Table 1.

Experts’ evaluation on existing countermeasures for restraining institutional medical corruption

	Countermeasures	Content	Structure	Process	Outcome
1	Fines and criminal penalties ruled by the ‘Penal Law’ (amended, 2006), the ‘Anti-unfair Competition Law’ (1993) and the ‘Interim Provisions on Anti-commercial bribery’ (1996)	Financial fines, imprisonment and cancellation of physician licences	(1) The fines are not high enough to effectively restrain bribery. (2) The punishment differs strikingly when bribers or bribees are in different institutions.	(1) It is well implemented.	(1) Imposing fines and criminal penalties is the easiest and most direct way to restrain medical corruption.
2	Health policy regulations, especially those regarding drugs
2.1	The establishment of the National Reimbursement Drug List (NRDL, 2000) and the Essential Drug List (EDL, 2009)	To select the most therapeutic and economical drugs by the government	(1) The initial lists are incomplete. The adjustment of the lists may induce corruption.	(1) Many of the drugs on the NRDL can still be sold at prices higher than the purchasing price. (2) Hospitals will only purchase drugs that are not on the NRDL if they generate profits.	(1) It makes the drugs on the lists under the government’s high supervision. (2) The ‘zero-profit drug’ policy for the EDL can shrink the benefit space.
2.2	The new centralised purchase policy (2009)	Public tenders, bidding and auction processes relating to the purchase of drugs are mostly operated by provincial governments.	(1) Usually, the purchasing committee is affiliated with the health bureau, and purchasing decision is not made independently. Additionally, many areas have one purchasing institute, leading to monopoly of drug procurement. (2) There are many defects in the selection criteria.	(1) From 2009 according to the strict regulation by the National Health Bureau, the purchasing of drugs or equipment has formal process for execution.	(1) Shifting purchasing power from public hospitals to governments can reduce medical corruption to a large extent.
3	Reporting scheme for medical corruption (2013)	Establishment of a reporting and record-keeping scheme of commercial bribery records	(1) The reporting scheme focuses on adverse behaviours. A comprehensive rating system to rating the companies’ reputation should be established.	(1) The reporting scheme is poorly implemented.	(1) The public can be a constraint force for the corruption.