KUALA LUMPUR, Jan 8 — Potential problems with guarantee letters (GLs) may emerge if delays in issuance of 2026 annual practising certificates (APCs) for medical practitioners persist, the Life Insurance Association of Malaysia (LIAM) has warned.
LIAM chief executive Mark O’Dell said insurers and takaful operators (ITOs) do not currently appear to be facing operational issues amid the APC backlog, following checks with a few companies.
He added that the association will not issue any guidance to its members.
“However, there is a concern that if the situation drags on, it could create issues with GLs due to compliance concerns,” O’Dell told CodeBlue. “Hopefully, this technical issue will be resolved soon.”
The current absence of reported issues from ITOs may either be due to GLs being submitted only from licensed doctors so far in the first week of the year or insurers not making a practitioner’s APC status as part of its routine real-time checks yet.
The Federation of Private Medical Practitioners’ Associations Malaysia (FPMPAM) previously noted that APC issues may surface later during claims audits or payment disputes.
LIAM’s comments come amid widespread concern over delays by the Malaysian Medical Council (MMC) in processing and issuing 2026 APCs that has left tens of thousands of doctors without formally issued certificates, despite having applied on time.
MMC has apologised and said medical practitioners who submitted complete applications by December 31, 2025 may continue practising pending APC issuance, but it did not announce a timeline to clear the backlog.
While health regulators have said there will be no enforcement action against affected doctors and private health care facilities for now, lawyers, a health think tank, doctors’ groups, and a pharmaceutical trade group have warned of ongoing legal and third-party risks, including billing, indemnity cover, drug procurement, and insurer recognition.
GLs are commonly used by ITOs and third-party administrators (TPAs) to authorise hospital admissions, procedures, and treatment costs.
Section 20(7) of the Medical Act 1971 doesn’t only prohibit medical practitioners from practising medicine, surgery, or obstetrics and gynaecology (O&G) without a valid APC, but also expressly prohibits such doctors from recovering any fee or cost incurred during the time without the certificate.
In CodeBlue’s October 2025 health insurance survey among over 850 specialists in private hospitals, several respondents reported a rising trend of insurance companies conducting retrospective audits and “clawing back” payments to doctors for previously approved procedures performed up to two to three years back.
O’Dell said LIAM would not be able to provide further comment beyond his brief statement within the time available, reiterating that insurers hope the APC delay remains a short-term technical issue.
The APC backlog continues to draw scrutiny as Malaysia prepares for 2026 as the Year of Medical Tourism, with stakeholders warning that prolonged licensing delays could affect insurer confidence, hospital operations, and patient safety if left unresolved.
