Health until October 7, 2026. These provisions are expected to take effect from January 1, 2027, replacing Circular No. 48/2017/TT-BYT dated December 28, 2017 of the Minister of Health, which stipulated the extraction and transfer of electronic data in the management and payment of HI-covered MET costs./.

Tuấn Anh