On August 29, 2025, the Ministry of Health issued Decision No. 2775/QD-BYT and Decision No. 2776/QD-BYT, respectively issuing professional documents "Guidance on technical procedures for diagnostic imaging" and "Guidance on technical procedures for interventional electrophoresis - Volume 1. These two documents include a total of 555 technical procedures, built to standardize professional practice, improve the quality of medical services and ensure safety for patients.
However, during the implementation process, the Ministry of Health received feedback from some localities and medical examination and treatment facilities stating: The social insurance agency has used the technical implementation time recorded in the instructions as a basis for refusing to pay health insurance costs, if the actual time is shorter than the reference time (such as X-ray scans under 6 minutes, heart ultrasounds under 30 minutes).
Faced with this situation, the Ministry of Health has sent a document to the Ministry of Finance, clearly stating its views to ensure the unified implementation of the law and protect the legitimate rights of health insurance participants as well as medical examination and treatment facilities.
The time in the guide is for reference only.
According to the Ministry of Health, the time parameter in the technical procedure guidelines is only the average time, built on the basis of common professional practice, not a mandatory legal condition and not a rigid quantitative criterion for inspection and health insurance payment.
Notably, the Ministry of Health emphasized: The recorded time on technical systems such as PACS, DICOM files or device logs only reflects the operating time of the machine, not covering the entire technical process. In fact, the service implementation process also includes many steps such as patient pick-up and drop-off, information confirmation, medical history exploitation, posture guidance, explanation, reading and evaluating results, consulting and returning results.
Therefore, the use of individual equipment time parameters for comparison and refusal of health insurance payment is not in accordance with the nature of the technical process.
The Ministry of Health also affirmed that the duration of performing technical services may vary depending on the patient's clinical condition, professional requirements, human resource level, facilities conditions and the modernity of equipment at each medical facility.
No assessment, health insurance payment based on technical time
Regarding the principle of health insurance payment for electro-optical technical services, the Ministry of Health clearly stated: the inspection and payment are not based on the time parameters in the technical procedure guidelines.
Instead, the social insurance agency needs to comprehensively assess medical records and actual service provision, including: the suitability of the indication, compliance with key professional steps, clinical value of technical results and actual conditions for human resources and equipment at the medical examination and treatment facility.
Currently, payment for services such as X-rays, CT scans up to 32 rows, ultrasound, magnetic resonance imaging (MRI) has been specifically regulated in Circular No. 35/2016/TT-BYT and related amended and supplemented circulars.
In case of detecting abnormal signs or abuse of technical services, the Ministry of Health said that social insurance agencies need to coordinate with medical facilities and state management agencies to inspect and verify according to their authority and legal procedures, instead of mechanically applying time criteria.
Ensuring the rights of patients and medical facilities
The Ministry of Health requests the Ministry of Finance to direct the Social Insurance agency to conduct inspection and payment in accordance with regulations, especially not to use time parameters in the guidance on electronoptical technical procedures to refuse health insurance payment.
According to the Ministry of Health, unifying this understanding and application is necessary to ensure the rights of health insurance participants, and at the same time create conditions for medical examination and treatment facilities to feel secure in deploying techniques and improving service quality.
In the process of implementation, if difficulties and obstacles arise, the Ministry of Health requests units to report in writing for timely consideration and resolution.
