Private medical insurance is an important component of Singapore’s healthcare financing system. Doctors are increasingly requested to provide medical reports, clinical summaries, diagnoses, treatment details, and in some cases, prognosis to Private Insurers and Third-Party Administrators (TPA). Insurers and TPAs have legitimate administrative functions, including verifying diagnoses and treatment, assessing claims, determining policy coverage, and administering employer medical benefits. However, these functions must be balanced against patient confidentiality, consent, and the doctor’s professional judgement.

Patient Consent

Patients should be notified and their explicit consent obtained before their health information is sent to insurers. This does not require a fresh signature for every request. A valid patient authorisation accompanying the request may provide the necessary basis, provided the consent covers the proposed disclosure and the information is appropriate for the stated purpose. If there is any doubt as to the validity or scope of consent, the doctor should discuss these with the patient.

Consent to disclosure is not consent to unrestricted disclosure. A broad consent form should not be regarded as authorisation to release everything in the medical record. Consent establishes that disclosure is authorised; it does not remove the doctor’s responsibility to consider relevance and necessity. For example, an insurer assessing a knee injury claim may reasonably require information about the diagnosis, treatment, prognosis, and functional consequences of that injury. It does not justify disclosing unrelated psychiatric or gynaecological treatment.

What Information May Insurers and TPAs Request?

Insurers and TPAs have legitimate reasons for requesting medical information. Depending on the circumstances, these may include:

• the patient’s diagnosis;
• the date and circumstances of an illness or injury;
• relevant symptoms and clinical findings;
• investigations performed and their results;
• treatment provided;
• dates of admission, surgery, or treatment;
• • relevant previous medical history;
• • prognosis or functional impairment;
• • whether a condition is related to a pre-existing condition; and
• • whether treatment is clinically related to the condition being claimed.

Clarifying Unclear or Overly Broad Requests

A common difficulty arises when an insurer requests “medical records” or “all medical information” without identifying the claim being assessed. Where the purpose is unclear, clinicians should seek clarification.

A doctor may respond: “The request does not identify the claim, condition, or assessment for which the information is required. Please provide sufficient context so that relevant information can be provided.”

A request for clarification should not be regarded as an unreasonable refusal. Without knowing the purpose, the doctor cannot determine what information is relevant. This remains true even where the patient has signed a broad consent form.

Medical Reports Versus Raw Medical Records

The Ministry of Health’s (MOH) guidance favours the preparation of separate medical reports or clinical summaries rather than routine disclosure of raw medical records.

A medical record is created primarily to facilitate patient care and may contain extensive information unrelated to the insurance claim. An insurance report, in contrast, is prepared for a specific administrative purpose. Doctors should provide information supported by their records, relevant to the stated purpose and within their professional competence. Where information cannot reliably be established, the appropriate response is to state that it is unavailable rather than speculate.

What May a Doctor Decline or Defer?

Doctors have a professional responsibility to limit disclosure to information that is appropriately authorised, relevant, necessary, and lawfully disclosable.

A doctor may appropriately decline, defer, or seek clarification where:

• appropriate patient authorisation is absent;
• the validity or scope of consent is genuinely uncertain;
• the purpose is unclear;
• the information is unrelated to the claim;
• the request is unnecessarily broad;
• disclosure would reveal unrelated confidential information;
• the doctor is asked for an opinion outside his or her competence;
• the information cannot reliably be established; or
• compliance would require prohibited access to the NEHR.

In many situations, the appropriate response is to narrow or clarify the request rather than refuse it entirely.

Clinical Opinions and Insurance Determinations

Doctors should distinguish between providing clinical information and making contractual determinations. If an insurer asks whether a condition falls within a policy exclusion, the doctor can provide the diagnosis, clinical history, and relevant professional opinion. Whether those facts satisfy a contractual definition is ordinarily a matter for the insurer.

Where an insurer asks whether a condition was “caused by stress” or seeks another conclusion that cannot be established from available evidence, the doctor should avoid unsupported speculation and clarify where uncertainty remains.

Outside One’s Knowledge or Competence

Doctors should not provide opinions outside their competence. A General Practitioner (GP) who has referred a patient with a complex orthopaedic injury to an orthopaedic surgeon can provide information from the GP’s own records. If the insurer asks whether the patient has permanent impairment, the GP can explain that the particular question is more appropriately answered by the specialist. This reflects appropriate professional boundaries rather than a refusal to cooperate.

TPAs and Contractual Audit Provisions

The fact that a request comes from a TPA rather than directly from an insurer does not change the principles governing disclosure. The doctor should establish who the TPA is acting for, the purpose, and the specific information required.

Similar considerations apply to panel-doctor contracts containing “right to inspect and audit” provisions. Such clauses should not automatically be interpreted as giving unrestricted access. MOH has reminded insurers that contractual arrangements must not compromise doctors’ legal obligations. Insurers should not ordinarily receive raw medical records merely because an audit clause exists. In exceptional circumstances, appropriately redacted records may be provided where necessary and relevant.

Commercial relationships with TPAs must not compromise clinical independence. Singapore Medical Council (SMC) guidance aims to prevent financial arrangements from influencing clinical judgement.

The NEHR: A Separate Statutory Boundary

The Health Information Act (HIA) 2026 creates an important distinction between a doctor’s own clinical records and the NEHR. Insurers do not have access to the NEHR, and healthcare professionals are prohibited from accessing the NEHR for insurance purposes except in specified circumstances authorised by law.

A doctor cannot respond to an insurer’s request by logging into the NEHR. Patient consent does not provide a general exception to this prohibition. Doctors should rely on their own clinical records, history-taking, and examination when preparing insurance reports.

A Practical Approach for Doctors

When an insurer or TPA request is received, doctors should:

1. Identify the requester. Determine whether the request comes from the insurer, TPA, employer, or another intermediary.
2. Establish the purpose. Identify the claim, condition, treatment, pre-authorisation request, or underwriting issue being assessed.
3. Confirm authority. Check that appropriate patient authorisation or another lawful basis for disclosure exists.
4. Assess relevance and necessity. Determine what clinical information is actually required to answer the stated questions.
5. Consider competence. Provide information and opinions supported by the records and within the doctor’s expertise. Refer specialist questions where appropriate.
6. Disclose selectively. Prepare a focused medical report or clinical summary rather than routinely releasing the entire medical record.
7. Not access the NEHR for insurance purposes.
8. Document the process. Record the request, authority for disclosure, clarification sought, response received, and information ultimately disclosed.

When Should Medical Protection or Legal Advice Be Sought?

Routine reports generally do not require legal advice. Assistance from a medical protection organisation, professional indemnity insurer, or solicitor may nevertheless be appropriate where:

• an insurer demands the entire medical record;
• an audit clause is invoked; consent is absent or disputed;
• the insurer refuses to clarify its purpose;
• unrelated sensitive information may be disclosed;
• contractual sanctions are threatened;
• the doctor is asked to access the NEHR;
• the requested opinion falls outside expertise; or
• litigation is threatened.

Where there is uncertainty, the doctor should first seek clarification. If the dispute persists, professional or legal advice should be obtained before disclosure.

Suggested responses to Insurer/TPA requests

Insurer/TPA request	Suggested response
TPA requests information without clear authority or purpose	Verify the requester, authority, and purpose before disclosure.
“Please provide the entire medical record”	Do not automatically release it; clarify the purpose and consider a targeted report.
Request does not identify the claim or purpose	Seek clarification before disclosure.
“Diagnosis relevant to the claim”	Provide the diagnosis based on clinical records.
“Treatment provided”	Provide relevant treatment information.
“Relevant investigation results”	Provide results relevant to the claim or assessment.
Opinion is requested outside the GP’s expertise	Provide information within the GP’s competence only.
“Prognosis or functional impairment”	Provide an opinion within professional competence only.
“Previous medical history relevant to the claim”	Provide it only where clinically relevant.
Request for unrelated medical history	Clarify or decline/defer disclosure where it is not relevant.
Information cannot be established reliably	State that it is unavailable or cannot be determined; do not speculate.
Request to access the NEHR for insurance purposes	Do not access the NEHR for that purpose.
Patient asks the doctor to obtain information from the NEHR for an insurer	Patient consent does not circumvent the statutory restriction.
Insurer asks doctor to determine whether a policy exclusion applies	Provide relevant clinical facts and professional opinion; avoid unsupported contractual conclusions.

 

Conclusion

The relationship between doctors, TPAs, and insurers requires a balance between legitimate insurance administration and the doctor’s obligations of confidentiality and professional independence. The doctor is not simply an administrative intermediary. The doctor retains professional responsibility for determining what confidential medical information can appropriately be disclosed, in what form, and for what purpose.

The appropriate response depends on the circumstances. A clear, authorised, and relevant request should be met with disclosure; an unclear, overly broad, or unauthorised request should be clarified or declined. When seeking clarification, the response may be: “Please clarify the purpose and specific information required, and I will provide the clinically relevant information that I am professionally and legally able to disclose.” This balances legitimate insurer functions with patient confidentiality and professional independence.

Source: The College Mirror