Comparative approach in public health social security: a legal case study of the Indonesian, France, and Singapore health systems

Purpose This research paper aimed to study the legal structure of top-performing health governance systems and compare them with the Indonesian health social security system to identify the main differences and provide recommendations for Indonesian and other developing countries’ health policymakers and administrators. Design/methodology/approach Using formative research with a conceptual approach and statute approach as method in this study. Data was gathered using the document study technique, which studies various documents, especially legal documents related to health law, linked to legal purpose theories. Moreover, the World Health Organization ranking was considered to choose the two countries (France and Singapore) with a high social health security system for comparative analysis. All data collected has been analyzed using a qualitative and theoretical basis. Content analysis was performed by analyzing the legal documents, and the regulatory framework of all three countries was deeply analyzed to draw conclusions and recommendations. Findings Indonesia has specific laws to implement a social security system in the health sector. However, the lack of the best medical facilities and infrastructure and weak implementation of existing laws were identified as major reasons behind the poor health security system compared to comparative countries. Also, as a developing nation Indonesian Government face budgetary pressures and huge population challenges to meet required standards. Thus, the financing approaches used by Singapore and France may help developing countries meet these challenges effectively. Therefore, there is a dire need to strengthen the social health security system all over the country with amendments to laws and ensure the implementation of prevailing laws and regulations. Practical implications Providing understanding related to the social security health system in Indonesia along with a detailed description of the sound social health security system in France and Singapore will further provide an avenue for the researchers to critically analyze this line of study to devise some valuable suggestions further and to draw loopholes in the system. Originality/value A comparative approach for legal studies in the health sector is rare. So, this research advanced the social security health system-related literature and legal studies on the health sector by using this comparative approach to develop policy insights and future research directions, which will further help the field to grow.