In an indication that fraud remains a significant problem in relation to the implementation of the National Health Security (Jaminan Kesehatan Nasional – “JKN”) program, the Indonesian Government has mandated that the Social-Security Agency for Health (Badan Penyelenggara Jaminan Sosial Kesehatan - “BPJS for Health”) should improve the implementation of JKN program.[1]
In line with this mandate, the Minister of Health (“Minister”) has issued Regulation No. 16 of 2019 on the Prevention and Management of Fraud and the Imposition of Administrative Sanctions for Acts of Fraud in Relation to the Implementation of the Health Insurance Program (“Regulation 16/2019”), which updates provisions originally set out under Regulation No. 36 of 2015 (“Regulation 36/2015”), [2] which bore the same title.
......