Updated: 2026-08-31

What you have is not "nothing" — it is "not that kind of thing." The price-transparency provisions of the Private Healthcare Facilities Ordinance (Cap. 633) — sections 61, 62 and 63are still not in force, and the standardised written fee estimate the Government proposed in May 2025 (together with "a written explanation if the final bill exceeds the estimate by 20%") remains a proposal. ⚠️ But that does not mean there are no rules: the Department of Health's Code of Practice for Private Hospitals, 2026 Edition (version record: first edition June 2019, fourth edition July 2026) contains an entire Part IV: Price Transparency, which states that "Patients have the right to know the fees and charges prior to consultation and any procedure" and "Patients have the right to examine and be given explanation on their bill, including hospital's charges and doctors' fee"; fee schedules must be "readily available" at the admission/registration office, the cashier and nursing stations; price changes must be published 14 calendar days in advance; and the licensee must publish historical fee statistics for specified treatments and procedures in the manner specified by the Director of Health. These are licensee obligations under the Code, not voluntary measures. The Consumer Council's 2025 study found that 39.0% of respondents received only a verbal estimate, 67.2% had encountered a price discrepancy, and of those, 64.9% were given no explanation at all. The Government's May 2025 legislative proposals include a written explanation where the final charge exceeds the estimate by 20% or more — but that is a proposal, not a current rule; the draft regulations are targeted for submission to the Legislative Council in 2026. This article covers what you can ask for today, how to ask, and how to read the numbers. It does not evaluate any facility and does not give medical advice.


What is the "Pilot Programme," and why is it voluntary?

Because the Ordinance was passed but its price-transparency sections were never brought into operation; what fills the gap is a pilot programme that began in 2016 and that hospitals join voluntarily. ⚠️ Remember, though: the pilot being voluntary does not mean there are no mandatory obligations — the duties in Chapter 33 of the 2026 Code of Practice for Private Hospitals sit under the licensing regime and are a different thing from the pilot. See the next section.

The sequence runs like this. The Private Healthcare Facilities Ordinance (Cap. 633) was gazetted on 30 November 2018 (Government reply to the Legislative Council, 8 May 2019). Before the Ordinance, the Government had already launched — from October 2016 — a pilot programme with the Hong Kong Private Hospitals Association to improve price transparency in private hospitals. The Department of Health's platform states in its own words that "all private hospitals in Hong Kong have voluntarily joined the pilot programme."

The pilot has only three measures, which the Health Bureau listed one by one in its 6 March 2025 response to the Consumer Council: "(i) publishing fee schedules for major charge items; (ii) providing patients with service fee estimates for 30 common treatments/procedures; and (iii) publishing actual bill statistics for those 30 common treatments/procedures."

And the legislation? In 2019 the Government's stated aim was "to submit the relevant regulations to the Legislative Council for scrutiny by the end of 2019 or in early 2020." As at 6 March 2025, the Consumer Council's press release still read: "the provisions relating to price transparency in the Ordinance have yet to come into operation."

But "the provisions are not in force" is not the same as "there are no rules" — a point most reporting skipped over.

Who most needs to know: anyone who assumes the Government already regulates private hospital charges by statute. Those sections are not running — but the Code of Practice described below is a licensee obligation, not a voluntary one. And the Government said plainly in 2019 that it does not regulate the level of fees itself.


The part that is not voluntary: Part IV of the Code of Practice for Private Hospitals

A private hospital's licence comes with a code of practice, and that code has a whole part on price transparency.

The Department of Health's Code of Practice for Private Hospitals, 2026 Edition (cover printed July 2026; version record: 1st edition June 2019, 2nd edition February 2022, 3rd edition September 2024, 4th edition July 2026) contains PART IV: PRICE TRANSPARENCY, which is Chapter 33. The following is from the Code itself (an English-language document):

Extracts from Chapter 33, "Price Transparency," of the Code of Practice for Private Hospitals. Source: Department of Health, PHF(E) 11A Code of Practice for Private Hospitals (2026 Edition), cover printed July 2026, retrieved 2026-08-31. Clause numbers are the Code's own.
ClauseSubstance
33.1.1The fee schedule must cover all chargeable items
and be readily available at the
admission/registration office,
cashier and nursing stations
33.1.2Items that cannot carry a fixed price
must be shown as a price range,
or marked available upon request
33.1.3Fee schedules must be kept
for all room classes
33.1.5A price change requires the schedule
to be updated and published first;
the licensee must publish it
14 calendar days in advance
33.1.6During a stay, the patient must be kept
informed of current charges at
appropriate intervals,
hospital charges and doctors' fees alike
33.1.7Patients have the right to examine
their bill and be given an explanation
,
including hospital charges and doctors' fees
33.2.1Patients have the right to know the fees
before consultation and any procedure
33.2.2On admission, staff must respond
to enquiries from the patient or family
about expected charges
33.3.1The licensee must publish historical
fee statistics for specified treatments
and procedures in the manner specified
by the Director of Health

Two sentences worth memorising, in the Code's own words:

33.2.1 Patients have the right to know the fees and charges prior to consultation and any procedure.

33.1.7 Patients have the right to examine and be given explanation on their bill, including hospital's charges and doctors' fee.

⚠️ So what exactly is the part that is "not in force"? Two specific things: (a) sections 61, 62 and 63 of the Private Healthcare Facilities Ordinance themselves, and the regulations to be made under them; and (b) the standardised written fee estimate format proposed by the Government in May 2025, together with the "written explanation where the final charge exceeds the estimate by 20% or more" rule. The Code already requires hospitals to let you know the charges beforehand and to let you examine your bill afterwards; but a uniform, itemised written estimate you can hold in your hand is still at the proposal stage.

The day procedure centre code is written more narrowly. Clause 1.3.9 of the Code of Practice for Day Procedure Centres (2026 Edition) likewise requires that "An up-to-date fee schedule covering all chargeable items must be readily available for reference of patients at the admission or reception office, cashier, and where appropriate," and allows presentation as a price range or "available upon request." ⚠️ But that code has no counterpart provision on historical fee statistics — a page-by-page search of the code for the word "historical" returned 0 occurrences.


If you ask about price today, what can you actually get?

Five kinds of information. Several are licensee obligations under the Code of Practice for Private Hospitals; the rest you have to ask for. And the day procedure centre code is written more narrowly.

The position as at 31 August 2026. Sources: Department of Health, Code of Practice for Private Hospitals (2026 Edition), Chapter 33; Code of Practice for Day Procedure Centres (2026 Edition), clause 1.3.9; Medical Council of Hong Kong, Code of Professional Conduct (Chinese version, 2022), Chapter 12. Retrieved 2026-08-31.
What you can ask forWhereOn what basis
The fee schedule
(all chargeable items)
Admission/registration
office, cashier,
nursing stations
Code of Practice for
Private Hospitals 33.1.1
:
must be readily available
Knowing the charges before
consultation or a procedure
Private hospitalCode 33.2.1:
the patient has this right
Examining the bill and being
given an explanation
(doctors' fees included)
Private hospitalCode 33.1.7:
the patient has this right
Historical bill statisticsThe hospital's website,
or the Department of
Health's common platform
Code 33.3.1: the licensee
must publish them; the day
procedure centre code has
no counterpart provision
The doctor disclosing
the consultation fee
Your attending doctorMedical Council Code 12.1,
but only "upon the patient's
request"

⚠️ On historical fee statistics, the requirement differs between private hospitals and day procedure centres. The Consumer Council's press release of 6 March 2025 states plainly: "Neither the Ordinance nor the Code of Practice for Day Procedure Centres requires day procedure centres to publish historical fee statistics" (unofficial translation of「《條例》或《日間醫療中心實務守則》並無規定日間醫療中心公布過往收費統計數據」). A page-by-page search of the 2026 Edition of that code on 31 August 2026 found the word "historical" 0 times, consistent with the Council's description. Clause 1.3.9 of the same code does require day procedure centres to keep an up-to-date fee schedule available for patients. The same press release also records that of 20 day procedure centres sampled, 15 did not provide fee schedules online for the specified treatments, and 1 had no website at all (the denominator is the 20 sampled, not the 128 covered by the study).

Who most needs to know: anyone going to a day procedure centre for an endoscopy or minor surgery — the transparency rules you face are narrower than those covering private hospitals.


The doctor's side: what the Code says (this section decides how you open the conversation)

The Medical Council's Code gives you a right to ask. It does not give you a right to be told without asking.

Chapter 12, "Fees," of the Code of Professional Conduct for the Guidance of Registered Medical Practitioners (Chinese version, 2022) has four clauses. Read one by one:

  • 12.1:"A doctor must disclose the amount of the consultation fee upon the patient's request. During diagnosis and treatment, the doctor must, on request and on the basis of what is known to them, disclose before providing the service all fees that may be required. A doctor who refuses or fails to disclose fees when the patient makes a reasonable request may be regarded as guilty of professional misconduct."
  • 12.2:"Although a doctor is under no obligation to provide a schedule of fees in advance, where the fees involved are high the doctor should inform the patient of them before providing the service, so as to avoid complaints and dissatisfaction."
  • 12.3:"A doctor must not overcharge or accept excessive remuneration." The Code sets out three principles by which the Council judges whether a fee is excessive: "(a) the difficulty, cost and special circumstances of the service, and the time, skill and experience required; (b) the fee generally charged in Hong Kong for comparable services; and (c) the doctor's own experience and ability in providing the service."
  • 12.4:"A doctor must display a notice in their practice informing patients that they have the right, before receiving treatment, to enquire about the fees involved."

In one line: 12.1 says that if you ask, you must be told; 12.4 says the clinic must post a notice reminding you that you may ask; 12.2 says there is generally no obligation to volunteer a price list — but the same clause carries an exception: "where the fees involved are high, the doctor should inform the patient of them before providing the service." So it is not right to say flatly that you will only ever be told if you ask; but for most situations, all of this points to the same action — you have to open your mouth. ⚠️ Keep two things separate, though: the Medical Council's Code governs the doctor's fee; on the hospital's side, clause 33.2.1 of the Code of Practice for Private Hospitals states that patients "have the right to know the fees required before receiving consultation, treatment and any medical procedure". ⚠️ But this is a right to be informed, not an automatic quotation mechanism: the proactive duty in 33.1.1 is worded "the hospital must, where practicable, inform patients of service charges", and 33.2.2 is worded "on admitting a patient, staff must respond to enquiries from the patient or family about the expected charges for using the hospital's services or facilities". In other words, if you want a case-specific estimate, you still have to ask — and a standardised written estimate format is, to this day, not a statutory requirement.

Who most needs to know: anyone who feels that asking about price is awkward, as though it signals distrust of the doctor. Code 12.4 itself requires the clinic to post a notice telling you to ask. Asking is something the system expects you to do.


What did the Consumer Council's 2025 study find?

In one sentence: more than half of respondents had not looked at published price information, those who did could not understand it, and almost nobody who met a discrepancy complained. ⚠️ Before the figures, the denominator: this is not a general population survey. The telephone survey ran from 9 October 2023 to 18 March 2024 and interviewed 500 local residents; the inclusion criteria were that the respondent had already obtained a fee estimate and had undergone one of the 30 specified treatments/procedures on or after 1 October 2016. In other words: by design, every respondent had at some point obtained an estimate. The "57.0% had not looked at prices" figure refers to not having consulted available or published price information — not to never having been given any price at all.

The Council's study, Confidence and Value: Enhancing Price Transparency in Healthcare, was conducted between October 2022 and December 2024 and covered 13 private hospitals and 128 day procedure centres; the desktop research component examined 13 private hospitals and 20 day procedure centres. All figures below come from the Council's press release of 6 March 2025 and the Chinese-language executive summary of its report.

Key figures from the Consumer Council study "Confidence and Value: Enhancing Price Transparency in Healthcare." Study period: October 2022 to December 2024. Source: Consumer Council press release and the Chinese executive summary of the study report, 6 March 2025, retrieved 2026-08-30. All percentages are proportions of survey respondents; denominators in the right-hand column.
FindingFigureDenominator / qualifier
Had consulted price information43.0%Consumers surveyed
Received only a verbal estimate39.0%Consumers surveyed
─ of those, at day procedure centres59.0%Those who went to a
day procedure centre
─ of those, at private hospitals31.7%Those who went to a
private hospital
Had encountered a price discrepancy67.2%Consumers surveyed
─ of those, given no explanation64.9%Those who met a discrepancy
Final bill exceeded the estimate
by 20% or more
10.6%Consumers surveyed
Had consulted historical bill statistics10.1%Respondents treated at
a private hospital
Aware that historical fee statistics
are published at all
7%Consumers surveyed
Complaints (2021–2024)191Involving more than
HK$7.2 million
─ price/fee disputes45.5%Of those 191
Conciliation success rate
(as at February 2025)
35.6%Cases overall

Two details stand out.

(1) The people who do not compare prices mostly have insurance. The executive summary states that 67.6% of consumers surveyed had not enquired at, or compared prices across, different facilities; and of that group, 87.0% were covered by medical insurance. ⚠️ Note how the denominator narrows at each step — the 87.0% is a proportion within the group that did not compare, not of all respondents.

Two: almost nobody complains — 1 person out of 218. From the executive summary: "of the 218 consumers surveyed who were given no explanation for a price discrepancy, only 1 made a complaint." The reasons the Council recorded: unfamiliarity with the complaint channels, a belief that complaining takes too long, and a wish to stay on good terms with the doctor.

On packages: all 13 private hospitals offered at least 20 of the 30 treatments/procedures, but "7 private hospitals offered package pricing for no more than 6 of the treatments/procedures" — ⚠️ "no more than 6" is a ceiling, not "each of them offered six." Further, "1 private hospital offered medical packages for 26 treatments/procedures, and another for only 2"; colonoscopy, gastroscopy and Caesarean section were relatively common (offered by 10 private hospitals). The Council also found that packages often did not set out the charges for excluded items, with drugs, consultation fees and doctors' fees all common exclusions.

Who most needs to know: anyone with insurance who feels that "the insurer picks up the tab anyway." ⚠️ The study runs the other way: among respondents who did not compare prices, 87.0% held medical insurance, and the Council took this to suggest that insurance may reduce price sensitivity. This figure cannot be read in reverse as "insured people compare prices least" — that would need a different denominator. Using multivariate analysis, the study separately found that private hospital users compared prices less than day procedure centre users.


"HK$33,881 to HK$85,387, a difference of 152.0%" — what does that sentence actually say?

Those two numbers are not prices. They are 50th percentiles — and they are from the 2022–2024 study period.

The Council's press release, in its own words: "for inpatient haemorrhoidectomy, the 50th percentile charge ranged across private hospitals from HK$33,881 to HK$85,387, a difference of 152.0%." The very next sentence reads: "although charges may vary with the patient's condition, service quality and the choice of doctor, facility or treatment method, the finding nonetheless reflects the importance of patients comparing prices."

What is a 50th percentile? In the Department of Health platform's own definition: "the 50th percentile is the amount at or below which 50% of patients paid. It can serve as a reference for estimating the median charge."

So: HK$33,881 does not mean "the cheapest hospital charges you HK$33,881." It means "at that hospital, half of patients paid at or below HK$33,881." Higher-charging cases can and do sit above it. ⚠️ You cannot treat this figure as a quotation.

One more thing to be clear about: these figures come from a study period of October 2022 to December 2024. The platform figures printed below are for a reporting period covering the whole of 2025. The two sets cannot be strung together as a time series — the methods, periods and coverage all differ.


What does the Government platform print today (and how do you read it)?

The Department of Health runs a common electronic platform that prints, hospital by hospital and procedure by procedure, the 50th and 90th percentiles of actual bills.

The reporting period the platform prints for itself: 1 January 2025 to 31 December 2025. The procedure menu has 30 items and the facility menu 14 (one of which is marked as having no fee statistics available).

Taking inpatient haemorrhoidectomy as the example, queried on 30 August 2026, 13 facilities had data:

Inpatient haemorrhoidectomy, total charge (HK$). Source: Department of Health, Office for Regulation of Private Healthcare Facilities, common electronic platform for the Pilot Programme on Enhancing Price Transparency of Private Hospitals (apps.orphf.gov.hk); reporting period printed by the platform, 1 January to 31 December 2025; 13 facilities with data; queried 2026-08-30. The platform prints no percentage difference, and this article has calculated none.
 Lowest facilityHighest facility
50th percentile, total charge$38,497$79,987
90th percentile, total charge$48,679$107,522

The platform sets out four rules for reading it. All four matter:

  1. Standard rooms and single procedures only. "participating private hospitals provide historical actual-bill statistics for patients accommodated in standard rooms who underwent a single treatment or procedure. The statistics do not include data for patients who underwent multiple treatments or procedures."
  2. The 90th percentile is an estimate of the higher end. "the 90th percentile is the amount at or below which 90% of patients paid; the remaining 10% paid more."
  3. Small case counts need care. "readers should interpret with caution bill data where a hospital reported no more than 30 cases of a procedure, since such data are based on few cases and may not reflect typical charges." ⚠️ Note it is "no more than 30" — a ceiling, not "fewer than 30."
  4. ⚠️ The doctor's fee and hospital charge on a given row are not each their own percentile. "the percentile figures above are ranked by the amount of the "total charge," not by the "doctor's fee" or "hospital charge" within it." That is: the doctor's fee on that row is the doctor's fee of the single case whose total charge sat at the 50th position — not the median doctor's fee.

These four rules, and a cell-by-cell reading of the platform's table, are handled in a separate article on this site (see "How do you read a private hospital surgical bill?" at the end). The platform also states what each fee covers: "the doctor's fee includes the anaesthetist's, the surgeon's and ward-round fees." "the hospital charge includes the admission fee, accommodation, operating theatre and related materials, nursing procedures, laboratory, examination and diagnostic procedures, drugs, meals and drinks, and sundries."

This is precisely what the Council found: fee schedules generally do not list doctors' fees. From the press release: "price lists and fee schedules did not set out doctors' fees, including those of other specialists and anaesthetists, nor disclose the basis on which those fees are set."

One more thing to watch: the room class pulls the doctor's fee up with it. From the Council's executive summary: "for the same treatment/procedure, the higher the class of room, the higher the doctor's fee and the hospital charge — for example daily ward-round fees, general nursing procedures and operating theatre charges."

Who most needs to know: anyone planning to look up a number online and treat it as their estimate. What you are looking at covers standard rooms and single procedures only — and the doctor's fee is a separate matter again.


If I have VHIS cover, do I still need to ask about price?

Yes. The VHIS Standard Plan sets benefit limits on surgeon's fees by surgical category — note that these cap what is paid out, not what the doctor may charge.

The Benefit Schedule of the Standard Plan in the Voluntary Health Insurance Scheme Certified Plan Policy Template (Chinese version) prints, on the surgeon's fee row: "per surgery, by the surgical category in the Schedule of Surgical Procedures — Complex $50,000; Major $25,000; Intermediate $12,500; Minor $5,000". ⚠️ These four figures are benefit limits. What a doctor actually charges is not capped by them; how much you finally pay out of pocket depends on the actual eligible expenses, the other benefit items, your policy terms and the outcome of the claim — it cannot be stated flatly as "the excess is simply yours to pay."

And it cascades: the benefit limits for the anaesthetist's fee and the operating theatre charge are each "35% of the surgeon's fee" (a method of calculating the limit — not a statement that the actual anaesthetist's fee or theatre charge equals 35% of the surgeon's fee), and the template's note specifies that this percentage applies to whichever is lower of the amount actually paid for the surgeon's fee and the benefit limit for the surgeon's fee under that surgical category.

⚠️ Two qualifiers that have to be stated:

  • This Benefit Schedule is the Standard Plan's. The template's own note reads that the schedule applies to all certified Standard Plans and "represents the minimum requirements for all certified Flexi Plans". A Flexi Plan may cover more, so these figures are a floor, not what your own policy necessarily pays.
  • Which category a given operation falls into is determined by the categorisation of the relevant procedure in the Schedule of Surgical Procedures, and "the Government reviews the content and categorisation of the Schedule from time to time".

Working the numbers (every figure taken from the Benefit Schedule above): take an operation categorised in the Schedule as "Intermediate" — the Standard Plan's surgeon's fee limit is $12,500. If the surgeon's fee is paid in full at $12,500, then the limit for the anaesthetist's fee and for the operating theatre charge is $12,500 × 35% = $4,375 each. On that basis, the combined benefit limit for these three items is $12,500 + $4,375 + $4,375 = $21,250 (⚠️ for these three items only — not the Standard Plan's overall benefit ceiling). What the surgery actually costs, and how any excess is treated, depends on your quotation and your own policy — which is why asking about price and getting a written estimate does not conflict with having insurance. It is the precondition for using it.


VHIS certified products: does the insurer have to tell you how much it will pay?

Yes — but only within the scope of VHIS certified products, and only after you give the insurer a fee estimate first.

The Government's written reply in the Legislative Council on 8 May 2019 states: "so that consumers can budget with certainty, an insurance company that receives a fee estimate for a non-emergency operation must provide the consumer with an estimate of the claimable amount for that operation, for the consumer's reference."

⚠️ Two qualifiers to hold onto. First, scope: the sentence sits under the heading "As regards the Voluntary Health Insurance Scheme," and corresponds to the VHIS Code of Practice requirements on participating companies and certified products, and to the arrangement under the standard policy terms whereby the policyholder makes a request, attaching the hospital's or attending doctor's fee estimate, and the insurer then provides an estimate of the claimable amount. ⚠️ This article does not extend that obligation to all medical insurance products. Second, trigger: the wording is "if it receives a fee estimate for a non-emergency operation" — it is not a duty on the insurer to quote a figure unprompted, and the estimate is for reference only; the final claim is handled on the actual documentation and the policy terms. So the order runs: get the written estimate → give it to the insurer → get the claimable-amount estimate → then decide.


What is the law changing to, and when? (everything in this section is a proposal, not a current rule)

In May 2025 the Government put three legislative proposals to the Legislative Council, targeting submission of the draft regulations in 2026.

The Legislative Council Secretariat's Research Office Information Note (ISE03/2026, 2 March 2026) records the proposals and sets out the provisions in its footnotes: "the Private Healthcare Facilities Ordinance empowers the Secretary for Health to make regulations on price transparency under sections 61 and 62 … while section 63 requires hospitals to publish actual fee statistics for specified treatments and procedures in the manner specified by the Director of Health."

The three proposals (as recorded in the Information Note; all are proposals):

The three legislative proposals put forward in May 2025. ⚠ All are proposals; as at 31 August 2026 none is a statutory requirement (see also the Code of Practice obligations already in force, above). Sources: opening remarks by the Secretary for Health at the Legislative Council Panel on Health Services (government press release, 9 May 2025); Legislative Council Secretariat Information Note ISE03/2026 (2 March 2026). Retrieved 2026-08-30.
ProposalFacilities covered
Publish fee schedules
in a specified format
Private hospitals, day procedure
centres and clinics
Provide a written service fee estimate
in a specified format before treatment
Private hospitals
Report and publish actual fee
statistics annually
Private hospitals

One of these — the written explanation where the bill overshoots by 20% — is a proposal, not a right you have today. The Secretary's own words on 9 May 2025: "where the final charge clearly exceeds the estimate — by 20% or more, for example — the hospital must provide a written explanation, so as to protect the interests of all parties." The Information Note likewise records this as proposed, and adds an exemption: "where a patient must be admitted within 12 hours of booking, the estimate form may be dispensed with."

How wide would the scope be? From the Information Note's footnote: the "specified treatments and procedures" would include at least the 30 already in the pilot programme, plus the "close to 470 items in the VHIS Schedule of Surgical Procedures" set out in the VHIS policy template.

As for "when": the Information Note says "the draft regulations are expected to be submitted to the Legislative Council in 2026", and the Secretary said in May 2025 that the target was to submit the draft regulations in 2026 and implement the measures progressively. As at 31 August 2026, none of the official documents this article opened states that sections 61, 62 or 63, or the related regulations, have come into operation. ⚠️ But remember: that concerns the Ordinance's provisions and the standardised written estimate — not the Chapter 33 Code obligations described above, which are already in force.

Who most needs to know: anyone who read the news about "the Government legislating to require written estimates" and assumed it was already in force. The standardised written estimate is not in force — but the Chapter 33 obligations in the 2026 Edition of the Code of Practice for Private Hospitals are (fee schedules readily available, 14 calendar days' notice before a price rise, charges updated at intervals during a stay, the right to examine a bill and be given an explanation, and publication of historical fee statistics for specified procedures). So the present position has three layers side by side: Code obligations in force + a voluntary pilot programme + Ordinance provisions not in force.


Closure risk: one 2025 closure, 1,299 complaints

The prepayment risk in private healthcare has a 2025 example that speaks in numbers.

On 23 February 2026 the Consumer Council published its complaint figures for the whole of 2025: after excluding mainland-consumer complaints against the three major mainland online shopping platforms, it received 35,969 complaints relating to Hong Kong consumers and/or local traders. Within that table, medical services accounted for 1,845 complaints (530 in 2024, up 248%), involving a total of $16,254,358, ranking 5th. The Council stated the cause plainly: "complaints about medical services also entered 5th place because of the 1,299 complaints arising from the closure of the Human Health Medical Group."

⚠️ The denominator has to be stated: the 1,845 is the full-year figure for the "medical services" complaint category, and it ranks within the 35,969 (already net of mainland-consumer complaints against the three major mainland platforms) — not within the 38,187 overall total for the year.

The same publication also records that although the group closed all its outlets, complaints involving business closures actually fell 69% in 2025 (to 2,012), because the 2024 closure of Physical Fitness had inflated the base.

⚠️ This article does not claim that all, or any given proportion, of those 1,299 complaints involved prepaid packages. The Council's publication states only that this batch of complaints arose from the closure and falls in the "medical services" category; it does not classify them by content. The relevance to everything above is this: what a prepayment buys is a promise of future service, and the risk in that promise is not only about price. The Council's study separately found that packages often did not set out the charges for excluded items. Put the two together and you have the second reason to ask.


If you dispute the bill, what routes are there?

Not just "talk to the doctor" — the Code already requires facilities to have a complaints mechanism in place, and there is a statutory complaints committee as well.

Step 1: ask the facility for an itemised bill and a written explanation. Clause 33.1.7 of the Code of Practice for Private Hospitals states that patients have "the right to examine the bill and to have the items explained by staff, including hospital charges and doctors' fees".

Step two: use the facility's own complaints procedure. Chapter 7 of the same Code sets out the licensee's duties:

"7.1.1 The licensee must establish a complaint-handling procedure to receive, manage and respond to complaints against the hospital. 7.1.3 Notices must be displayed at the admission registration office, the reception areas of individual services, payment offices and the reception lobby so that patients know the complaint channels; the notice must also include the contact details of the Complaints Committee. 7.1.4 A time limit for staff to make an initial response to a complaint must be set — ten working days, for example. 7.1.5 A member of staff must be designated as Patient Relations Officer to handle complaints."

On the day procedure centre side, clause 1.3.10 of the Code of Practice for Day Procedure Centres (2026 Edition) likewise requires a complaints mechanism, the provision of information on the complaints procedure to patients and carers, and the display at the admission/reception office and payment office of a notice including the Complaints Committee's contact details.

Step three: the Complaints Committee. The Office for Regulation of Private Healthcare Facilities maintains formal contact and submission channels for the Private Healthcare Facilities Complaints Committee (orphf.gov.hk).

⚠️ But pick the right route: complaints about a doctor's professional conduct go to the Medical Council; consumer disputes can go to the Consumer Council; insurance claims follow the policy and insurance complaint channels. These routes have different targets and different outcomes; do not treat them as one.

Who most needs to know: anyone whose bill came in far above the estimate and who does not know whom to approach. Start with the itemised bill and a written explanation, then use the complaint channel the facility has posted.


Ask about these

Before you ask about price, be clear which item you are asking about — then get each one in writing.

  1. Does this price include the doctor's fee, the anaesthetist's fee, other specialists, pathology and imaging? Fee schedules generally do not list doctors' fees (Consumer Council, 6 March 2025). The platform also states that the doctor's fee covers the anaesthetist, the surgeon and ward rounds — check which of these your quotation actually contains.
  2. Is it written or verbal? Does it state a validity period? The Council recommends that written estimates state a validity period, because facility websites generally state that prices may change without notice.
  3. If I choose a higher room class, does the doctor's fee move too? From the Council's executive summary: the higher the room class, the higher both the doctor's fee and the hospital charge.
  4. What does the package exclude? How are complications handled? Drugs, consultation fees and doctors' fees are common exclusions.
  5. Have you obtained the insurer's estimate of the claimable amount? Once you have the fee estimate, give it to the insurer, who must then come back with an estimate of the claimable amount (Government reply, 8 May 2019).
  6. Will there be a written explanation if the bill exceeds the estimate? The standardised written estimate and the "written explanation if it overshoots by 20%" are still proposals; but Code 33.1.6 requires the hospital to keep you informed of current charges at appropriate intervals during a stay, and 33.1.7 gives you the right to examine the bill and be given an explanation — so if a charge is unclear, you can ask on that basis.
  7. Where is the fee schedule? Code 33.1.1 requires it to be readily available at the admission/registration office, the cashier and nursing stations — you can ask to see it on the spot.

The Council separately recommends asking your doctor about five things before accepting treatment (the Council states that these five are drawn from Choosing Wisely Australia): "Is this treatment necessary? What are its risks or side effects? Are there simpler or safer alternatives? What happens if I do not have it? What will it cost me in money, emotion and time?"


Frequently asked questions

  • Does a private hospital have to give me a written fee estimate? A uniform, itemised statutory written estimate is still a proposal; sections 61, 62 and 63 of the Private Healthcare Facilities Ordinance (Cap. 633) and the related regulations are not in force. But clause 33.2.1 of the Code of Practice for Private Hospitals (2026 Edition) provides that patients "have the right to know the fees and charges prior to consultation and any procedure," and 33.2.2 provides that on admission staff must respond to enquiries from the patient or family about expected charges. The two are not the same thing.
  • Can a doctor decline to quote a price? Code 12.2 states that a doctor is under no obligation to provide a schedule of fees in advance, but the same clause continues: "where the fees involved are high, the doctor should inform the patient of them before providing the service". Code 12.1 states that a doctor must disclose the fee "upon the patient's request," and that refusing or failing to disclose when the patient makes a reasonable request "may be regarded as professional misconduct." So in the general case you have to ask — while for high fees the doctor should volunteer them.
  • If the final bill exceeds the estimate by 20%, do they have to explain it in writing? The "written explanation if it exceeds by 20%" remains one of the Government's May 2025 legislative proposals; the draft regulations are expected to reach the Legislative Council in 2026. However, Code 33.1.7 already provides that patients have the right to examine the bill and be given an explanation, including hospital charges and doctors' fees. The Council's 2025 study found that among respondents who met a price discrepancy, 64.9% were given no explanation.
  • Is the "50th percentile: $X" on the Government platform a quotation? No. The platform's own definition is "the amount at or below which 50% of patients paid," useful only as a reference for estimating the median charge — and it covers only standard rooms and single treatments or procedures.
  • Why don't the doctor's fee and hospital charge on a row add up to a "median doctor's fee"? Because the platform states that "the percentile figures are ranked by the amount of the total charge, not by the doctor's fee or hospital charge within it" — the doctor's fee on that row belongs to the single case whose total charge sat at that percentile.
  • Do day procedure centres offer the same protections? Some, but narrower. Clause 1.3.9 of the Code of Practice for Day Procedure Centres (2026 Edition) requires an up-to-date fee schedule to be available for patients; but that code has no counterpart provision on historical fee statistics, consistent with the Council's description. Of the 20 centres the Council sampled, 15 did not provide fee schedules online for the specified treatments and 1 had no website.
  • If I have VHIS cover, can I ignore the quotation? The Standard Plan sets benefit limits on surgeon's fees by surgical category (Complex $50,000 / Major $25,000 / Intermediate $12,500 / Minor $5,000), with the limits for the anaesthetist's fee and the operating theatre charge each set at 35% of the surgeon's fee (calculated on whichever is lower of the amount actually paid and the category limit). ⚠️ These are payment ceilings, not ceilings on what a doctor may charge; what you actually pay out of pocket depends on the eligible expenses, the policy terms and the claim outcome. That Benefit Schedule is the Standard Plan's, and is also the minimum requirement for all certified Flexi Plans.
  • Where can I look up historical bill statistics? On each private hospital's own website, or on the Department of Health's common electronic platform (apps.orphf.gov.hk). The reporting period the platform currently prints is 1 January to 31 December 2025, covering 30 treatments/procedures.

Also in this series:

  • A cell-by-cell reading of the Government platform's table: "How do you read a private hospital surgical bill? A full breakdown of the platform's 50th/90th percentiles, its four rules of use, and the two mechanisms that make the numbers incomparable, 2026"
  • How a private doctor's bill is assembled: "How are private doctors' fees put together? A full breakdown of the five parts of a bill, fourteen mutually incomparable fee schedules, and the eight questions to ask, 2026"
  • What VHIS actually covers: "How much does VHIS actually cover? A full breakdown of a scheme that was never legislated, its zero-payout first-year waiting period, and its 12 standard benefits, 2026"
  • Public hospital fees in full, and waivers: "Do you have to apply for the $10,000 annual cap yourself? A full breakdown of 2026 public hospital fees, the $400 A&E charge and fee waivers"

What this article does not claim

  • This article does not claim that the 1,299 complaints arising from the Human Health closure involved prepaid packages. The Council's publication only lists that batch as "medical services" complaints arising from the closure, without classifying them by content.

  • This article does not treat the Council's 500-person telephone survey as a general population survey. Its inclusion criteria were that the respondent had already obtained a fee estimate and had undergone one of the 30 specified treatments/procedures.

  • This article does not infer from "87.0% of those who did not compare prices had insurance" that "insured people compare prices least." The denominators differ.

  • This article does not treat the VHIS benefit limits as ceilings on what a doctor may charge.

  • This article does not extend the estimate obligation for VHIS certified products to all medical insurance products.

  • This article does not name the charges of any private hospital or day procedure centre. The Government platform does list them facility by facility, but this article reads out only the lowest and highest printed figures among the 13 facilities with data — no ranking, no comparison, no evaluation of any facility.

  • This article calculates no percentage differences. The 152.0% is the Council's own printed figure, quoted together with its own definition (the 50th percentile) and its study period (October 2022 to December 2024). For the platform's 2025 reporting-period figures, the platform prints no difference and this article has calculated none.

  • This article does not treat the Council's figures and the platform's figures as one time series. Their methods, periods and coverage all differ; they cannot be read as "rose from X to Y."

  • This article does not equate the obligations in the Code of Practice for Private Hospitals with statutory rights. The Code binds licensees and is enforced through the licensing regime; sections 61, 62 and 63 of the Private Healthcare Facilities Ordinance and the related regulations are not in force. They are different in kind and this article has kept them apart.

  • This article does not quote the text of the Private Healthcare Facilities Ordinance (Cap. 633). On 30 August 2026 the Hong Kong e-Legislation page for the Ordinance showed only a loading screen; five URLs were tried and none returned the provisions themselves. The content of sections 61, 62 and 63 is reported here only as described by the Legislative Council Secretariat's Information Note (ISE03/2026) and the 2019 Legislative Council question, and is marked as such.

  • This article does not draw on the body of CHOICE issue 584. The paginated content of that article did not display when opened on 30 August 2026, and no figure here comes from it.

  • This article does not cite facility-level data from the full text of the Council's study report. The Council states that the full report is available in English only; to avoid back-translating Chinese quotations out of English, this article uses the Council's own Chinese executive summary instead.

  • This article has not checked whether the contractual package arrangements mentioned in 2019 for two hospitals remain in effect. The Government's reply of 8 May 2019 mentioned that Gleneagles Hospital and the then forthcoming CUHK Medical Centre were required by their service deeds to provide a certain proportion of package charges; none of the 2026 documents this article opened restates or updates that point.

  • This article does not report a stakeholder allegation that "having insurance means being charged more" as fact. The Council's executive summary records this observation from an insurance industry representative; it is a stakeholder view rather than a study finding, and is not cited here as one.

  • This article does not give medical advice and does not judge whether any treatment should be undergone. The Council's five questions are its own consumer-education recommendation (drawn from Choosing Wisely Australia) and are quoted as published.


Status: compiled from official announcements, statutory body research and Government platform data; every figure carries its source, its denominator and the date the document itself prints.

Quotations from Chinese-language official documents and press materials appear in our own English translation; the original wording governs.

資料來源 (Sources)

Compiled by the editorial team from official announcements, statutory body research and Government platform data; every figure carries its source. This is service information, not medical advice, and not insurance or legal advice.