Health care expenditure (SHA 2011) (hlth_sha11)

National Reference Metadata in ESS Standard for Quality Reports Structure (ESQRS)

Compiling agency: Inspection générale de la sécurité sociale


Eurostat metadata
Reference metadata
1. Contact
2. Statistical presentation
3. Statistical processing
4. Quality management
5. Relevance
6. Accuracy and reliability
7. Timeliness and punctuality
8. Coherence and comparability
9. Accessibility and clarity
10. Cost and Burden
11. Confidentiality
12. Comment
Related Metadata
Annexes (including footnotes)
 



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1. Contact Top
1.1. Contact organisation

Inspection générale de la sécurité sociale

1.2. Contact organisation unit

Service études et analyses

1.5. Contact mail address

26, rue Zithe . L-2763 Luxembourg


2. Statistical presentation Top
2.1. Data description

Health care expenditure quantifies the economic resources dedicated to health functions, excluding capital investment. Healthcare expenditure concerns itself primarily with healthcare goods and services that are consumed by resident units, irrespective of where that consumption takes place (it may be in the rest of the world) or who is paying for it. As such, exports of healthcare goods and services (to non-resident units) are excluded, whereas imports of healthcare goods and services for final use are included.
Health care expenditure data provide information on expenditure in the functionally defined area of health distinct by provider category (e.g. hospitals, general practitioners), function category (e.g. services of curative care, rehabilitative care, clinical laboratory, patient transport, prescribed medicines) and financing scheme (e.g. social security, private insurance company, household). For the collection of the data on health care expenditure the System of Health Accounts (SHA) and its related set of International Classification for the Health Accounts (ICHA) is used. SHA sets out an integrated system of comprehensive and internationally comparable accounts and provides a uniform framework of basic accounting rules and a set of standard tables for reporting health expenditure data. The System of Health Accounts - SHA 2011 is a statistical reference manual giving a comprehensive description of the financial flows in health care.

It provides a set of revised classifications of health care functions, providers of health care goods and services and financing schemes. The SHA is currently used as a basis for a joint data collection by OECD, Eurostat and WHO on health care expenditure. The manual sets out in more detail the boundaries, the definitions and the concepts of health accounting – responding to health care systems around the globe with very different organisational and financing arrangements.

Accounting period: Health expenditure and financing data pertain to the calendar year (1 January to 31 December).
The time coverage of this Quality report is 2013 to 2017 reference years.

2.2. Classification system

Healthcare expenditure is recorded in relation to the international classification for health accounts (ICHA) defining:

  • healthcare expenditure by financing schemes (ICHA-HF) — which classifies the types of financing arrangements through which people obtain health services; health care financing schemes include direct payments by households for services and goods and third-party financing arrangements;
  • healthcare expenditure by function (ICHA-HC) — which details the split in healthcare expenditure following the purpose of healthcare activities — such as, curative care, rehabilitative care, long-term care, or preventive care;
  • healthcare expenditure by provider (ICHA-HP) — which classifies units contributing to the provision of healthcare goods and services — such as hospitals, residential facilities, ambulatory health care services, ancillary services or retailers of medical goods.
2.3. Coverage - sector

1. Household individual consumption on health, including the collective consumption with two exceptions:
i. Occupational health care (intermediate consumption within establishments) minus an estimated share of occupational health in health providers’ and other medical industries net administration;
ii.“Remunerated” unpaid household production in the form of transfer payments (social benefits in cash) for home care of sick, disabled and elderly persons provided by family members.
SHA 2011 Manual recommends following the standard System of National Account (SNA) rules for drawing the production boundary of health care services, albeit with two notable exceptions:
- Occupational health care is included in the national totals of health care spending. In SNA, this item is recorded as ancillary services and part of intermediate production of enterprises and
- Part of the cash transfers to private households for care givers of home care for the sick and disabled are treated as the paid household production of health care.
2. Health care financing schemes: HF1 Government schemes and compulsory contributory health care financing schemes; HF2 -voluntary health care payment schemes;
HF3 - Household out-of-pocket payment; HF4 - rest of the world financing schemes.
3. NACE rev. 2, section Q, human health and social work activities.

2.4. Statistical concepts and definitions

SHA concept is the consumption of health care goods and services.
Health care statistics describe the process of providing and financing health care in countries by referring to health care goods and services, its providers and financing. For the collection of the data on health care expenditure the System of Health Accounts (SHA) and its related set of International Classification for the Health Accounts (ICHA) is used. SHA is a tri-axial system in which the financing, provision and consumption dimensions are covered by the ICHA (International Classification for Health Accounts): Health Care Functions (HC), Health Care Providers (HP), Health Care Financing Schemes (HF).
Data are presented in 3 summary (one-dimensional) tables and 3 cross-classification tables (2-dimensional tables).

Summary tables provide data on:

  • Current expenditure by provider (ICHA-HP)
  • Current expenditure by function (ICHA-HC)
  • Current expenditure by financing scheme (ICHA-HF)

Cross-classification tables refer to:

  • HC x HP: Health care expenditure by function and provider: data on which type of health care goods and services are supplied by which health care provider;
  • HC x HF: Health care expenditure by function and by financing scheme: data on how are the different types of services and goods financed;
  • HP x HF: Health care expenditure by provider and by financing scheme: data on from which health care provider and under which particular financing scheme are the services and goods purchased.
2.5. Statistical unit

Commission Regulation 2015/359 concerns the collection of data on "current expenditure on healthcare" which is defined as the "final consumption expenditure of resident units on health care goods and services".
There is a very close relationship between the concept of "final consumption expenditure" as defined in the System of Health Accounts (SHA) and in National Account and, as a consequence, also between the underlying economic transactions as recorded in the two accounting frameworks.
In National Accounts there are two types of statistical units: institutional units and local kind-of-activity units (KAU). A local KAU groups all the parts of an institutional unit in its capacity as producer which are located in a single site. A local KAU belongs to one and only one institutional unit.
SHA uses the same two types of units for data compilation.
Local KAUs operating as providers of healthcare goods and services to resident units are statistical units in SHA.
Also transactions by institutional units are recorded in SHA, in which framework institutional units are also referred to as "financing agents". More precisely, SHA financing agents are institutional units that manage one or more financing schemes. The transactions are executed by the financing agents, according to the rules of the financing schemes.
Financing agents serve as key statistical units in producing national health accounts. While financing schemes are the key units for analysing how the consumption of health care goods and services is financed, the data concerning the relevant transactions are collected either from the financing agents that operate the different financing schemes or from the providers.
The concept of "healthcare financing schemes" in SHA is an application and extension of the concept of "social protection schemes" defined by the European System of Social PROtection Statistics (ESSPROS):  "a distinct body of rules, supported by one or more institutional units, governing the provision of social protection benefits and their financing ...". The social protection scheme is the statistical unit in ESSPROS. It is an analytical unit that allows describing the complete structure of the social protection financing system:  expenditure and receipts.
According to SHA Manual 2011, "the key concepts for describing the structure of the health care financing system are based on measuring: (a) the expenditure of health care financing schemes, under which goods and services are purchased directly from health care providers, on the one hand, and (b) the types of revenues of health care financing schemes, on the other hand.  
Commission Regulation 2015/359 limits its scope to the collection of data on the expenditure of health care financing schemes.

2.6. Statistical population

SHA focuses on the consumption of health care goods and services by the resident population irrespective of where this takes place. This implies the inclusion of imports (from non-resident providers) and the exclusion of exports (health care goods and services provided to non-residents).

2.7. Reference area

The data aims at providing a complete overview of expenditure on health care goods and services consumption of services and goods by the resident population on the national territory of a country.

2.8. Coverage - Time

2013-2017.

2.9. Base period

Not applicable.


3. Statistical processing Top
3.1. Source data
1. (mandatory) Social security funds  Healthcare fund (Caisse nationale de Santé - CNS) ;                                                                                   LTC (Assurance dépendance - AD)                                                                                                Accident insurance (Assurance accident - AA)            
1.1 Financial statements + additional data on benefits delivered by accounting departments of the social security funds  Benefits in kind per category (ex: medical consultation, Dentist, ...). Available as per date of payment/reimbursement (accounting date) and per date of benefit, including provisions. (For AA, only date of payment is available).  financial statements + supplementary tables HF.1.2.1, HC: All; HP: All 2013-2017 6-8 months Annual Elimination of benefits out of scope of SHA (cash benefits, rents,..).  Consumption by non-residents is eliminated using prorata per category deducted from social security data files(+/- 2% of benefits in LU).   
1.1 Financial statements + additional data on benefits delivered by accounting departments of the social security funds  Percentage rate, per category, of patient out of pocket participation (Statutory participation+ supplementary participation "personal convenience").  Rates observed/estimated by social security funds and included in financial statements Financial reports HF.3.2, HC: All; HP: All 2013-2017 6-8 months Annual Calculation of "gross" out of pocket participation using given percentage rates. Validity check using social security data files (1.2)
1.2 Social security data files Database of social security contains information on healthcare benefits at individual level. Only "paid" benefits included (no provisions).  public administrative records HF.1.2.1, HC: All; HP: All 2013-2017 at least 12 months.  To be considered as "provisional data " for at least 24 months continuous Pro-rata calculation in case detail the financial statements information (1.1) is insufficient for the requested 2.or 3-digit HC and HP classification.  
1.3 Financial statements of social security funds  Financial statements of social security funds used for non-benefit details (ex: administrative costs) and FS classification Balance sheet, Income statement HF1.2.1; HP7, HC7, FS:1;3&6 2013-2017 6-8 months Annual Elimination of "non Sha related" administrative costs (sickness benefit (cash benefits), rents (AAA),…) (prorata if necessary).                                                                                 Proratisation of revenu categories for FS-*classification
2. Central government  / NPISH sector              
2.1  General account of State / State budget  "Financial statement" of general administration expenditure, detailed by budget item Law HF.1.1 2013-2017 +/- 7 months (draft law); +/- 12 months (law) Annual Data mainly used for HC7 categories (Governance and Administration of healthcare system); preventive care programms, Occupational healthcare for public servants and HC benefits in kind (partially/fully) taken in charge by State (social assistance, prisons, ...)
      HF.2.2       Data also used to estimate preventive care programms by NPISH providers that are mainly financed by state subsidies
              Data also used to doublecheck transfers to social security and other schemes.
2.2 Financial statements + Administrative data on National solidarity funds (FNS) Detailed data on benefit "accueil gérontologique". For people with insufficient ressources, FNS (partially) takes in charge "room and board" in nursing homes (residential LTC facilities) and CIPAs (assisted living facilities). financial statements + public administrative records HF1.1 / HC3 and HCR.1 2013-2017 6-8 months Annual Data also used to estimate room and board expenditure in LTC facilities.
2.3 Financial statements / Activity reports of several non-profit organisiations   financial statements HF.2.2 2013-2017      
3. Statistical office / National accounts              
3. Statistical office - turnover of pharmacies  (estimation) For national account compilation (final consumption of households), the national statistical office (Statec), uses (among others) data from tax administration to estimate turnover/sales  of pharmacies (detailed by VAT rate) Other HC.5.1.2 OTC medecines 2013-2016 at least 12 months irregular The part of pharmacy-turnover subject to the reduced VAT rate of 3% (applicable to pharmaceuticals) is used as a proxy (see II.5).  The total amount of prescribed pharmaceuticals (part paid/reimbursesd by social security (or other mandatory) schemes + statutory participation of patients) is deducted from this turnover in order to estimate the OTC medicine expenditure.
4. Voluntary healthcare schemes (supplementary schemes)               
4.1 Financial statements and data on benefits from CMCM (Caisse Médico Chirurgicale Mutualiste) Financial statements and detailed data (individual level) of services and goods reimbursed by CMCM financial statements + supplementary tables HF.2.1, HC: All; HP: All 2013-2017 6-12 months Annual Reimbursements from CMCM and private supplementary insurance schemes are deducted from the "gross" out of pocket participation (see 1.1) in order to estimate "net" cost sharing with third party payers
4.2 Other supplementary schemes - Insurance companies -  Activity report of CAA Commissariat aux assurance (CAA = Administration supervising the insurance sector) CAA gives the overal amount of Healthcare benefits in kind reimbursed by insurance companies on supplementary healthcare insurance contracts by residents.   HF.2.1, HC: All; HP: All 2013-2017 6-8 months Annual
4.3 Other supplementary schemes - Insurance companies  -  Questionnaire IGSS questionnaire to major insurance companies asking for more details on above-mentioned reimbursements   HF.2.1, HC: All; HP: All 2014-2017/2018   Irregular Data used to classify the "CAA amount (4.2.)". Detailed  (2- and 3.digit) classification based on  prorata of social security funds (1.2).
5. Healthcare schemes for international bodies              
5. Healthcare schemes for international bodies - Data on benefits received from RCAM (scheme for EU-officials) Aggregated data of Healthcare services reimbursed by RCAM in Luxembourg (by categorie of service) Aggregated data HF4 ; HC: All; HP: All 2013-2017   Annual  Detailed  (2- and 3.digit) classification based on  prorata of social security funds (4.2).
3.2. Frequency of data collection

Annual.

3.3. Data collection

Data are collected through the joint health accounts questionnaire (JHAQ) that countries submit to Eurostat during the annual data collection exercise. There is a voluntary deadline to send the JHAQ questionnaire for the calendar year T by the 31st of March T+2. The joint health accounts questionnaire (JHAQ) is coordinated in agreement with the World Health Organisation (WHO) and the Organization of Economic Co-operation and Development (OECD). These three international organisations are known collectively as the International Health Accounts Team (IHAT). Countries submit data to Eurostat on the basis of Commission Regulation (EU) 2015/359 of 4 March 2015 implementing Regulation (EC) No 1338/2008 of the European Parliament and of the Council as regards statistics on healthcare expenditure and financing.

Social security data serve as a base to calculate most keys. Double counting are eliminated from calculations. Non-health consumption are eliminated as much as possible.

3.4. Data validation

The 2018 JHAQ includes a number of features which allow national data correspondents to perform various quality checks before submitting the data. The embedded programmes allow the verification of:


1- Consistency of the data between tables,
This step checks if the marginal totals reported in each table of the JHAQ are consistent across all tables. For example, for each function (HC), the total across all financing schemes (HF) in the HCxHF table has to be equal to the total across all providers (HP) in the HCxHP table, i.e. the values in the column “All HF” in the HCxHF table have to be equal to the values in the column “All HP” in the HCxHP table. Any detected differences are flagged up in the corresponding row or column in the relevant tables and all inconsistencies are listed in the “Report” worksheet by variable code together with the amount by which the respective variable differs between the two compared tables. A positive value indicates that the first listed table has a higher value for the same variable, and vice versa.

 

2- Consistency of the data within tables,
Any detected inconsistencies are listed by variable code together with an indication of which total is not equal to the sum of its subcomponents as well as the numerical difference. A positive figure indicates that the total is greater than the reported sub-components, and vice versa.

  • The presence of negative values,

Entries in the tables cannot be negative as they refer to the consumption of goods and services.
If an individual data table is checked for internal consistency, the negative values check is performed for the relevant table and then any negative values are highlighted red and crossed out.

  • The presence of atypical entries,

The atypical entries check provides information whether the data tables contain values in cells which are – if at all – only reported by very few countries and are thus atypical for health accounting.
If an individual data table is checked for internal consistency, the atypical entries check is performed for the relevant table. In the data tables, any cell containing an atypical entry will be highlighted for national data providers.
Should any atypical entries be identified, compilers should scrutinize in detail the transactions that led to entries in those cells and assess whether the accounting rules of SHA have been correctly applied. If they come to the conclusion that the transactions are recorded in the correct categories of the ICHA classifications, then the corresponding atypical entries represent unique – and correctly accounted for – features of the country’s health system. In this case a short description of the nature of the transactions should be included in the accompanying Metadata file under “II.3. Atypical entries”.
If, on the other hand, compilers come to the conclusion that the transactions are not recorded correctly, then they need to make adjustments in the concerned tables. In case the transactions recorded in a cell do not belong to the boundaries of SHA (e.g. they refer to intermediate consumption) the value of the respective cell should be deleted (and all cells that are affected by this change adjusted accordingly). In case the transactions are misreported and another category of the ICHA classification is more appropriate, the value of the cell should be transferred to the correct cell of the table.

 

3- The growth rates against the previous year and the magnitude of revisions as compared to previously submitted data. Results are grouped into three different categories:

  • Breaks in series (the current questionnaire shows no data for an item that is not null in the other file)
  • Newly reported (the current questionnaire contains data for an item that is empty in the other file)
  • Differences (all other types of differences)
3.5. Data compilation

SHA data is compiled both by a bottom-up approach as well as by a top-down approach, depending on the data source. Compilation is done by financing schemes and by different health care functions/task areas. The results of the several calculations are then aggregated.

To gain the differentiation between the different SHA-dimensions (especially HC and HP) quotas and pro-rating and utilisation keys are applied on some spending items. For some spending items it is necessary to extra-/intrapolate data as there is no up-to-date data available or data is missing for certain years. For some other spending items, estimation methods have to be applied.

 

Several methods are normally used for estimations:

  • Balancing item/Residual method: For example, if data are available from the financing side, which permit accurate estimation of the flows to a provider or function, then an acceptable estimation method is to subtract these expenditure flows from the total revenues, and derive the expenditure flows from the unmeasured financing scheme as a residual.
  • Pro-rating/Utilisation key: Typically in the absence of direct spending data, a utilisation key linked to the proportion of resources used can be constructed in order to distribute e.g. aggregate provider spending across functions. For every key a fraction of total utilisation within the cost-unit is assigned: fractions in the key must add up to 100% of all care delivered by the cost-unit. Examples of utilisation keys are admissions, bed-days, contacts, staffing, etc.
  • Interpolation/Extrapolation: In the absence of data for the period in question, missing values can be estimated using known data points.
  • Or other.
HF.4 Pro-rating/Utilisation key Pro-rating of RCAM data using health care data of the national health insurance as key
HF.2.1 Pro-rating/Utilisation key Pro-rating of CMCM and Insurance company data using health care data of the national health insurance as key
HC.5.1.2 Pro-rating/Utilisation key Amount for missing year(s) estimated using the last available ratio Prescribed medicals/OTC drugs
HP.7.1xHC.6.5xHF.1.1 Other Expenditure on occupational healthcare, Estimation based on the  social contributions*
    *) For occupational healthcare (private sector), most employers rely on  a "social security type" funds (STM - Service de Santé au travail multisectoriel), funded by employer contribution. Nevertheless employers are allowed to organise/finance occupational healthcare by themselves or in mutual organisations whithin their sector. For the estimation of occupational health expenditure, we assume that all employers pay tot the STM
3.6. Adjustment

Not applicable.


4. Quality management Top
4.1. Quality assurance

Authorities responsible for SHA data collection are working to ensure that the statistical practices used to compile national health accounts are in compliance with SHA methodological requirements and that good practices in the field are being followed, according to the methodology underlined in the SHA 2011 Manual and European Statistics Code of Practice respecting professional independence of the statistical authorities. Procedures are in place to plan and monitor the quality of the health care expenditure statistical production process.

4.2. Quality management - assessment

Goverment accounts are classified based on budgetary article label. This may lead to overestimation or underestimation of some items. Subsidies or programs on local level are excluded.

Out-of-pocket payments for glasses are only partly included and thus do not perfectly reflect private consumption patterns.

It is not always evident to include/exclude consumption of residents abroad and consumption of non-residents in Luxembourg, as Luxembourg is faced with a lot of cross-border activity.  


5. Relevance Top
5.1. Relevance - User Needs

Not applicable.

5.2. Relevance - User Satisfaction

Not applicable.

5.3. Completeness

HF4 Data are incomplete, but this is only marginal.

5.3.1. Data completeness - rate

Not available.


6. Accuracy and reliability Top
6.1. Accuracy - overall

Most data are based on financial statements and administrative data and should thus be accurate. OOP data, OTC drug data are estimates, HF4 is partially missing.

6.2. Sampling error

Not applicable.

6.2.1. Sampling error - indicators

Not applicable.

6.3. Non-sampling error

See coverage error.

6.3.1. Coverage error

Double counting has been excluded this year, we are not aware of any double-counting at the moment. OTC medicines (HC.5.1.2) are estimated based on the proportion of turnover/sales of pharmacies subject to the reduced VAT rate (3%). This might include "non pharmaceuticals" sold by pharmacies also subject to the reduced VAT rate (such as food,..). No data available on (OTC) pharmaceutical sales to non-residents. No data available on pharmaceuticals bought by residents abroad and/or in shops other than pharmacies (supermarkets,..). An under-coverage exists in OOP-payments for HP.9 and HC.5.2, as well as HF4.

Mental hospitals are included in specialised hospitals.

6.3.1.1. Over-coverage - rate

OTC medicines (HC.5.1.2) are estimated based on the proportion of turnover/sales of pharmacies subject to the reduced VAT rate (3%). This might include "non pharmaceuticals" sold by pharmacies also subject to the reduced VAT rate (such as food,..). No data available on (OTC) pharmaceutical sales to non residents. No data available on phramaceuticals bought by residents abroad and/or in shops other than pharmacies (supermarkets,..).

6.3.1.2. Common units - proportion

Not applicable.

6.3.2. Measurement error

Not available, mainly administrative data/financial statement data.

6.3.3. Non response error

Not applicable.

6.3.3.1. Unit non-response - rate

Not available, mainly administrative data/financial statement data.

6.3.3.2. Item non-response - rate

Not available, mainly administrative data/financial statement data.

6.3.4. Processing error

Typing errors can always occur, clerical work means risk of random and systematic measurement error.

6.3.4.1. Imputation - rate

Not available.

6.3.5. Model assumption error

No model is used.

6.4. Seasonal adjustment

Not applicable.

6.5. Data revision - policy

No data revision policy is in place, as data are considered stable.  

6.6. Data revision - practice

Data will be revised if variations in the social security data occur. This may be due to wrong estimations or more data becomes available.

6.6.1. Data revision - average size

Not available.


7. Timeliness and punctuality Top
7.1. Timeliness

Member States are required to transmit their data to Eurostat in compliance with the Commission Regulation 359/2015 transmission deadlines.
Data and reference metadata for the reference year T should be transmitted to Eurostat by 30 April T+2.

7.1.1. Time lag - first result

As no t-1 data is published, no first results are published.

7.1.2. Time lag - final result

Unless revisions are produced, final results are published for t-2 in March of year t.

7.2. Punctuality

Deadlines respected since EU regulation is in place.

7.2.1. Punctuality - delivery and publication

Deadlines respected since EU regulation is in place.


8. Coherence and comparability Top
8.1. Comparability - geographical

Not applicable at national level.

8.1.1. Asymmetry for mirror flow statistics - coefficient

Not applicable.

8.2. Comparability - over time

Breaks in time series resulting from methodological changes

2013 (JHAQ 2019) All items For the JHAQ2019  the years 2013-2017 have been revised due to an major internal revision of methodology (see V.)     
2011 All items Switch from SHA 1.0 to SHA 2011.
2000 All items Start of SHA-based reporting
8.2.1. Length of comparable time series

Data is comparable for the period 2013-2017 (no break in time series).

8.3. Coherence - cross domain

ESSPROS is compiled using a different method than SHA and cannot be mapped.

8.4. Coherence - sub annual and annual statistics

Not applicable.

8.5. Coherence - National Accounts

National accounts are compiled using a different method than SHA and cannot be mapped.

8.6. Coherence - internal

Atypical entries:

Years(s)

Atypical entry

Explanations

2011-2016

HP.7.2

All grey marked cells: The social health insurance appears as provider in the data base. 

2011-2016

HP.5.2xHC.3.1

Long term care: people living in an institution an having technical aids

2011-2016

HP.7.2xHF.1.1

Long term care insurance: mostly costs of medical expertise provided by physicians who are civil servants.

2011-2016

HP.7.2xHC.3.4

Long term care: national health insurance is the provider - cash benefits or products required for care


9. Accessibility and clarity Top
9.1. Dissemination format - News release

SHA data are not disseminated on national level.

9.2. Dissemination format - Publications

SHA data are not disseminated on national level.

9.3. Dissemination format - online database

SHA data are not disseminated on national level.

9.3.1. Data tables - consultations

SHA data are not disseminated on national level.

9.4. Dissemination format - microdata access

Not applicable.

9.5. Dissemination format - other

SHA data are not disseminated on national level.

9.6. Documentation on methodology

SHA data are not disseminated on national level.

9.7. Quality management - documentation

SHA data are not disseminated on national level.

9.7.1. Metadata completeness - rate

SHA data are not disseminated on national level.

9.7.2. Metadata - consultations

SHA data are not disseminated on national level.


10. Cost and Burden Top

Cannot be estimated.


11. Confidentiality Top
11.1. Confidentiality - policy

The Regulation (EC) No 223/2009 on European statistics (recitals 23-27, 31-32 and Articles 20-26) applies.

11.2. Confidentiality - data treatment

The health expenditure data only uses aggregated data or data without direct personal reference. Otherwise, the European GDPR applies.


12. Comment Top

No further comment.


Related metadata Top


Annexes Top