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. 2020 Mar 20;13(Suppl 1):1694744. doi: 10.1080/16549716.2019.1694744

Table 3.

Frameworks and typologies of corruption, transparency, and accountability in the health sector.

Framework Purpose Constructs/definitions
EHFCN Waste Typology© European Healthcare Fraud and Corruption Network, 2014
www.ehfcn.org/what-is-fraud/ehfcn-waste-typology-matrix
To clarify anti-fraud definitions; avoid semantic confusion when exchanging information on counter fraud activity; and allow benchmarking Errors: unjustly obtaining a benefit of any nature by unintentionally breaking a rule or a guideline
Abuses: unjustly obtaining a benefit of any nature by knowingly stretching a rule or guideline or by taking advantage of an absence of rule or guideline
Fraud: illegally obtaining a benefit of any nature by intentionally breaking a rule
Corruption: illegally obtaining a benefit of any nature by abuse of power with third party involvement
European Union Corruption in the Healthcare Sector Typology, 2013 (updated 2017)
https://ec.europa.eu/home-affairs/sites/homeaffairs/files/what-is-new/news/news/docs/20131219_study_on_corruption_in_the_healthcare_sector_en.pdf
To come to an analytically, practically and policy-wise meaningful grouping of corruption in health.
To clarify various forms of corruption for a deeper analysis of the drivers and prevalence of corruption in health
Bribery in medical service delivery: Informal payments offered by patients or demanded by service providers. The 2017 update renamed this category “privileged access to medical services” also including use of privileged information
Procurement corruption: Occurring throughout bidding cycle, involves bribes to individuals or institutions, collusion, favoritism, false invoicing, etc.
Improper marketing relations: Problematic interactions between industry and providers or regulators (gifts, money, sponsorship, fees) which may bias decisions. Involves prescription influencing, undue promotion, and influence on market authorization and reimbursement of medicines/medical devices.
Misuse of high-level positions: Regulatory state capture, trading in influence, conflicts of interest, favoritism and nepotism. Involves regulators, political parties, industry and providers.
Undue reimbursement claims: Upcoding, reimbursement of unnecessary or non-delivered treatments. Involves payers and providers.
Fraud and embezzlement of medicines and medical devices: Sale of public or prepaid medicines for private gain; sale of counterfeit medicines; use of publicly owned or financed devices or facilities for private gain. Involves providers.
Double practice: The 2017 update considered risks associated with dual practice.
Typology of Individual and Institutional Corruption
Sommersguter-Reichmann, et al., 2018, citing Thompson (2013) and Oliveira (2014)
To help determine what is to count as corrupt and to help prevent conduct already known to be corrupt Individual corruption: When an institution or a public official receives a personal gain or benefit in exchange for promoting private interests (usually undeserved). The conduct does not serve the institution and involves a quid pro quo motive.
Institutional corruption: When an institution or a public official receives a benefit while providing a service to the benefactor under conditions that undermine procedures that support the primary purposes of the institution.
Five Key Actors in the Health System, William D. Savedoff and Karen Hussmann, 2006 To identify possible types of corruption based on opportunities and interests that encourage corrupt behavior among the different categories of actors involved and the complexity of their multiple forms of interaction Government regulator. Defines and approves norms for construction, equipment, medicines approval and control which can affected by state capture; may accept bribes to overlook compliance issues; inspectors may extort suppliers or providers.
Payer e.g. social security, private or public health insurance. Affected by supplier influence on decision-makers (bribes, kickbacks related to procurement). May set negative incentives to save costs.
Drug & Equipment and Other suppliers. May attempt to influence prescription and treatment practices, could engage in corruption in medicine and equipment procurement, procurement of facilities and ambulances.
Provider. May engage in over-provision, overbilling, phantom patients, absenteeism, unnecessary treatment and prescriptions, demand informal payments
Patients. May engage in fraud in beneficiary ID use, or understatement of income to obtain benefits
OECD framework of integrity violations in health care systems, Couffinhal and Frankowski, 2017 To link health care system actors to the main types of integrity violations they are involved in; to help organize categories of policy options to tackle integrity violations Actors
  • Regulators (ministry or dedicated agencies)

  • Payers (entities that pool funds and finance care)

  • Suppliers and manufacturers of medical goods and services

  • Providers of medical goods and services

  • Individuals (patients, tax-payers, or the insured)

Categories of integrity violation
  • Integrity violations in health service delivery, payment and coverage (denial of coverage, payroll tax evasion, informal payments, absenteeism, and over-billing).

  • Integrity violations in procurement and distribution (bid-rigging, kickbacks, SF medicines).

  • Inappropriate business practices (gifts and advantages to influence prescribing; corruption to influence regulation of private insurance market; bribes to obtain license or accreditation, systemic corruption).

Framework of Corruption in the Health Sector, Vian, 2008 To model the proximate causes and enabling factors that promote or impede corruption in the health sector Proximate causes for individual corruption include opportunities to abuse power (gaps in control systems, excess discretion, etc.); pressures or incentives (which provide motivation to abuse), and rationalizations (how agents justify abuse of power).
Enabling factors which allow individual or institutional corruption include monopoly (limiting choice or ability to exit a corrupt system); too much discretion (autonomous power to make decisions); lack of accountability; lack of transparency; weak citizen voice (participation of citizens in planning and monitoring government); and inadequate detection and enforcement.

EHFCN = European Healthcare Fraud and Corruption Network; SF = Substandard or Falsified; ID = Identification card Sources: EHFCN. EHFCN Waste Typology ©. 2014; www.ehfcn.org/what-is-fraud/ehfcn-waste-typology-matrix. Accessed 7 August 2018; Ecorys. Study on Corruption in the Healthcare Sector. HOME/2011/ISEC/PR/047-A2. October 2013. Luxembourg: Publications Office of the European Union; 2013; Ecorys. Updated Study of Corruption in the Health Sector. Final Report. Brussels: European Commission;2017; Sommersguter-Reichmann M, Wild C, Stepan A, Reichmann G, Fried A. Individual and Institutional Corruption in European and US Healthcare: Overview and Link of Various Corruption Typologies. Applied Health Economics and Health Policy. 2018;16(3):289–302; Savedoff WD and Hussmann K. Why are health systems prone to corruption? p. 4–16 in Transparency International, Global Corruption Report 2016: Special Focus Corruption and Health, London: Pluto Press. 2016; Vian T. Review of corruption in the health sector: theory, methods and interventions. Health Policy Plan. 2008;23(2):83–94; Couffinhal A, Frankowski A. Wasting with intention: Fraud, abuse, corruption and other integrity violations in the health sector. In: OECD, ed. Tackling Wasteful Spending on Health. Paris: OECD Publishing; 2017:265–301.