A comparative review of health care and occupational health systems across selected Asian countries

Abstract

Objectives

Japan increasingly relies on foreign workers from Vietnam, Indonesia, Thailand, the Philippines, and Nepal to address domestic labor shortages. This article describes and evaluates the present state of health services, insurance frameworks, workers’ compensation, and occupational health systems across these five nations, and assesses their readiness to implement standardized overseas health check-ups comparable to Japanese requirements.

Methods

We conducted a scoping comparative review examining national health system architecture, occupational health governance, regulatory frameworks, worker compensation mechanisms, and health workforce trends. Evidence was synthesized from peer-reviewed literature and official legal and policy documents.

Results

Substantial heterogeneity was observed in the legal maturity, institutional capacity, and operational implementation of occupational health examination systems. Overseas health check-ups demonstrated the greatest feasibility in Thailand, with Vietnam, Indonesia, and the Philippines exhibiting moderate readiness subject to targeted regulatory enhancements. Nepal requires considerable capacity-building and legislative reform prior to implementation. These disparities underscore the imperative for accelerated Association of Southeast Asian Nations -level harmonization to advance shared standards and structured technical cooperation.

Conclusions

Thailand demonstrated the highest level of systemic preparedness, followed by Vietnam and Indonesia. The Philippines occupies an intermediate position, while Nepal remains at a nascent stage of development. These findings constitute preliminary comparative evidence to inform policy deliberations by the Government of Japan regarding overseas occupational health check-ups for returning migrant workers, subject to policy decisions and intergovernmental collaboration.

Introduction

Japan is at the forefront of the global demographic transition. Labor shortages, indicative of decreases in the working-age population, have persisted since 1995¹⁾. As a consequence, Japan will increasingly depend on foreign workers to sustain production levels. It is estimated that, in 2030, Japan will experience a labor supply shortage of over 3.41 million people; by 2040, that number will climb to over 11 million²⁾.

There are considerable differences in the characteristics of foreign workers in Japan depending on their country of origin, immigration status, industrial sector, and the size of the firm employing them. In 2021, China and Vietnam accounted for approximately 25% of the foreign workforce in Japan, with four additional Asian nations (ie, the Philippines, Nepal, Korea, and Indonesia) together equally accounting for an additional 25%³⁾.

Foreign workers are classified into those entering Japan through the Technical Intern Training Program (TITP) and those entering through the Specified Skilled Worker (SSW) program. The TITP was established as a formal program in 1993^1,4,5). As part of the TITP, trainees are placed with a specific employer and are allowed to work in Japan for 3–5 years without their families¹⁾. Trainees employed via the TITP are concentrated in the manufacturing (58%) and construction (17%) industries^1,5). Approximately three-quarters of foreign workers entering Japan via the TITP come from Vietnam, Indonesia, and the Philippines¹⁾. The SSW program was implemented in 2019^1,4,5) as an extension of the TITP.

Although labor migration generates mutual benefits, it also entails risks. Occupational hazards remain a major global public health concern. The burden of disease attributable to select occupational risk factors accounts for approximately 1.5% of the global disease burden measured in disability-adjusted life years⁶⁾.

In Japan, the personal health record notebook (nPHR) is issued to workers who have been engaged in high-risk occupational activities, such as those associated with cancer, by the Director General of the Prefectural Labor Bureau upon or after retirement⁷⁾. It is vital for these workers to have the nPHR as part of their health management, including continuing health examinations after returning to their home country. However, the current system does not support inspections overseas in line with the nPHR. Thus, to effectively address this issue, it is essential that nations with bilateral agreements regarding the training of technical interns with Japan and that supply a significant proportion of the foreign worker labor force have medical institutions that can conduct health examinations after workers have returned to their home country.

In line with this, the Department of Environmental Medicine, Kochi Medical School has implemented the Overseas Health Checkup Initiative (OHCI) study, commissioned by the Ministry of Health, Labour and Welfare since 2023⁷⁾. In this study, “overseas health checkup” is defined as a health examination conducted in the home country for returning workers to detect occupational diseases. This study aimed to describe and critically assess the current state of health services, health insurance frameworks, workers’ compensation insurance, and occupational health (OH) systems in five countries — Vietnam, Indonesia, Thailand, the Philippines, and Nepal — and to examine the feasibility of establishing systems comparable to those in Japan to support standardized medical checkups for all workers, including returnee foreign workers. To this end, we conducted a comparative review regarding certain key areas of the healthcare and OH systems in those countries, which are partner countries in this collaborative study.

Methods

Study design and scope

We conducted a scoping comparative review to map national health system architecture (ie, governance, service delivery, and quality assurance), OH systems (ie, governance, legal/regulatory frameworks, compensation and scheme for workers), and health workforce availability and trends (physicians, nurses/midwives, and hospital beds) in Vietnam, Indonesia, Thailand, the Philippines, and Nepal.

Data sources

In this study, we used a multistream search strategy integrating peer-reviewed literature, official legal/policy texts, and statistical portals, as follows:

• academic databases: PubMed/MEDLINE, Scopus, and Google Scholar for empirical and policy analyses on health systems, OH systems, and workforce dynamics

• legal/policy repositories:

 ∙ International Labour Organization (ILO) NATLEX database and national gazettes for primary laws and regulations

 ∙ ministry portals (health or labor) for decrees or circulars

• statistical and monitoring portals:

 ∙ World Bank Open Data

 ∙ national yearbooks (eg, Vietnam Health Statistics Yearbook)

The literature review was conducted over the period from June to December 2025, with two reviewers involved in the identification, screening, and selection of relevant literature.

Results

Basic information

All the countries, with the exception of Nepal, are located in Southeast Asia. The largest and the most populous country is Indonesia. Consequently, among the five countries, Indonesia has the largest total labor force and gross domestic product (Table 1)^8,9). In terms of workforce demographics, Vietnam ranks highest in the number of workers in Japan, followed by Indonesia (Figure 1A)³⁾.

Table 1. Basic information for each of the countries included in the study.

	Vietnam	Indonesia	Thailand	Philippines	Nepal
Population (2025), n	101,598,527	285,721,236	71,619,863	116,786,962	29,618,118
Median age, years	33.4	30.4	40.6	26.1	25.3
Total labor force (2024), n	57,133.48	143,143,940	40,623.02	50,979.29	8,435.34
Area, km2	310,070	1,811,570	510,890	298,170	143,350
Number of administrative divisions	34 provinces	38 provinces	77 provinces	82 provinces	7 provinces
GDP (nominal), USD	429.7 B	1.371 T	514.9 B	437.1 B	40.9 B
Number of accredited sending organizations	450	522	56	334	497
Date MoC concluded	June 26, 2017	June 26, 2019	March 27, 2019	November 21, 2017	January 1, 2024

B, billion; GDP, gross domestic product; T, trillion; MoC, memorandum of cooperation.

Fig. 1.

(A) Number of foreign workers in Japan according to workforce category and the (B) population and (C) labor workforce in Vietnam, Indonesia, Thailand, the Philippines, and Nepal.

All five countries actively participate in Japan’s TITP, sending temporary technical trainees to build skills, pursuant to bilateral government arrangements, and have concluded memoranda of cooperation (MoC) with Japan. The MoC between these countries and the Japan International Training Cooperation Organization ensure ethical recruitment, skills and language testing, and the protection of workers’ rights⁴⁾. Each country has a main body that is responsible for migrant workers overseas, whereas sending agencies are the key operational stakeholders that directly interact with workers.

Indonesia has the highest number of sending agencies, followed by Nepal, which aligns with these countries’ large overseas labor workforces. Regarding the MoC between the Japan International Training Cooperation Organization and the five countries, Vietnam (2017) and Philippines (2017) early adopters. Indonesia and Thailand (2019) followed, and Nepal (2024) being the most recent, indicating either a newer engagement or a refreshed policy framework⁴⁾ (Table 1).

Overview of health systems

There are differences in the healthcare systems in the five countries at the national level (Table 2), including in terms of healthcare provision, what key stakeholders are involved, how quality is monitored and the insurance system. However, all of them share the same fundamental goal: to improve population health.

Table 2. Healthcare systems in each of the countries included in the study.

Indicator	Vietnam	Indonesia	Thailand	Philippines	Nepal
Governance structure	Centralized under MoH Four administrative levels ranging from national to commune	Decentralized, District and provincial health offices responsible for planning and financing	Strong central role of MOPH with autonomous agencies (NHSO, HAI)	Fragmented between DOH and LGUs after devolution (1992)	Three-tiered federal structure since 2015 Constitution
Service delivery	Commune health stations, district hospitals, and tertiary hospitals	Puskesmas (primary care) supported by Class A–D hospitals	Health centers and hospitals devolved to local governments under Decentralization Act B.E. 2542 (1999)	Rural health units, Barangay health stations, provincial hospitals	Health posts, PHC facilities, and district/provincial hospitals
Health insurance/ coverage	Compulsory SHI since 1992 Nearly universal coverage with gradual quality reforms	Jaminan Kesehatan Nasional: single-payer UHC scheme since 2014	UCS since 2002 integrating SHI and CSMBS	PhilHealth: national insurer expanded under Universal Health Care (UHC) Act of 2019	NHIP since 2016 to promote UHC
Managing agency	Vietnam Social Security and MoH	BPJS Kesehatan (social security administrative body)	NHSO	Philippine Health Insurance Corporation (PhilHealth)	Health Insurance Board under MoHP
Accreditation body	Vietnam Administration of Medical Services	KARS (Indonesia Hospital Accreditation Commission)	HAI	DOH-BHFS, PhilHealth, ISO certifiers	MoHP
Coverage level	All levels from central to district hospitals	All public and private hospitals nationwide	Most hospitals, public and private	Public and private hospitals, primarily urban centers	Selected hospitals; mostly public sector

BHFS, Bureau of Health Facilities and Services; CSMBS, Civil Servant Medical Benefit Scheme; DOH, Department of Health; HAI, Healthcare Accreditation Institute; ISO, International Organization for Standardization; LGUs, local government units; MoH, Ministry of Health; MoHP, Ministry of Health and Population; MOPH, Ministry of Public Health; NHIP, National Health Insurance Program; NHSO, National Health Security Office; PHC, Primary Health Care; SHI, Social Health Insurance Scheme; UCS, Universal Coverage Scheme; UHC, Universal Health Coverage.

Vietnam

The healthcare system in Vietnam functions as a mixed model, incorporating both public and private sectors. Healthcare is organized into four administrative tiers: national/central (Level I), provincial (Level II), district (Level III), and commune (Level IV). Provincial (Level II) facilities serve a population of 1–2 million, district (Level III) facilities serve a population of 100,000–200,000, and commune (Level IV) facilities serve a population of approximately 5,000–10,000^10,11). The Ministry of Health (MoH) oversees health policy and regulation through a centralized, top-down approach. Primary healthcare services are delivered at the communal and district levels, which serve as the foundations of the Vietnamese national health program. Specialist medical secondary and tertiary care is provided at the provincial and central levels^10,12). The MoH provides guidance on the provision of healthcare and the relationship between higher- and lower-level institutions, known as the Direction of Healthcare Activities or Chỉ đạo tuyến in Vietnamese¹²⁾. A compulsory hospital quality management system was introduced in 2013 (Circular No. 19/2013/TT-BYT) to standardize service delivery and performance evaluation. Issued on July 12, 2013, this Circular serves as the foundational regulation for hospital quality management in Vietnam^13,14).

Indonesia

Indonesia’s health system is characterized by a decentralized and pluralistic architecture^15,16,17,18). Since the 1999 decentralization reforms, responsibility for the planning, financing, and management of local health services has shifted substantially to provincial- and district-level health offices^17,18,19). At the primary care level, the Puskesmas (community health centers) serve as the backbone of service delivery, supported by village health posts (Poskesdes) and integrated community health posts (Posyandu)^16,18,20). To implement the provisions of Article 24 of Law Number 44 of 2009 concerning hospitals, the classification of hospitals is regulated through the Indonesian MoH. At the secondary/tertiary level, hospitals operate under a tiered classification system (Class A–D), with increasing service capacity, specialist staffing, and referral functions from Class D to A hospitals^19,20,21). The Indonesian hospital certification standard determined by the number of service units or departments was assessed during the survey. All public and private hospitals are subject to mandatory accreditation overseen by the Komisi Akreditasi Rumah Sakit, a formal governmental entity for hospital certification that subsequently evolved into a more autonomous organization^22,23).

Thailand

Thailand’s health system is characterized by a strong public-sector foundation and extensive government-led service delivery network^15,24). The Ministry of Public Health (MOPH) leads national policy, whereas several autonomous agencies, such as the Health Systems Research Institute (1992), Thai Health Promotion Foundation (2001), and National Health Security Office (NHSO), enhance system governance and accountability^25,26). The Thai Health Promotion Foundation, financed through “sin tax” revenues, supports nationwide health promotion initiatives; the National Health Commission facilitates participatory policy making through the National Health Assembly; and the Healthcare Accreditation Institute (HAI) advances quality improvement by fostering local ownership, funding mechanisms, and hospital accreditation processes^24,26,27). The HAI, which has no contractual connection with hospitals, collaborates with the NHSO and leverages its financial incentives to improve quality assurance and accelerate accreditation^28,29). The existing accrediting structure is founded on the HAI’s Hospital and Healthcare Standards³⁰⁾. The Decentralization Act 1999 requested that the MOPH devolves all public healthcare facilities to the local elected government units, health centers to Tambon (subdistrict) administrative organizations, district hospitals to municipalities, and provincial hospitals to provincial administrative organizations^24,26). The introduction of universal health coverage in 2002 was arguably the most significant point in the evolution of Thailand’s healthcare system. The 2002 reforms led to the establishment of the NHSO, which is responsible for managing funds and purchasing services for the universal coverage scheme (UCS). The MOPH oversees the NHSO’s functions via an independent board and has the authority to determine the budget and benefit packages under the UCS^24,29,31). However, the MOPH does not have direct authority over the NHSO²⁴⁾.

Philippines

Healthcare in the Philippines is provided via a mixed public–private and decentralized healthcare system³²⁾. Following the 1992 Local Government Code (R.A. 7160), primary and secondary healthcare services were devolved to local government units, while the Department of Health (DOH) retained roles in policy, regulation, and the provision of tertiary care services. Barangay health stations and rural health units form the community-level service base, supported by municipal and provincial hospitals^32,33). Under devolution, the national government, through the DOH, continues to set the national objectives and policies for the health system, whereas the implementation and delivery of healthcare services at local levels is the responsibility of local governments. More specifically, the provinces assumed responsibility for provincial and district hospitals that provide secondary and tertiary care, and the municipalities within these provinces became responsible for the rural health units that deliver primary care services. Conversely, cities in the Philippines may have their own hospitals and rural health units, and provide both levels of care^34,35,36).

The 2019 Universal Health Care Act strengthened equitable healthcare access through the Philippine Health Insurance Corporation (PhilHealth), the national insurance agency³⁷⁾. Regulation is coordinated by the Health Facilities and Services Regulatory Bureau (HFSRB), which licenses hospitals and synchronizes accreditation with PhilHealth to streamline service delivery. The HFSRB issues licenses for all public and private hospitals. The Act mandates the HFSRB to classify hospitals. Administrative Order No. 2011-0020 issued by the Secretary of Health ordered the automatic accreditation of all DOH-licensed hospitals by PhilHealth^32,38).

Nepal

Nepal’s health system has transitioned from centralization to a three-tiered (federal, provincial, and municipal) structure^39,40). The Ministry of Health and Population (MoHP) leads national policy and coordinates with healthcare facilities at subnational levels to implement policy. The MoHP is the federal-level decision-making authority for health policy and planning in conjunction with the Department of Drug Administration, the Department of Health and Family Welfare, and the Department of Ayurveda^41,42). In Nepal, traditional healers, referred to as Vaidhyas, Dhamis, and Jhankris, have served as the principal healthcare professionals for generations. Various dynasties popularized the Ayurvedic system. Traditional and Ayurvedic healers remain culturally significant, but modern reforms emphasize universal access to healthcare, quality improvement, and system resilience^40,43).

Primary health care, as the first point of contact, constitutes the foundation of healthcare in Nepal and comprises over 7,000 public institutions and approximately 50,000 female community health volunteers delivering preventive and promotive services across the country^39,41). Female community health volunteers are essential in providing fundamental healthcare and health education at the community level^40,44). Zonal and district hospitals constitute the secondary level of the healthcare system in Nepal, with central and regional hospitals providing tertiary care^39,42).

The national policy and strategy on quality of care document (unofficial translation) states that a hospital accreditation system will be established and developed⁴⁵⁾, yet there is limited, publicly available, detailed documentation of a nation-wide hospital accreditation program (with benchmarks, scoring, external surveyors) in Nepal.

Infrastructure and the health workforce

Number of hospitals/health facilities

Vietnam

As of December 31, 2020, Vietnam had a total of 1,029 hospitals, along with 29,644 polyclinics, specialty clinics, and family doctor and health centers, as well as 3,536 other types of medical and treatment facilities distributed over its six regions. Of the 1,029 hospitals, 721 were managed by the government and 308 were private. Across all health facilities, there were 460,097 hospital beds⁴⁶⁾. Nationwide, the public sector accounted for 96% of hospital beds and the private sector accounted for the remaining 4%⁴⁷⁾.

Indonesia

Between 2019 and 2023, Indonesia’s hospital infrastructure expanded significantly. The total number of hospitals increased by 9.7%, from 2,877 in 2019 to 3,155 in 2023. Most hospitals are privately managed (58.6%), followed by those managed by local government (32.2%) and the central government (9.2%). By classification, Class C hospitals dominate (53%), with the fewest number being Class A hospitals (2%). In 2023, there were 10,180 community health centers in Indonesia, comprising 4,210 inpatient and 5,970 non-inpatient community health centers²⁰⁾.

Thailand

Most of the health facilities managed by the MOPH are district public health offices (47%) and community hospitals (42%). The remainder comprise general hospitals (5%), provincial public health offices (4%), and regional hospitals (2%)²⁵⁾. As of 2021, Thailand had an estimated 167,563 hospital beds nationwide. Health facilities managed by the MOPH accounted for the largest share (67.2% of all beds), followed by private hospitals (19.5%), with the rest distributed among other public-sector healthcare facilities.

Philippines

Throughout the Philippines there are 1,351 hospitals, 1,689 drug testing laboratories, and approximately 3,900 primary care facilities, of which 2,593 are rural health units/health centers.

Nepal

In Nepal, public health services are currently delivered through a wider network of 7,221 public health facilities (125 hospitals, 205 primary health care centers, 395 Ayurvedic facilities, 3,870 health posts, and 2,626 community health centers), which fall under the jurisdiction of any of the three tiers of government (federal, provincial, and municipal)⁴¹⁾.

Number of hospital beds per 1,000 people (2000–21)⁴⁸⁾

Between 2000 and 2021, the availability of hospital beds per 1,000 people showed distinct trends across the five countries. Thailand consistently maintained the highest bed density, fluctuating slightly but remaining at approximately 2.0–2.5 beds per 1,000 people, indicating a relatively strong hospital infrastructure. Vietnam demonstrated steady improvement in the availability of hospital beds, increasing from approximately 1.4 beds per 1,000 people in 2000 to over 2.5 beds per 1,000 people in 2017. In Indonesia, hospital bed density increased modestly from approximately 0.6 to 1.4 beds per 1,000 people, signaling gradual progress but still lagging behind neighboring countries. In the Philippines, the number of hospital beds has remained relatively stable at around 1.0–1.3 beds per 1,000 people, while Nepal has consistently had the lowest hospital bed density, remaining at below 0.5 beds per 1,000 people for most of the period from 2000 and 2021 (Figure 2A).

Fig. 2.

(A) The number of hospital beds and trends in the healthcare worker force (B) number of physicians and (C) number of nurses and midwives, in Vietnam, Indonesia, Thailand, the Philippines, and Nepal.

Trends in physician numbers (1990–2023)⁴⁹⁾

From the early 1990s to 2023, the trajectories in the number of physicians per 10,000 population differed among the five countries, with Vietnam and Nepal recording the most significant improvements. Specifically, the number of physicians in Vietnam increased from approximately 5.4 per 10,000 population in 2001 to 11.1 in 2021. Similarly, there was a marked increase in the number of physicians in Nepal from 2.1 per 10,000 population in 2004 to 10.1 in 2023. Gradual but steady growth was recorded in the number of physicians in Indonesia and Thailand (Indonesia: from 0.6 per 10,000 population in 1993 to 5.2 in 2023; Thailand: from 2.3 per 10,000 population in 1991 to 5.4 in 2021), largely due to consistent national programs for physician distribution and universal health coverage reforms. In contrast, the Philippines experienced a decline in the number or physicians, from 11.9 per 10,000 population in 2000 to 7.9 per 10,000 population in 2021, likely due to the outward migration of medical professionals (Figure 2B).

Trends in nursing and midwifery personnel (1990–2023)^49,50)

From the early 1990s to 2023, all five countries recorded a clear upward trend in the number of nurses and midwives, although the pace of growth varied significantly among countries. Thailand achieved one of the largest improvements in the number of nurses and midwives, with an increase from 7.3 per 10,000 population in 1991 to 35.7 in 2023; this reflects the country’s long-term investment in human resources under the UCS. A similar pattern was seen in Indonesia, where the number of nurses and midwives increased from 6.2 per 10,000 population in 1992 to 32.4 in 2023, supported by continuous recruitment programs and decentralization policies that strengthened local health service delivery. Nepal had the steepest proportional growth in the number of nurses and midwives, from 4.5 per 10,000 population in 2004 to 40.9 in 2023, signaling rapid expansion of health training institutions and midwifery education in recent years. More modest increases were seen in Vietnam (from 7.6 per 10,000 population in 2001 to 14.4 in 2016), whereas in the Philippines, which had the highest baseline, the number of nurses and midwives increased from 42.3 per 10,000 population in 2000 to 47.9 per 10,000 population in 2021 (Figure 2C).

Overview of the OH system

The delivery of OH services is crucial for enhancing the health, productivity, and sustainable work capacity of the labor workforce. The different components of the OH systems in each of the five countries, such as governance and key legislation, are summarized in Table 3.

Table 3. Occupational health systems in each of the countries included in the study.

Country	Vietnam	Indonesia	Thailand	Philippines	Nepal
Governance	MOLISA, MoH, VGCL, VIHEMA, NIOEH; multiagency coordination	Ministry of Manpower (Kemnaker) and Ministry of Health (Kemenkes)	Ministry of Labour (DLPW, SSO) and MOPH; DIW for industrial safety	DOLE, BWC, OSHC	MoLESS, DoLOS
Key labor/OSH law	-Vietnam Labour Code 2019 (No. 45/2019/QH14) -Law on Occupational Safety and Health (OSH) 2015 (No. 84/2015/QH13)	-Law No. 1/1970 on Occupational Safety -Law No. 13/2003 on Manpower -GR No. 50/2012 (OSH Management System)	Occupational Safety, Health, and Environment Act B.E. 2554 (2011) (updated in 2019)	-Labor Code of the Philippines (Presidential Decree No. 442) -RA 11058 (2018) -DOLE Department Order 198-18;	-Labour Act,2017 (2074 BS) -Labour Rules,2018 -National Occupational Safety and Health Policy, 2020
Health checkup for workers	Pre-employment and periodic medical examinations (typically annual) or every 6 months required for workers exposed to occupational hazards.	Pre-placement and periodic medical examinations (typically annual) for workers in hazardous or exposure-prone jobs.	Pre-employment and periodic (annual) medical examinations mandated for hazardous work under OSH Act (2011) and ministerial regulations.	Pre-employment and exposure-based periodic medical examinations required under OSHS	PPre-placement and periodic medical examinations are recommended for workers in hazardous or exposure-prone occupations.
Compensation for workers	Labour Occupational Accident and Disease Insurance	BPJS Ketenagakerjaan (JKK)	Workmen’s Compensation Fund	PhilHealth (NHIP) and Employees’ Compensation Fund	Employment Injury Scheme
Compensation scheme	Paid by employer (100%) 0.5% of payroll Flat rate	Paid by employer (100%) 0.24–1.74% of payroll Risk based	Paid by employer (100%) 0.2–1.0% of payroll Risk based	Paid by employer (100%) 0.4–0.6% of payroll Flat rate	Paid by employer + employee 1.4% of payroll
Main bodies for migrant workers	MOLISA: Department of Overseas Labour	-Ministry of Manpower (Kemnaker) -Ministry of Protection of Migrant Workers (Kementerian Pelindungan Pekerja Migran Indonesia)	Ministry of Labour: -Department of Employment -DLPW	Department of Migrant Worker: -Overseas Workers Welfare Administration -Philippine Overseas Employment Administration	MoLESS: -Department of Foreign Employment -Foreign Employment Board

BPJS, Badan Penyelenggara Jaminan Sosial; BWC, Bureau of Working Conditions; DIW, Department of Industrial Works; DLPW, Department of Labour Protection and Welfare; DOLE, Department of Labor and Employment; DoLOS, Department of Labour and Occupational Safety; GR: Government Regulation; JKK, Jaminan Kecelakaan Kerja; MoH, Ministry of Health; MoLESS, Ministry of Labour, Employment & Social Security; MOLISA, Ministry of Labour, Invalids and Social Affairs; MOPH, Ministry of Public Health; NHIP, National Health Insurance Program; NIOEH, National Institute for Occupational and Environmental Health; OSH, Occupational Safety and Health; OSHC, Occupational Safety and Health Center; SSO, Social Security Office; VGCL, Vietnam General Confederation of Labour; VIHEMA, Vietnam Health Environment Management Agency.

Vietnam

Vietnam’s OH system is managed jointly by the Ministry of Labour, Invalids and Social Affairs (MOLISA) and the MoH alongside sectoral ministries and trade unions, such as the Vietnam General Confederation of Labour. Both MOLISA and the MoH have important roles in the administration of occupational safety and health (OSH): MOLISA is responsible for ensuring work safety, whereas the MoH is responsible for the provision, safeguarding, and advancement of workers’ health^13,51,52). Some organizations under MOLISA and the MoH have specific OSH responsibilities, such as the Vietnam Health Environment Management Agency, which has responsibilities related to health and the environmental (eg, environmental health, hygiene, and OH, including occupational diseases and accident/injury prevention), and the National Institute for Occupational and Environmental Health, which is in charge of scientific research, international cooperation, and scientific–technological services related to occupational and environmental health^53,54). At the provincial level, there are 63 offices of the Department of Labour, Invalids and Social Affairs. These offices further support and monitor 697 district divisions⁵⁵⁾.

Vietnam regulates occupational safety and health through the Labour Code 2019 (enacted by the National Assembly and brought into effect in 2021), which includes a dedicated chapter on occupational safety and hygiene. Technical implementation is guided by the Law on Occupational Safety and Hygiene (Law No. 84/2015/QH13) and several decrees, including Circular No. 15/2016/TT-BYT (May 15, 2016) on occupational diseases covered by social insurance^56,57). In Law No. 84/2015/QH13, Chapter II, Section 3 (Labour protection and health care for workers), Article no. 21 (Health check-up and treatment of occupational diseases for workers) states that employers must provide health checkups for workers at least once a year. All the costs associated with these activities are borne by employers⁵⁷⁾. Meanwhile, Articles 23 and 24 of Circular No. 28/2016/TT-BYT (June 30, 2016) on the management of occupational diseases state that examining facilities and provincial health departments are required to “submit biannual and annual reports on occupational disease examination” to the ministry (specifically the Vietnam Health Environment Management Agency under the MoH)⁵⁸⁾.

Indonesia

The Ministry of Manpower, Indonesia’s key sector for OSH, has released an initial national OSH legislation framework. In addition to the Ministry of Manpower, several ministries/sectors have enacted legislation or rules that are similar in nature and contain components related to sectoral OSH⁵⁹⁾. Indonesia’s national legal framework for OSH is governed by Law No. 1 of 1970 on occupational safety, which forms the foundation for all regulations concerning the safety and health of workers. In addition, Government Regulation No. 50 of 2012 on the implementation of the occupational safety and health management system (SMK3) requires companies to integrate safety management systems into their operational activities^59,60).

The Ministerial Decree of Manpower No. 2 of 1980 regulates mandatory OH examinations, including pre-employment, periodic, and special examinations. Companies must establish in-house or outsourced OH units. In addition, public facilities, such as Puskesmas, provide occupational medical services⁶¹⁾. Reporting of occupational diseases must be conducted by company doctors or health facilities to the Ministry of Manpower and the Workers Social Security Agency (BPJS Ketenagakerjaan) through the Work Accident Insurance (Jaminan Kecelakaan Kerja [JKK]) claim system^59,61,62).

Thailand

Thailand’s OSH governance involves multiministerial coordination, with key agencies under both the Ministry of Labour and the MOPH. The Department of Labour Protection and Welfare (DLPW), under the Ministry of Labour, serves as the lead enforcement body, supported by its Occupational Safety and Health Bureau. The Thai Institute of Occupational Safety and Health functions as the national training and research center, promoting OSH knowledge and competency development. Meanwhile, the MOPH, through the Department of Disease Control and Department of Health, oversees medical surveillance, disease reporting, and OH service delivery via provincial and district health offices. The Social Security Office (SSO) administers the Workmen’s Compensation Fund (WCF), ensuring financial protection for workers affected by occupational injuries or diseases. The Ministry of Industry is responsible for issuing permission for factories to be set up and to operate, ordering laws on safety in industrial settings, undertaking inspections to ensure legal compliance, and renewing business permits. The responsible agency is the Department of Industrial Works^63,64,65).

Thailand regulates OSH through the Occupational Safety, Health and Environment Act B.E. 2554 (2011). The law clearly establishes the employer’s responsibility to ensure the safety, health, and welfare of workers⁶⁶⁾. In accordance with the regulations that need to be implemented according to the DLPW, OH examinations are mandatory based on the level of occupational risk. The employer is required to furnish a personal health report book for any employee with work risk factors in the format specified in the Announcement by the Director-General⁶⁷⁾. The Occupational Safety, Health and Environment Act B.E. 2554 (2011) establishes the duty of employers to maintain medical records and report occupational accidents and diseases to the DLPW⁶⁶⁾.

Philippines

In the Philippines, the Department of Labor and Employment is responsible for OSH regulation and supervision. The Occupational Safety and Health Center provides training and resource support. The Bureau of Working Conditions enforces OSH regulations through inspections and compliance audits. Finally, the Employees’ Compensation Commission was established by Presidential Decree (PD) 626 to oversee OSH compensation and rehabilitation^68,69,70). Workplace safety and health in the Philippines is governed by an extensive array of laws, regulations, and initiatives. Republic Act No. 11058 is a significant achievement in Philippine labor legislation. This law prioritizes the protection of workers’ health and safety by strengthening and amending sections of the Philippine Labor Code (PD No. 442, as modified).

The Labor Code comprises seven books, with Book IV embodying the regulations and guidelines regarding health and safety in the workplace^69,70,71). Title I in Book IV of the Philippine Labor Code, which deals with medical, dental and occupational safety, provides a general outline of the medical and dental care that an employer should provide to workers, including medical examinations. Title II, which deals with employees’ compensation and the State Insurance Fund, specifies that employers from both the private and public sectors must contribute to the State Insurance Fund, which, in turn, provides benefits to eligible employees⁷¹⁾. Asbestos-related diseases are included in the list of occupational and compensable diseases under the Employees’ Compensation Program (which was authorized on September 27, 2012)⁷²⁾.

Nepal

In Nepal, the Ministry of Labour, Employment, and Social Security is the main body for national OSH supervision and administration. The Ministry of Labour, Employment, and Social Security is divided into four divisions, and the Ministry is responsible for the development and execution of policies and regulations that pertain to the administration of OSH, social security, juvenile labor, and labor welfare⁷³⁾. The major ministries and agencies for OSH in Nepal include the Ministry of Agriculture and the Ministry of Health. The Department of Labour and Occupational Safety oversees workplace safety, whereas the Labour and Employment Office is the primary enforcement entity in specified areas and at the local level⁷³⁾. There are general provisions on OSH in Nepal’s fundamental legal framework, established by the Labour Act 2017 and Labour Rules 2018^73,74,75). The previous Act was applicable only to businesses with 10 or more employees, but the new Act encompasses a broader range of establishments with more extensive regulations⁷⁵⁾. A Nepali migrant worker is required to procure a certificate of fitness from a government-approved medical center in Nepal, with a government-approved hologram issued by the Nepal Health Professional Federation affixed to the report card⁷⁶⁾. Companies are required by the Labor Act 2017 to notify the Labour and Employment Office of any occupational diseases or accidents⁷²⁾.

Health financing and workers’ compensation

Vietnam

Vietnam operates two main systems. The Vietnam Health Insurance Scheme, overseen by the Vietnam Social Security organization, was established in 1992 and became compulsory in 2015. District hospitals and certain provincial hospitals are established under the capitation system, with most hospitals receiving reimbursement via a fee-for-service model^15,77). Meanwhile, for workers, there is Labour Accident and Occupational Disease Insurance (LAODI) under the Law on Occupational Safety and Health (2015), which compensates workers for occupational injuries and diseases. Employers contribute 0.5% of their payroll to LAODI. Workers affected by occupational diseases receive a daily allowance, reimbursement for medical costs, and disability compensation^13,78).

Indonesia

Since 2014, the Indonesian Government has instituted national health insurance, known as Jaminan Kesehatan Nasional (JKN), which is managed by the national social security agency. The JKN program is administered by two non-profit governmental organizations: the Health Insurance Agency (Badan Penyelenggara Jaminan Sosial [BPJS] Kesehatan) and Workers Insurance Agencies (BPJS Ketenagakerjaan for general workers; Taspen for public officials; Asabri for military and police personnel). BPJS Kesehatan provides general health insurance through the national health insurance (JKN)^18,61).

The health agency uses an alternative methodology for the distribution of funding for referral services. Specifically, funding is distributed according to diagnosis-related groups via a system known as Indonesia Case-Based Groups (INA-CBG)^58,77). BPJS Ketenagakerjaan covers occupational injuries and diseases under the Work Accident Insurance Program (JKK), including treatment, rehabilitation, and death benefits. Different types of employees pay different amounts toward their premiums, based on risk^56,58,59).

Thailand

There have been significant advances in Thailand in extending coverage to the entire Thai population. By 2002, the entire population, including civil servants, was covered by the three public health insurance schemes. Dependents are covered by the Civil Servant Medical Benefit Scheme, private-sector employees are covered by the Social Health Insurance Scheme (SHI), and the remainder of the population is covered by the UCS under the NHSO^24,25,29).

The WCF was created in 1974 under the SSO and provides compensation and care for occupational injuries and diseases. Early in its inception, the WCF applied to industries with 20 or more workers; however, since April 2002, the scope of the WCF has been expanded to include firms with one or more employees nationwide^63,64). The employer bears exclusive responsibility for contributing to the WCF, with contributions collected annually. Employee contributions are limited to Thai Baht 240,000 each year. Employers contribute 0.2%–1% of their payroll to the WCF, with this varying according to risk. The UCS and WCF share service facilities and have a referral coordination mechanism⁷⁸⁾.

Philippines

The Philippines maintains a two-pillar system. PhilHealth administers the National Health Insurance Program, providing general health benefits for the entire population. For worker protection, the Employees’ Compensation Program (ECP), under the Employees’ Compensation Commission and Social Security System, provides occupational injury and disease benefits. The ECP is fully employer-funded, with a standard contribution of 1% of monthly salary credit (private sector) pooled into the State Insurance Fund.

Nepal

The Government of Nepal initiated the Social Health Insurance Program in the Fiscal Year 2015–16, commencing its first phase in three districts, based on the principle of financial risk protection via prepayment and risk pooling in healthcare. Family contributions finance the voluntary health insurance program. Families consisting of up to five members are required to prepay Nepalese Rupee (NPR) 3,500 annually, with an additional charge of NPR 700 for each extra member⁷⁹⁾. Nepal recently developed its social protection framework through the Social Security Act (2017) and Social Security Fund. The Employment Injury Scheme covers occupational injuries and diseases, and is funded by employer contributions (~1.4% of payroll)⁷⁸⁾.

Human resources for occupational medicine

The availability of competent health personnel in the field of OH plays a crucial role in implementing workplace disease prevention programs. However, the training courses for OH physicians vary widely among countries (Table 4).

Table 4. Requirements for occupational health physicians in each of the countries included in the study.

Country	Certification/licensing	Study/course
Vietnam	Certified under the Ministry of Health: specialization in Preventive Medicine with an OH track Must be a licensed MD with OH training (e.g., basic OH course)	OH is part of the Preventive Medicine postgraduate program
Indonesia	Minimum requirement: short course/training for general physician (Hiperkes), certification from the Ministry of Manpower Masters degree in OH with valid competence as a medical doctor Specialist training in occupational medicine (SpOk)	6 days training for Hiperkes 2-year postgraduate program 3–4 year residency program for SpOK
Thailand	Residency program in occupational medicine is offered at major universities Board-certified by the Thai Medical Council in Occupational Medicine	3-year residency in occupational medicine
Philippines	Philippine College of Occupational Medicine provides training, courses, and certifies physicians, accredited by DOLE Licensed MD having completed a basic course in occupational medicine	8-day intensive Basic Course in Occupational Medicine for DOLE accreditation
Nepal	No formal OH medical specialization Training through workshops, NGOs, or international agencies	Short courses or modules (ILO, WHO, regional programs) OH incorporated minimally into medical/public health training

DOLE, Department of Labor and Employment; Hiperkes, Higiene Perusahaan dan Kesehatan Kerja; ILO, International Labour Organization; MD, medical doctor; NGOs, non-governmental organizations; OH, occupational health; SpOk, Spesialis Okupasi; WHO, World Health Organization.

Vietnam

Vietnam does not yet have a formal residency program in occupational medicine. Training is provided through short courses under the preventive medicine program or at the National Institute of Occupational and Environmental Health. Specialists in preventive medicine are often given additional competencies in OH, including the diagnosis of occupational diseases and workplace risk management¹³⁾.

Indonesia

In Indonesia, formal education for occupational physicians is available through the Specialist Program in Occupational Medicine (Spesialis Okupasi) at universities such as Universitas Indonesia⁸⁰⁾. In addition to the specialist route, short-term certification training is available for OH examining doctors and company physicians through OH and safety training centers (Balai K3) and OH centers⁵⁹⁾. This course known as Hiperkes (Higiene Perusahaan dan Kesehatan Kerja).

Thailand

Thailand has a formal training system for occupational physicians. The Residency Program in Occupational Medicine is offered at major universities, such as Chulalongkorn University and Mahidol University. The 3-year program produces board-certified occupational medicine specialists. In addition to physicians, supporting professionals, such as industrial hygienists and OH nurses, follow certification pathways under the MOPH⁸¹⁾.

Philippines

The Philippines has not yet implemented a comprehensive, nationally accredited residency program in occupational medicine comparable to Thailand’s or Indonesia’s specialty track. However, it has developed a tiered professional pathway through the Philippine College of Occupational Medicine, a specialty society affiliated with the Philippine Medical Association. The primary formal pathway is the Basic Course in Occupational Medicine⁸²⁾.

Nepal

In Nepal, there are no formal residency or certification programs in occupational medicine. OH topics are included only minimally in community medicine curricula at medical schools. A small number of professionals receive short-term training from international organizations such as the ILO and WHO⁷³⁾.

Discussion

There are large structural differences between Vietnam, Indonesia, Thailand, Philippines, and Nepal in terms of their health systems, the availability of health facilities and the health workforce, health financing and workers’ compensation mechanisms, OH governance, and the capacity of OH professionals. Consequently, there is variation in the overall preparedness among these countries for cross-border or internationally standardized OH frameworks. Thailand stands out as the most prepared nation, with a robust public health system, well-established OSH legislation (Occupational Safety, Health and Environment Act [2011]), and recognized occupational medicine residency programs. Thailand has a commendable number of hospital beds and nurses per population, supported by strong governance from the MOPH, DLPW, SSO, and HAI. Thailand also has the strongest financing foundation, with its integrated UCS, SSO, and WCF providing comprehensive health and occupational injury protection. The integration of data between the SSO and NHSO positions Thailand as a model for the unification of social security and OH systems in Southeast Asia. The existence of established regulatory pathways further places Thailand in a position of high readiness for cross-border standardized OH frameworks (eTable 1).

Vietnam and Indonesia exhibit upper-medium readiness for cross-border or internationally standardized OH frameworks, although for different structural reasons. Vietnam benefits from a clear vertical organization of the healthcare system and the long-standing Direction of Healthcare Activities mechanism, which strengthens referral coordination and technical supervision between central and provincial hospitals. Vietnam also benefits from a robust financing architecture through the Social Health Insurance system and LAODI, the latter explicitly covering medical costs, rehabilitation, and disability benefits for occupational diseases. Mandatory OH examinations and the national list of 35 occupational diseases also create a strong regulatory foundation. However, overlapping mandates between the MOH and MOLISA, coupled with limited numbers of formally trained OH professionals, continue to constrain full operationalization.

Indonesia shows strengths in terms of the size and distribution of its health infrastructure, with more than 3,000 hospitals, extensive Puskesmas networks, and near-universal insurance under the JKN. Basic OH services are also provided by general practitioners or community health staff in Puskesmas⁶¹⁾. However, OSH regulations are dispersed among multiple ministries, and the lack of a centralized national OH database or standardized reporting system constrains the country’s ability to harmonize worker health assessments. Therefore, regulatory harmonization and information integration are essential. Indonesia’s dual national health insurance arrangement, namely JKN for general health and BPJS Ketenagakerjaan for work-related injuries, provides wide population coverage, but regulatory fragmentation and the absence of a distinct, well-defined occupational disease compensation pathway limit its potential for fully integrated worker health examinations. Because the two programs remain administratively unintegrated, occupational disease claims need to be processed through BPJS Ketenagakerjaan. Nevertheless, the return-to-work program for workers stands out as one of its exceptional and distinctive offerings.

The Philippines scored an intermediate readiness level. The Philippines has a long history of implementing decentralized health governance, enabling local government units to adapt programs to local needs, and the combination of PhilHealth and the ECP provides an integrated platform. However, the allocation of health infrastructure and personnel is predominantly concentrated in urban areas. This imbalance is further exacerbated by disparities in financial access to healthcare services. The passage of Republic Act No. 11058 modernized OSH regulation and created a stronger legal basis for mandatory safety and health programs. Compensation for occupational disorders via ECP and formal worker protection is distinctly defined. Nonetheless, the decentralization to local government units has resulted in disparities in execution and quality; therefore, variations in local implementation, inadequate rural infrastructure, and limited OH workforce numbers hinder system-wide readiness. Meanwhile, Nepal currently exhibits a low readiness for cross-border standardized OH frameworks. Although the Labour Act 2017 and the Social Security Fund/Employment Injury Scheme provide an emerging legal and financial foundation, Nepal lacks a comprehensive system for mandatory health examinations and disease reporting. It prioritizes injury compensation above OH examinations and disease reporting. Limited hospital beds, weak inspection structures, and the absence of formal occupational medicine training significantly restrict Nepal’s preparedness for an integrated worker health examination system.

Across the five countries, various health-OH mechanisms have been implemented, showing varying levels of sustainability, forms of governance, and outcomes. The present comparative analysis underscores the importance of regionally harmonized OH systems in Southeast Asia. Thailand and Vietnam, with their established legal frameworks and institutional capacity, can serve as anchor countries for Association of Southeast Asian Nations (ASEAN)-wide collaboration on standardizing worker health examination policies. Establishing mutual recognition of medical certificates, regional training for occupational physicians, and digital record sharing through secure platforms (eg, ASEAN OSHNET) would enhance efficiency and strengthen collective readiness. Future implementation should focus on ensuring affordability, data integrity, and follow-up mechanisms, transforming overseas health checks from a bureaucratic requirement into a preventive public health instrument that protects both migrants and host communities and evolves alongside rapid industrial and economic growth in the region.

Conclusion

Overall, the readiness landscape highlights a clear gradient among the five Asian countries. Thailand emerges as the most advanced and ready for cross-border standardized OH frameworks, followed by Vietnam and Indonesia, whereas the Philippines occupies an intermediate position and Nepal remains at an early stage of development. This study provides a feasibility assessment of health services, insurance frameworks, workers’ compensation insurance, and OH systems in selected Asian countries. The findings may serve as a reference for future policy considerations by the Government of Japan regarding the potential implementation of overseas health checkups for returnee foreign workers. Any such initiative would depend on policy decisions and require the support and collaboration of the respective national governments.

Supplementary Material

Supplementary eTable 1

Authors’ contributions

LHI analysed the data, prepared the figures/ tables, and drafted the manuscript. ME, JP, TT and NS collaborated to edit and revised the manuscript. All authors completed a review process and approved the final version of the work.

Funding

The Ministry of Health, Labor, and Welfare of Japan provided financial assistance for this work through the Research of Industrial Disease Clinical Research Grants (230101-01). The findings and conclusions presented are exclusively our responsibility and do not reflect the official views of the Japanese government. The funding body did not participate in the study design, data collection, analysis, interpretation, or the decision to submit the manuscript.

Conflicts of interest

The authors declare no conflict of interest.