The moves to increase the transparency of medical fees are definitely laudable and welcome.

However, one should tread carefully in adopting the suggestion that formal guidelines be published.

Mr Edmund Khoo Kim Hock ("Competition Act should not apply to healthcare"; last Friday) implied that the abolition of the Singapore Medical Association (SMA) guidelines on fees resulted in overcharging.

The same proposition surfaced in an earlier report ("Listing of op fees at private hospitals helps patients"; Oct 6), which cited the example of Dr Susan Lim.

Such assertions oversimplify the complex causal links and market forces involved.

It must be emphasised that the fee guidelines abolished by the Competition Commission of Singapore (CCS) in 2010 were not based on actual price data.

Among other things, the CCS' findings revealed that the fee guidelines were based on the fees stated by SMA members, as opposed to the actual prices charged or actual operating costs.

Moreover, the purpose of the fee guidelines was to recommend what prices should be, rather than to reflect what the prices were.

This is unsurprising since the doctors polled by SMA undoubtedly had a conflict of interest.

In contrast, the operation fees published by the Ministry of Health are based on actual transacted fees submitted by public and private hospitals. The data would hence be more transparent and reliable.

Tellingly, the inherent problems with a prescriptive set of guidelines are acknowledged in the 2016 Handbook on Medical Ethics published by the Singapore Medical Council.

In a section dealing with overcharging, it is rightly noted that the danger of a fee threshold is that doctors might charge at the upper end, irrespective of the circumstances and context.

Therefore, a strong case can be made that the descriptive approach regulated by the ministry, founded upon clear and sound policy, is preferable to the SMA's guidelines on fees.

Alfie Lim Si En