Comparison of Health Dispute Mediation Mechanisms in Indonesia and ASEAN Countries

The health dispute mediation mechanism in Indonesia has not yet developed optimally and remains general in nature, failing to specifically accommodate the complexities of medical cases. In contrast, several ASEAN countries such as Malaysia and Singaporehave established more structured and effective health mediation systems. This study aims to compare the health dispute mediation mechanisms in Indonesia and selected ASEAN countries in order to identify weaknesses and formulate recommendations for improvement. The method employed is a normative juridical approach through legal comparative analysis and literature review.

The research findings indicate that Indonesia does not yet have a specialized mediation institution, lacks specific sectoral regulations, and has a shortage of mediators with medical expertise. On the other hand, other ASEAN countries have developed institutions and regulations that support professional and efficient dispute resolution. Therefore, Indonesia needs to establish an independent health mediation body, develop sectoral regulations, and enhance the capacity of mediators in order to strengthen its medical dispute resolution system.