Many foreign healthcare investors are surprised that private hospitals and clinics in Vietnam, including FDI facilities, set their own service prices instead of following a state price table like public facilities. Self-pricing is not absolute freedom, however: prices must be publicly posted, declared to the regulator and never charged above the posted level.
The principle: private pricing managed through transparency
Law on Medical Examination and Treatment 15/2023/QH15 draws a clear line between the two sectors: public facilities apply prices issued or approved by the state under a full-cost roadmap, while private facilities decide their own service prices. Healthcare services also sit in the group of goods and services subject to price declaration under Law on Prices 16/2023/QH15, so an FDI facility must file its price declaration with the receiving authority and update it when the price list changes.
This management style means there is no prior approval procedure for a private facility’s price list or price increases. Instead the state controls through posting duties: the price list must be public at the facility and on its information channels so patients can check before using a service, and actual charges may not exceed the posted price for the same service.
The hard limits inside pricing freedom
The first limit is services paid by health insurance where the facility contracts with the social insurance system: the fund’s payment follows its own price framework and payment rules, which the facility cannot set itself. The second limit is that on-demand services and bundled packages must still show transparent price components for patients to choose, avoiding a quoted price followed by unannounced extra charges.
The third limit is conduct: charging above the posted price, failing to post prices or declaring incorrectly are penalised violations in the health and price regimes. There is also a real if softer market limit: an FDI facility pricing above the premium private segment without matching clinical or experience differences will lose patients to competitors, because Vietnamese patients compare private providers’ prices quite actively.
Price increases and patient complaints
To raise prices a facility needs no permission, but it must complete two steps before applying the new level: update the price declaration under Law on Prices 16/2023/QH15 and refresh the public posting at every patient touchpoint. Applying new prices while the posting still shows the old ones is a violation even if the new level is itself reasonable, because the breach lies in transparency, not in the number.
When a patient complains about high prices, authorities typically check in sequence: whether the amount charged matches the posted price, whether the price declaration was filed, and whether the charged service sits in the published list. If the facility charged contrary to its posting it must refund the difference and faces penalties; if posting and declaration were fully compliant, a high price by itself is not a violation, because no price ceiling applies to the private sector.
Frequently Asked Questions
Are FDI healthcare service prices regulated by the state?
They are managed, but not by imposed prices. Private healthcare facilities, including FDI ones, decide their own service prices under Law 15/2023/QH15; the state manages through price declaration under Law on Prices 16/2023/QH15, mandatory public posting and inspection of charging exactly the posted price. No state price table applies to the private sector and there is no prior approval of price lists.
Can facilities set their own prices?
Yes. A private facility may set its own treatment prices, including at a premium positioning. The attached conditions are that prices must be declared and publicly posted so patients know them in advance, and actual charges may not exceed the posted price. The part paid by the health insurance fund, where the facility has a health insurance contract, follows the insurance payment framework instead.
Must price increases be notified?
No permission is needed, but the price declaration must be updated and all public postings refreshed before the new price applies. Raising prices without updating the posting is treated as a price transparency violation and penalised even if the new level is reasonable. In practice facilities should also notify regular patients and health insurance partners in advance to avoid expectation disputes.
How are patient complaints about high prices handled?
Patients should complain to the facility first, then to the health authority if unresolved. On inspection, officials compare the charged amount with the posted price and the declaration status: a facility that charged above its posting must refund the difference and faces penalties; a facility that posted and declared correctly has not violated the law merely by pricing high, because the private sector has no price ceiling.
Bottom line for healthcare investors
FDI facilities price freely but operate inside a strict transparency frame: declare, post and charge exactly what is posted. Good price governance in Vietnam means governing the price file and the patient’s transparency experience, not seeking state permission for each adjustment.