Logo UNDP'S ONLINE COURSE ON ANTI-CORRUPTION IN THE HEALTH SECTOR UNDP'S ONLINE COURSE ON ANTI-CORRUPTION IN THE HEALTH SECTOR

PROGRESS

General corruption risk approaches applicable to the health sector Overview of actors

2. Organizational level

To assess specific corruption risks in a particular institution, like a public hospital, a proper CRA should be conducted, including the following steps: 

  • Preparation (define strategy, objectives and methodology; select a working group; define responsibilities and leadership.
  • Identification of Risks (data collection, process evaluation, internal ethics environment, management practices).
  • Evaluation of Risks (risk prioritization and documentation, assessment of the adequacy of the existing control measures)

For detailed guidance on how to design and conduct a CRA in a designated institution like a hospital, please refer to the UNDP course on CRA (UNDP 2012: Module III, pg. 5-47).

The tables 1,2 and 3 provides an overview of some of the issues that should be taken into account when applying the methodology at an organizational level, like in the case of a hospital.

Administration
Procurement
  • Engaging in collusion, bribes and kickbacks in procurement processes, resulting in overpayment for goods and contracted services
  • Purchase of expensive technologies (for higher kickbacks)
  • Not enforcing contractual standards for quality
Embezzlement Diverting budget or user-fee revenue for personal advantage
Theft Stealing medicines and medical supplies or equipment for personal use, use in private practice or re-sale
Personnel
Absenteeism  Not showing up for work or working fewer hours than required, while being paid as if full time
Informal payments
  • Extorting or accepting under-the-table payments for services that are supposed to be provided free of charge
  • Soliciting payments in exchange for special privileges or treatment
Abuse of hospital resources  Using hospital equipment, space, vehicules or budget for private business, friends or personal advantage
Favouritism in billing, spending
  • Waiving fees or falsifying insurance documents for particular people
  • Using hospital budget to benefit particular favoured individuals
Theft Stealing medicines and medical supplies or equipment for personal use, use in private practice or re-sale
Sale of position and accreditation Extorting or accepting bribes to influence hiring decisions and decisions on licensing, accreditation or certification of facilities
Payment Systems
Insurance fraud and unauthorised patient billing
  • Illegally billing insurance companies, government or patients for uncovered services or services that were not actually provided, in order to maximize revenue
  • May involve falsification of invoice records, receipt books or utilization records, and/or creation of ‘ghost‘ patients (even ghost hospitals...)
Illegal referral arrangements
  • Buying business from physicians by creating financial incentives or ofering kickbacks for referrals
  • Physicians improperly refering puclic hospital patients to their private practice
Inducement of unnecessary medical procedures Performing unnecessary medical interventions in order to maximize fee revenue

Source: Vian 2006: 50