Statistics Portugal

National Accounts Department / Unit for Satellite Accounts and Quality Assessment of the National Accounts

Av. António José de Almeida, 5
1000-043 LISBOA - Portugal

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. Governmental schemes, compulsory contributory health financing schemes, voluntary health insurance schemes, Household out-of-pocket payment). On a voluntary basis, in order to meet internal information needs, Portugal also compiles information by financing  agents (e.g. General government, Insurance corporations, Corporations, Non-profit institutions serving households). 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 2000 to 2016 reference years.

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;
• healthcare expenditure by financing agents (ICHA-FA) — which classifies the institutional units involved in the management of one or more financing scheme (national purposes).

In relation to the European System of Accounts (ESA), healthcare expenditure compilation process is also used: general industrial classification of economic activities, NACE Rev. 2; classification of institutional sectors.

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,
- 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; part of section O, Public administration and defence; part of section G, retail trade.

4. Health care financing agents (voluntary): FA1 - General government; FA2 - Insurance corporations; FA3 - Corporations (other than insurance corporations); FA4 - Non-profit institutions serving households (NPISH); FA5 - Households; FA6 - Rest of the world.

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.

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.

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).

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. 

Portuguese territory includes:

• Mainland Portugal;
• The Autonomous Region of Azores;
• The Autonomous Region of Madeira.

2000-2016.

Not applicable.

Several data sources are used:

-          Surveys/census: 9

-          Public administrative records: 5

-          Financial reports: 7

-          Other: 2

Surveys/censuses

Public administrative records

 Financial reports

 Other

Annual.

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. Under regulation, data and reference metadata for the reference year N should be transmitted by 30 April N+2.

National data collection:

- Annual financial statements online available are extracted from the official websites of the entities. When they are not available, emails are sent to the entities requesting the submission. 

- The collection of information related to National Health Service, including the Public-private partnerships (PPPs), is carried out by the Ministry of Health. Under a protocol with Statistics Portugal, the Ministry of Health provides data according to the requested details and classifications of SHA (transfers, financing of NHS providers, costs of production of NHS providers, subcontracts/conventions, reimbursements and payments under international conventions) and also compiles the functional structures of NHS providers. Aggregate financial data (financing and cost of producion of NHS entities) to compile preliminary year N-1 are also available.  

- Data from National Pharmacy and Medicines Institute (INFARMED) are, usually, available on the official website. These data are also under a protocol with Statistics Portugal. INFARMED collects economic data related to the pharmeceutical sector in Portugal. 

- Simplified Business Information (SBI) - The SBI results from the integration in a single act of the provision of tax information, the accounting and statistical data from corporations. The SBI is sent electronically to the Ministry of Finance. After the validation process, data are centralized and storaged in relational data bases (Oracle) that are share with Statistics Portugal, Central Bank (Banco de Portugal), Ministry of Justice and Ministry of Economy (since 2015). 

- Statistics data collected and compiled by Statistics Portugal integrated in SHA: 

1) National Accounts data (derivated statistics)

2) Survey on International Tourism (ITI) - Survey carried out by Statistics Portugal in cooperation and financial assistance from Turismo de Portugal, I.P. The survey took place at air, road and sea borders and collected detailed information on tourist demand (including expenditure).

3) Hospitals Survey - The physical data of the hospitals (Mainland) are collected by Statistics Portugal. In the case of hospitals belonging to the National Health Service, the Ministry of Health collaborates. Regional Statistics Service of the Azores and Regional Directorate of Statistics of Madeira also collect data from their hospitals. 

4) Consumer prices index - Prices are collected on a monthly basis in retail outlets and service providers, using paper collection forms and price collection software. Housing rents prices are collected directly from households using the same method or by phone interview. Some prices (such as administered prices and fuels) are centrally collected, by phone or internet. The outlets are chosen to represent the existing trade and services network.

5) Mutual aid associations survey - Survey carried out by Statistics Portugal.

- Budgets and Accounts of Private Institutions of Social Solidarity (OCIP) - Since 2010, Private Institutions of Social Solidarity and similar institutions have obligatorily submitted their financial information, electronically, to Social Security. Since 2011, Statistics Portugal has accessed to the database that centralizes the individual financial data of these instituions namely: Balance Sheet, Cash flows, Statement of Results, Statement of Results by Social Response.

- Ministry of Finance - The total amount of income tax deductions related to health care services and retirement homes is, anually, provided by the Ministry of Finance.

- Information on the use of credit cards by residents and non-residents - Information on non-resident cards used in Portugal for credits and resident cards used abroad for debits are collected by the corporation (SIBS) which controls the entire electronic payment system.

- Balance of Payments (BoP) - Banco de Portugal is the entity responsible for the collection. The Balance of Payments systematically records, for a given period of time (usually a month, a quarter or a year), all economic transactions between Portugal and the Rest of the World according to the methodological principles contained in the Manual of the IMF's balance of payments. The current statistical system of external transactions is characterized essentially by the gathering of information from the following sources: bank reporting, direct reporting, General Directorate of the Treasury, Statistics Portugal and Banco de Portugal.

- Single report - The information on the company's social activity (Single Report) is collected, annually, by the Office of Strategic Studies of the Ministry of Economy. The report must be submitted by all employers (financial and non-financial corporations, Households, general administration and non-profit institutions).

- Statistical information on health insurance from Portuguese Association of Insurers (APS) - Survey is carried out, annually, by the Portuguese Association of Insurers (APS) collecting a set of variables from health insurances companies.

- Statistical information on health insurance from the Autoridade de Supervisão de Seguros e Fundos de Pensões (ASF) (the supervisory body for the insurance and pension funds sector) is extracted from the official website. The ASF collect annually financial information and physical data from all insurances companies.

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)

 National data validation: manual validation is performed throughout the compilation process to ensure the consistency and completeness of the final results. For instance:

• Cross checking between different data sources from financing side and production side;
• Evaluation of completeness and coverage of each data source;
• Control and analysis of financial microdata recorded by each statistical unit;
• Identification and elimination of eventual double counting problems;
• Cross checking between Health data and National Accounts data.

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 expenditure, 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

Not applicable.

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.

Statistics Portugal began a systematic quality approach in 1996, when it was decided, by its Board, to implement a Quality Management System. Currently there is a Unit responsible for quality management (the Planning, Control and Quality Unit), which reports directly to the Board. Another Unit (the Methodological Unit) also deals with aspects related to product/survey quality.The three main objectives of Statistics Portugal Quality Management System then defined and still present today are: to continuously improve the quality of: i) the products; ii) the services rendered to customers; and iii) the work and inter-department relations at all levels of the organization.

Quality audits, documentation of processes and surveys of users’ satisfaction were significant activities of this system, as the experience shows. It also deals with aspects related to the implementation of the European Statistics Code of Practice and maintains a close relation to the ESS at this level of interest. This system comprises a wide range of instruments, methods and activities covering process documentation, performance assessment and user relations, such as:• Internal and external audits;• Performance indicators and management tools, particularly in the context of the Public Administration, as well as a specific set of quality monitoring criteria;• User and respondent satisfaction questionnaires, considering the different services provided; • Suggestions and complaints management system; • Documentation system (E.g. methodological documentation, internal procedures, quality reports and the Statistical Production Process Handbook).

The last round of peer review took place in 2015 to assess the implementation of the European Statistics Code of Practice in Portugal in the context of the second round of Peer Reviews to Member States. According to the Peer Review Report, the main conclusions of the last peer review are mirrored in the resulting recommendations, which cover: the different roles and responsibilities of the actors of the National Statistical System (NSS), including the access to administrative data; budget procedures and constraints and the availability of human resources; quality documentation, particularly in regard to quality reports and process description, and quality audits; and dissemination issues, mainly related to data and microdata accessibility, statistical literacy and the visibility of the NSS.

The reviewers’ recommendations resulted into an Improvement Actions Plan, properly scheduled and involving both Statistics Portugal and Other National Authorities (ONA). It comprises the current situation in the context of each of the reviewers’ recommendations, the associated improvement actions and the timeline for their implementation. This implementation is regularly monitored by Statistics Portugal and reported to EUROSTAT, and is expected to be fully completed by 2019.

The SHA data are exhaustive, relevent, coherent, accurate, reliable, comparable and consistent with national accounts. Improvements in the estimations of households out-of-pocket and long term care (health) are expected in the coming years. 

The main users of the SHA data are: the Ministry of Health, reseachers, journalists, academia and an information platform (PORDATA).

In general, the following information needs were recorded:

1. conceptual and methodological clarifications - coverage and borderlines of the SHA data, criteria of classification, concepts and definitions, etc.;

2. SHA data available: calendar, SHA data breakdown, etc.

At the national level, Statistics Portugal performs a online user satisfaction survey to evaluate their level of satisfaction with the statistical information produced as well as the information available on its website at the level of content and usability.

SHA data not available: HF.4; HP.0; HC.3.2; HC.3.3.

For HF.4 and HP.0 an estimate is missing due to a lack of data sources. For HC.3.2 and HC.3.3 an estimate is missing and reported in HC.1.2/HC.2.2 and HC.1.3/HC.2.3, respectively.

Table HPxHF = 79,5%

Table HCxHP = 86,7%

Table HCxHF = 75,8%

In general, the accuracy is good. However, any update of the main financing agents data implies a revision in household expenditures estimates, since they are estimated as a residual value.

Not applicable.

Not applicable.

Not applicable.

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Not applicable.

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Not applicable.

In a general way, the Portuguese Health Accounts are reviewed and updated when the national accounts implement a new benchmark year. In each year, the Portuguese Health Accounts follow the Portuguese National Accounts release calendar, i.e., the results are final in T-3, provisional in T-2 and preliminary in T-1.

Under the 2018 SHA JQ, Portugal submitted revised data for the years 2015-2016, replacing the previous version (submitted in 2017). Data for 2015 and 2016 were revised due to the incorporation of the updated and final data sources. Additionally, preliminary data for 2017 was presented. The data available submitted are final for the year 2015, provisional for the year 2016 and preliminary for the year 2017.

Not available.

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.

At the national level: 18 months (provisional data for T+2).

At the national level: 30 months (final data for T+3).

Statistics Portugal complies the Commission Regulation 359/2015 transmission deadlines.

Deadlines respected.

Not applicable at national level.

Not applicable.

There are no breaks in 2000-2016 series. 

All data series 2000-2016 are comparable.

SHA data are consistent with the principles, concepts, definitions and classifications adopted in the Portuguese National Accounts, ensuring the harmonization of methodologies and comparability of data. Coherence between SHA and ESSPROS has not been considered.

Not applicable.

In statistics Portugal, the SHA data are compiled closely and linked with National Accounts. Despite the metodological differences between SHA and National Accounts (in terms of borderlines: occupational health care and Household provision of health (and social) care), the definitions, data sources, the criteria of classification and accounting methods are the same in both systems. 

Main differences with national accounts:

- There is no direct correspondence between SHA data and the final consumption expenditure of residents on human health activities estimated by national accounts. SHA data covers the administration of financing and regulation of health systems, as well as includes part of social support activities with housing.

- SNA recommends evaluating the output of retailers by trade and distribution margins. In SHA data, the expenditure of retail providers (HP.5) considered the value of sales in goods and products valued at acquisition prices.

- SHA recommends following the standard SNA rules for drawing the production boundary of health care services, albeit with two 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; 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.

At the national level, annual news release has regular published. Information is published on the Statistics Portugal's website at the following link: https://www.ine.pt/xportal/xmain?xpid=INE&xpgid=ine_destaques&DESTAQUESdest_boui=314638731&DESTAQUESmodo=2

At the national level, no paper or electronic publications are produced.

The online national database is available on the Statistics Portugal's website at the following link: 

https://www.ine.pt/xportal/xmain?xpid=INE&xpgid=ine_cnacionais2010&contexto=cs&selTab=tab3&perfil=220674570&INST=220617355&xlang=en

The following cross tables are disseminated, for the period 2000-2016:  

- Current Expenditure by Function of Care and Financing Agent

- Current Expenditure by Provider Industry and Financing Agent

- Current Expenditure by Function of Care and Provider Industry

- Current Expenditure by Financing Agent

- Current Expenditure by Financing Scheme

The number of consultations of SHA data tables on Statistics Portugal's website is not available. The SHA data are located in a specific dossier and this accounting requires additional work, which is not possible due to the ongoing technical reformulation process on the website of Statistical Portugal.

As a proxy information, the number of consultations of the last SHA Press Release, published in 2016 and 2017, was: 

2016: 1.580

2017: 2.252

Not applicable.

On the Statistics Portugal's website, infographies based on SHA data are also published (https://www.ine.pt/xportal/xmain?xpgid=ine_infografias&xpid=INE).

SHA methodological document (portuguese version) is available on the Statistics Portugal's website at the following link: https://www.ine.pt/xportal/xmain?xpid=INE&xpgid=ine_docmetodsec2010_cn&contexto=cs&perfil=220674570

Integrated metadata system can be accessed in: http://smi.ine.pt/?LANG=EN

Quality documentation is not available.

Information not available.

Information not available.

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

The official statistical activity and the application of the principle of statistical confidentiality are carried out in strict compliance with the established i) in the Constitution of the Portuguese Republic, ii) in Law no 22/2008, of 13 of May, which establishes the principles the norms and the structure of the NSS (SEN Law), iii) Law 67/98 of 26 October, Law on the Protection of Personal Data and iv) Regulation (EC) 223/2009 of the European Parliament and of the Council of 11 (European Statistics Regulation) and in accordance with the principles agreed between EU Member States, transposed into the European Statistics Code of Conduct, namely Principle 5 concerning Statistical Confidentiality.

Violation of statistical confidentiality, whether intentional or not (willful or negligent), is severely punished, constituting a very serious offense; breach of the obligation of professional secrecy entails disciplinary and criminal offense (a crime punishable by up to 5 years' imprisonment), pursuant to Articles 25 and of the National Statistical System Law.

Since SHA data are derivative statistics in Portugal, confidentiality is not a common problem. However, in case it takes place, Eurostat is warned of the confidential nature of data, so that public dissemination does not occur.