Assessing Digital Health
Adoption in ASEAN
ASEAN-JAPAN CENTRE 2024

CONTENTS

2

ABOUT THIS REPORT3EXECUTIVE SUMMARY

4

1. The Digital Transformation of the Healthcare Sector

52. Is ASEAN Digital Health–Ready?

6

3. Digital Health Adoption in ASEAN

15

4. Challenges and Gaps in Digital Health Adoption among AMSs

23

5. Advancing Digital Health Adoption in ASEAN

25

TOWARDS DIGITAL-IN-HEALTH

28

REFERENCES

29

APPENDIX

30

ABOUT THIS REPORT
Assessing Digital Health Adoption in ASEAN is co-authored by Katrina
Navallo, PhD, ASEAN-Japan Centre, and Keith Detros, Tech for Good
Institute. The report is published by the ASEAN-Japan Centre Researchand Policy Advocacy Cluster as part of its ASEAN-Japan Insights Series.
The authors wish to thank the members of the ASEAN Coordinating
Committee on Services, the ASEAN Healthcare Services Sectoral
Working Group, and the Technical Working Group on eHealthcare
Services for their invaluable insights and feedback, and Mr. Julius T.
Gonzales for providing the data visualization in the report.
The research utilized the online databases Global Digital Health Monitor(GDHM 2023a) and Network Readiness Index (2023) and included
interviews with six key persons involved in implementing the national
ehealth strategies in the Lao People’s Democratic Republic, Malaysia,
and the Philippines, and from companies providing digital healthcare
services in Singapore and Viet Nam. The interviewees have requested
not to disclose their names in this publication for privacy purposes.
Some parts of this report were published in ASEAN Focus (2023),“Advancing the Digital Health Ecosystem in Southeast Asia”, URL:
https://fulcrum.sg/aseanfocus/advancing-the-digital-healthecosystem-in-southeast-asia/
The opinions expressed in this report and any errors or omissions arethose of the authors and should not be attributed to their organizations.
Copyright © 2024 by the ASEAN Promotion Centre on Trade, Investment
and Tourism.
All rights reserved.
ISBN 978-4-910293-54-7 (print)

3

EXECUTIVE SUMMARY

The adoption of digital health technologies is a
key tool in shaping the future of global health,and the World Health Organization recognizes therole of digital health technologies in improving
medical treatment and service delivery. In ASEAN,
the adoption of digital health has wide disparities
in terms of legislation and policy, infrastructure,services and application, and workforce readiness.
The Global Digital Health Monitor (GDHM 2023a)
indicates that most ASEAN countries scorehigh particularly in the areas of leadership andgovernance,
standards
andinteroperability,
infrastructure, and services and applications.
However, more work is needed in developing
standards
andinteroperability,
legislation,
investment, and workforce development to support
digital health adoption among ASEAN member states.

4

This report finds the following gaps and challenges
to digital health adoption in ASEAN countries:• Lack of trust in data protection andcybersecurity• Fragmented
digitalhealthsystems
To address the remaining gaps in digital healthadoption of the ASEAN member states, this report
recommends the following:• Build trust through data protection andgovernance• Develop standards for data interoperability• Enable digital startups to drive innovation• Promote healthcare professionals’ digital
health training support

1. THE DIGITAL TRANSFORMATION OF THE
HEALTHCARE SECTOR
The COVID-19 pandemic significantly disrupted
access to medical care, leading to an unparalleledsurge in the use of telehealth and various formsof digital health technologies in Southeast Asia.
The digital health ecosystem in ASEAN has grownsignificantly, especially with the accelerated riseof healthtech startups, such as Doctor Anywhere(Singapore), HaloDoc (Indonesia), Alodokter(Indonesia), Doctor A to Z (Thailand), docosan (VietNam), and Doctor 2u (Malaysia), some of which have
expanded to other ASEAN member states (AMSs).
As many ASEAN countries swiftly transitioned totelehealth, governments modified and updated
their existing medical laws and policies to facilitate
teleconsultations and support remote medical care.
The adoption of digital health technologies is a key
tool in shaping the future of global health, and theWorld Health Organization (WHO 2021) recognizes
the important role of digital health in improving
medical treatment and service delivery. Digital healthencompasses a wide range of medical technologies
and services, from digital records, telecare,telehealth, and mobile health apps and wearables tomore sophisticated health analytics such as genomics,
precision medicine, and health data analytics. The
digitalization of different segments of the healthcare
process underscores the potential of digital healthservices to revolutionize the way societies access andefficiently utilize medical care, regardless of timeand location constraints. Concurrently, it gives healthservice providers and digital startups the impetus todemonstrate their innovative solutions in medicine,
health, and biotechnology.
The digital health ecosystem in the ASEAN region
involves multiple players, generally including
regulators (governments, medical associations),
innovators (digital health startups, health service
providers), enablers (governments, investors), andusers (patients, healthcare providers, insurers). Other
studies classified the players as innovation suppliers(startups, non-profits, academia, tech companies),
enablers (investors and governments), and demand
drivers (patients, healthcare consumers andproviders, pharmaceuticals and insurance companies)(ACCESS Health International Southeast Asia 2019).
Regulators are involved with legislation, policy, andcompliance governing digital health investments,
digital infrastructure, and data protection. Innovators
are involved in developing standards and fosteringinteroperability, while enablers usually provide
funding through investments, technical and businessdevelopment acceleration, and legal or administrative
support. Finally, users involve service providers andusers and insurers.
To get to a digitally connected healthcare system
requires transformation of the healthcare system
into interoperable segments connected in a chain ofdigital services. World Bank (2023) describes threeprogressive stages towards the evolution of digital
health demand and supply: digitalization, digitalfor-health, and digital-in-health. The initial stage,“digitalization”, establishes the structural design
and administrative procedures for health information
systems, links health providers and facilities, andgathers standardized medical data. The subsequent
stage, “digital-for-health”, integrates medical
data and digital technology into routine business
operations. Finally, the ultimate stage, “digitalin-health”, envisages the integration of digitaltechnology and health data into a smooth processingrained in developed and transformed healthsystems.
Despite significant advancements in digital healthinnovation in recent years, Southeast Asia still
faces fundamental challenges in adopting digital
health technologies. Countries in the region need toformulate specific digital transformation guidelines
for the healthcare sector. Moreover, governments
need to resolve policy implementation hurdles tofully leverage the digital revolution in healthcare.
A preference for face-to-face healthcare delivery
remains due to a lingering mistrust in digital
services. Understanding these issues necessitates anassessment of ASEAN’s progress in fully integrating
digital health.
This study used the Global Digital Health Monitor(GDHM 2023a) to assess the digital health readinessand maturity of ASEAN countries. It also relied oninterviews with key informants in the digital healthsector in five ASEAN countries (the Lao People’s

5Democratic Republic [PDR], Malaysia, Philippines,
Singapore, and Viet Nam) to further understandgovernment and private sector perspectives on theestablishment of digital infrastructures for healthand pain points from their experience.

These indicators are not exhaustive but provide an
overview of a country’s performance in terms of the
supply of health professionals and public financing
for health, which are essential for the provision ofbasic health services in any country.

To establish how digital health adoption can unlock
the possibilities for integrated and patient-centred
healthcare delivery in the region, the following
section looks at health systems and the digital
network readiness of ASEAN countries.

The bigger the coloured areas for all five indicators,
the stronger the health capacities and the higher
potential for that country to perform well in digital
health. Figure 1 clearly shows huge gaps in the supply
of healthcare professionals relative to the population
sizes of ASEAN countries. The overall ASEAN
score is plotted against individual AMSs’ scores forcomparison.

2. IS ASEAN DIGITAL HEALTH–READY?
The WHO defines health systems as “theorganizations, institutions, resources and people
whose primary purpose is to improve health” (2010,vi). The WHO Health Systems Framework identifies
six indicators that determine the strength of acountry’s health system:
1. Health service delivery
2. Health workforce
3. Health information
4. Access to essential medicines
5. Health financing
6. Leadership/governance
Figure 1 illustrates the strength of the AMSs’ healthworkforce and financing relative to the regional(ASEAN) average. The radar graphs present thecurrent state of the healthcare workforce among
AMSs, ASEAN, and Japan (number of hospital beds
and density of medical doctors, nurses and midwives,
pharmacists, and dentists per 10,000 population).

6

Singapore, Malaysia, and Brunei Darussalam havethe highest ratios of medical doctors. The ratiosof healthcare professionals for Indonesia, thePhilippines, and Thailand are almost the same as
the overall ASEAN score, while Cambodia, Lao PDR,
Myanmar, and Viet Nam have relatively smaller ratiosof healthcare professionals than the regional average.
The shortage of healthcare professional supply inthe region exists even though some AMSs are major
healthcare professional exporters to other countries.
For instance, the Philippines actively exports nurses
overseas, and Indonesia and Vietnam also actively
export healthcare professionals abroad.

FIGURE 1. HEALTH WORKFORCE IN ASEAN AND JAPAN7

FIGURE 1. HEALTH WORKFORCE IN ASEAN AND JAPAN8

9

FIGURE 1. HEALTH WORKFORCE IN ASEAN AND JAPANSource: Collated by the authors from WHO Health Statistics 2023: Annex 2

10

Notwithstanding the increasing cost of healthcare in
ASEAN, these huge gaps in the supply of healthcare
professionals have contributed to an increase ingeneral government health expenditures (GGHE)
among ASEAN member states. Demographic
issues, such as the ageing population, contributeto public health spending as medical and welfare
costs for the elderly population compound withage-related illnesses and demand for care. Figure 2
shows this: Japan’s GGHE of 24.2% is thrice that of
ASEAN overall. Meanwhile, ageing ASEAN countries
including Singapore, Thailand, and Malaysia scoremore than 10%.

FIGURE 2. GOVERNMENT HEALTH EXPENDITURE OF ASEAN MEMBER STATES

Source: General government health expenditure (domestic), WHO Health Statistics 2023: Annex 2

In terms of health financing among the AMSs, thetrend in the GGHE as a proportion of government
expenditure shows that Singapore has the highest
ratio at 14.5% of total government expenditure followedby Thailand at 13.9% and Malaysia at 10.1%. Singapore
and Malaysia both have universal health coverage ofmore than 85% of the population. Indonesia, with apopulation of roughly 300 million, mirrors the regional
average of government expenditure at 8.7%. Other
countries have government health expenditure ratios
below 7%, which corresponds to less than 60% in their
universal healthcare (UHC) coverage indices (Figure3). The ASEAN member states show great disparities
in the three indicators that reflect gaps in healthworkforce and financing.

FIGURE 3. UNIVERSAL HEALTHCARE COVERAGE INDEX OF ASEAN MEMBER STATES

Source: Universal health coverage, WHO Health Statistics 2023: Annex 2

11

ACCESS Health International Southeast Asia (2019)
found that ASEAN as a region stands to benefit fromdigital health by laying the infrastructure to achieve
UHC. The UHC index for the ASEAN region showsthat seven out of the 10 AMSs have attained morethan 60% coverage for their population. However,
the remaining tasks to achieve full coverage will
be further augmented by the establishment of
national medical records systems and digitalizationof medical records as part of the digitalization ofhealthcare services. The recent experience with the
COVID-19 pandemic also shows the promise of digital
health, especially in the use of telehealth medicine
to deliver healthcare services despite physical andgeographical distances. As digital health relies on
the connectivity and digital capacities of AMSs,
the following section discusses the current state ofdigital connectedness in the region.
Digital readiness in ASEAN varies widely bycountry. The Network Readiness Index (NRI), which
evaluates the digital readiness of countries basedon technology, people, governance, and impact,shows the state of ASEAN economies in their digitaltransformation journeys (Figure 4). To gauge thereadiness of countries to take advantage of digitalsocieties, the report uses the 2023 NRI.

FIGURE 4. NETWORK READINESS INDEX PILLARS AND INDICATORSNETWORK READINESS INDEXTECHNOLOGYPEOPLEGOVERNANCE

IMPACTACCESSINDIVIDUALS

TRUSTECONOMYCONTENT

BUSINESSESREGULATIONQUALITY OF LIFE

FUTURETECHNOLOGIESGOVERNMENTS

INCLUSION

SDG
CONTRIBUTION

Source: Network Readiness Index (2023)

The NRI provides a robust framework for assessing
the impact of information communication andtechnology (ICT) on society and the developmentof nations. The NRI recognizes the pervasivenessof digital technologies in today’s networked world,
resting on 58 indicators across four fundamental
dimensions: technology, people, governance, andimpact. It covers 134 economies, including eight of
the ASEAN member countries.
This measure indicates the ASEAN and Japanese
averages on various dimensions of ICT’s impact
on society and development. Before considering
specific countries, a key takeaway is that levels ofdigital readiness vary across ASEAN (Figure 5).
Furthermore, areas of improvement exist that canhelp enable digital health in the region.

12

Singapore, for example, ranks second out of the 134
economies included in the 2023 NRI. The country’s
main strength relates to governance, where trust,
regulation, and inclusion indicators are faring well.
Its people component, which is relatively lower thanthe other three pillars, is around the same as Japan.
Note that Singapore scores higher than Japan acrossall pillars of the NRI.
Malaysia is also trending in the right direction, withall pillars scoring higher than the ASEAN average. Its
core strength is also in governance, although areas
for improvement exist across all pillars.
Thailand rates slightly higher than the ASEAN averagein the pillars of governance, technology, and people,

but areas for improvement exist on the impact
component of ICT. To improve the impact pillar,
areas related to the digital economy, quality of life,and contributions to the United Nations Sustainable
Development Goals should be addressed. Thailand’sstrongest pillar is also governance.
Viet Nam rates slightly higher than the ASEAN
average on people and impact but slightly lower thanthe ASEAN average on technology and governance.
The country is not far behind its neighbors acrossall pillars. Viet Nam is strongest in the impact
component.
Indonesia, however, is above par on technology andgovernance, but people and impact components

need improvement. Indonesia is relatively strong ingovernance, while the people pillar has most roomfor growth.
The Philippines is slightly below the ASEAN averagein all pillars of technology, governance, people,
and impact. Most room for growth is around thetechnology pillar, while impact is the Philippines’
strongest component.
Finally, Cambodia and Lao PDR are just starting intheir digital development journeys. Both countries’
strongest pillars are in impact. Cambodia has themost room for improvement in the people aspect,and Lao PDR has most room for improvement ingovernance.

FIGURE 5. NETWORK READINESS OF EIGHT ASEAN MEMBER STATES (2023)
SINGAPORE

MALAYSIATHAILANDVIET NAM

13

INDONESIAPHILIPPINESCAMBODIALAO PDR

Source: Network Readiness Index 2023. Visualization by the authors.

The information and scores of different countries
reveal some trends with respect to digital readinessin ASEAN. As mentioned earlier, wide disparities
in readiness exist, but certain pillars are moredeveloped in ASEAN countries than others.

14

On average, ASEAN is relatively strong in terms ofimpact, or the cascading effects of technology on theeconomy, society, and the Sustainable Development
Goals. In addition, ASEAN has made strides indeveloping appropriate governance mechanisms. It
is the pillar that some of the more digitally matureeconomies fare stronger in as well (Figure 6).

FIGURE 6. GAPS IN THE DIGITAL READINESS OF ASEAN MEMBER STATESThe range of scores is also revealing. Governance,
while strong, also has one of the largest ranges
between the highest and the lowest scores.
Opportunity exists here for knowledge sharing andfor establishing enough channels for cross-bordercollaborations and policy alignments. The ASEAN
Digital Economy Framework Agreement is one
initiative that should help in this cause.
Most room for growth lies in the people andtechnology components. The AMSs have pressing
challenges in digital skilling, for example, which thisreport discusses later.

3. DIGITAL HEALTH ADOPTION IN ASEAN
Combining the current strength of health systems
and the digital network readiness of the AMSs, thissection assesses the overall digital health readinessof the region. This report does not offer a newframework or methodology for assessing digital
health readiness but adopts the Global Digital
Health Monitor as a measure.
The Global Digital Health Monitor measures digitalmaturity according to seven ehealth components
based on the WHO National eHealth Strategy
Toolkit (2012; Table 1):• Leadership and governance• Strategy and investment• Legislation, policy, and compliance• Workforce• Standards and interoperability• Infrastructure• Services and applications

15

TABLE 1. DIGITAL HEALTH INDICATORS AND MEASUREMENTDIGITAL HEALTH INDICATOR

DEFINITION AND MEASUREMENT
Measures the coordination of digital health at thenational level to ensure alignment with national healthgoals and priorities
Indicator 1: Digital health is prioritized at the national
level through dedicated bodies/mechanisms forgovernanceIndicator 2: Digital health prioritized at the national
level through planning

LEADERSHIP AND GOVERNANCE

Indicator 2a: Health is prioritized in national digitaltransformation and data governance policies
Indicator 3: Readiness for emerging technologies
adoption and governanceIndicator 4: Diversity, equity, and human rights
analysis, planning, and monitoring included in national
digital health strategies and plans
Indicator 4a: Gender considerations accounted for indigital health strategies and digital health governance
Ensures a responsive strategy and plan forsystematically financing and implementing national
digital health plans
Indicator 5: National ehealth/digital health strategy
or framework

STRATEGY AND INVESTMENT
Indicator 5a: National digital strategy alignment with
UHC core components
Indicator 6: Public funding for digital healthIndicator 6a: Private sector
investments in digital health16

participationandCreation of legal and regulatory environments
to establish trust and protection for users andconsumers of digital health interventions throughprivacy, security, and safety
Indicator 7: Legal framework for data protection(security/cybersecurity)

LEGISLATION, POLICY,
AND COMPLIANCE

Indicator 8: Laws or regulations for privacy, consent,
confidentiality, and access to health information(privacy)
Indicator 9: Protocol for regulating or certifying
devices and/or health services, including provisions
for artificial intelligence and algorithms (at higher
stages of maturity)
Indicator 9a: Protocol for regulating and certifying
artificial intelligence within health services
Indicator 10: Cross-border data security and sharing
Need for human resources with the skills to develop,
support, and use digital health services andapplications
Indicator 11: Digital health integrated in health andrelated professional pre-service training (prior to
deployment)

WORKFORCE

Indicator 12: Digital health integrated in healthand related professional in-service training (after
deployment)
Indicator 13: Training of digital health workforce
Indicator 14: Maturity of public sector digital healthprofessional careers

17Facilitate the ability for individuals and data to movethrough the continuum of care to enable data to beseamlessly shared, stored, and used when, where,
and how they are needed

STANDARDS AND INTEROPERABILITY
Indicator 15: National digital health architecture and/or health information exchange
Indicator 16: Health information standards
Includes computing equipment and connectivity andelectricity required to run digital health services andapplications

INFRASTRUCTURE

Indicator 17: Network readinessIndicator 18: Planning and support for ongoing digital
health infrastructure maintenance
Reflects the digital health interventions deployed
for service delivery and/or tracking health system
performance
Indicator 19: Nationally scaled digital health systems
Indicator 20: Digital identity management of service
providers, administrators, and facilities for digital
health, including location data for Geographic
Information Systems mapping

SERVICES AND APPLICATIONS

Indicator 21: Digital identity management of individuals
for health (master patient index representative of the
population)
Indicator 21a: Digital identity managementof individuals for health (master patient index
accessible and ready for use)
Indicator 21b: Digital identity managementof individuals for health (secure birth registry)
Indicator 21c: Digital identity managementof individuals for health (secure death registry)
Indicator 23: Population healthmanagement contribution of digital health

Source: GDHM (2023a)

18

These seven ehealth components were measured
based on the 23 standardized indicators developed by
the Global Digital Health Monitor team together withrepresentatives from ministries of health of the 67
participating countries. Where data are unavailable,
proxy data from publicly available databases wereused especially for countries that could not provide
data (e.g., Brunei Darussalam and Singapore). For acomprehensive discussion of the methodology used,
please refer to the Methodology section of GDHM
(2023a).
Figure 7 illustrates the performance of the ASEAN
countries and Japan on each indicator measuring
digital health readiness and maturity according to
the Global Digital Health Monitor (GDHM 2023a) using
a radar graph.

FIGURE 7. DIGITAL HEALTH READINESS AMONG ASEAN COUNTRIES
Note: Adjusted scale for extreme values (0 and -1), in Singapore and Brunei Darussalam due tolack of available data.

MEMBER STATEASEAN

MEMBER STATEJAPANMEMBER STATEMEMBER STATEBRUNEICAMBODIA19

MEMBER STATEINDONESIAMEMBER STATELAOMEMBER STATEMEMBER STATEMALAYSIA

MYANMAR

MEMBER STATEMEMBER STATE

PHILIPPINESSINGAPORE

MEMBER STATEMEMBER STATETHAILANDVIET NAM

Source: GDHM (2023a)

20

Figure 7 shows that in terms of leadership andgovernance,
Malaysia,
Singapore,
Thailand,Indonesia, Lao PDR, and Viet Nam have strong
coordination of digital health at the national level.
Malaysia, Myanmar, Philippines, and Thailand haveestablished responsive financing and implementing
strategies to support digital health initiatives andstartups.
Malaysia, Singapore, Thailand, Viet Nam, Indonesia,
Philippines, and Brunei Darussalam have establishednational legal and regulatory policies for thegovernance and protection of digital health data
against possible threats.
In terms of workforce readiness, the Philippines has
been integrating telehealth and ehealth programs
into the mandatory continuing professional

development programs for healthcare professionals
including nurses, doctors, and allied medical healthprofessionals. 1
Singapore, Brunei Darussalam, Indonesia, Malaysia,
Philippines, Viet Nam, and Thailand all have existing
infrastructure that allows for some level of digital
health connectivity.
Thailand, Indonesia, Malaysia, Philippines, andViet Nam have established basic digital healthmanagement systems that can track unique digital
identities of registered patients and users in thesystem.
Table 2 highlights concrete achievements made by
selected AMSs on the seven indicators.

TABLE 2. ACCOMPLISHMENTS OF ASEAN COUNTRIES IN DIGITAL HEALTH

DIGITAL HEALTH INDICATORAMS ACCOMPLISHMENTS
The Malaysian government is one of the first AMSs
to enact legislation with the Telemedicine Act in 1997.

LEADERSHIP AND GOVERNANCE

The Philippines enacted the Telehealth Act of 2012
and the subsequent Data Privacy Act of 2012.
Singapore implemented its National Telemedicine
Guidelines in 2015.
The Malaysian government provides grants,
acceleration, and regulatory support for digital healthstartups through the Malaysian Research Accelerator
for Technology & Innovation.

STRATEGY AND INVESTMENT
Singapore’s Startup SG provides funding andinvestment, infrastructure, and workforce support tostartups including digital health companies.

1

Continuing professional development in the Philippines is mandated by the Republic Act No.
10912: Continuing Professional Development Act of 2016.

21

Indonesia, Malaysia, Philippines, Singapore, and Viet
Nam have existing laws and regulations specific to
medical data protection and data privacy (refer tothe Appendix).

LEGISLATION, POLICY,
AND COMPLIANCE

Brunei Darussalam, Lao PDR, and Thailand haveregulations governing data protection for digital
health use.
Cambodia and Myanmar are still in the review stagesof their data protection policies.

WORKFORCEThe University of the Philippines Manila–National
Telehealth Center provides accredited continuing
professional development programs for licensed
nurses on ehealth training for health professionals,
open source medical record systems, community
health information tracking system, and HIV telehealthtraining program, among others. 2

STANDARDS AND INTEROPERABILITY

Brunei Darussalam established the Brunei Darussalam
Healthcare Information and Management System in
2012, which integrates the management of all patients’
health data through the country’s electronic patient
record system or One Health One Record System.

INFRASTRUCTURE

Singapore is integrating the connectivity of healthcare
services and processes by establishing the following
systems: HealthHub, National Electronic Health
Record, Next Generation Electronic Medical Record,
National Harmonised Integrated Pharmacy System,and the National Billing System. Upon completion,these systems will allow the seamless integration of all
patient data in the healthcare journey across various
care settings and providers.
Singapore established its National Electronic Health
Record System in 2012.

SERVICES ANDAPPLICATIONS

Overall, gaps (scores equal to or less than 3) needing
further strengthening are in the areas of strategy
and investment, workforce, and standards andinteroperability. In addition to these, key experts
and individuals in Lao PDR, Malaysia, Philippines,
Singapore, and Viet Nam contributed their insights

22

Brunei Darussalam established the One Health One
Record System in 2013.
on the contextual challenges and opportunities
of implementing digital health initiatives in theirrespective countries. The following section unravels
the various layers of digital health implementation in
selected ASEAN countries.
For a list of the accredited continuing professional development
programs for Filipino nurses, see NURSING PROGRAM12092020.
pdf (prc.gov.ph).
2

4. CHALLENGES AND GAPS IN DIGITALHEALTH ADOPTION AMONG AMSS

were found to be cyber vulnerable countries (TFGI2023; Figure 8). Borrowing from the Organisation for
Economic Co-operation and Development’s conceptof resilience as used in disaster management,
the study defines cyber resilience as the “abilityof individuals, communities, and states and their
institutions to absorb and recover from shocks, whilst
positively adapting and transforming their structuresand means for living in the face of long-term changes
and uncertainty” (TFGI 2023, 17). Regulations on dataprotection must be able to flexibly adapt given thefast and iterative nature of software and digital
health technology.

Despite significant achievements for someASEAN countries in establishing frameworks andinfrastructures for digital health, the challenge forthe public and private sector in adopting digital
health technologies is mainly user trust.

4.1. LACK OF TRUST IN DATA PROTECTION
AND CYBERSECURITY
In a study on the state of cybersecurity and resiliencein six Southeast Asian countries, Singapore, Malaysia,
Thailand, and the Philippines exhibited strong cyber
resilience capabilities, while Viet Nam and Indonesia

FIGURE 8. STATE OF CYBER RESILIENCE IN SIX ASEAN MEMBER STATESCapability to Lower Probability

100
Cyber Protective Countries

90

Cyber Resilient Countries

Malaysia

Singapore

80

Thailand70

Philippines

60
50

Viet Nam

40
30

Indonesia

20
10Cyber Vulnerable Countries

0
0

10

20

30

Cyber Responsive Countries

40

50

60

70

80

90

100

Capability to Reduce Impact
Source: Cyber Resilience Framework in TFGI (2023, 25)
Note: Cyber protective countries have high capability to reduce probability but have low capability to reduce impact. Cyber resilient
countries have high capability to reduce probability and have high capability to reduce impact. Cyber vulnerable countries have low
capability to reduce probability and have low capability to reduce impact. Cyber responsive countries have low capability to reduce
probability but have high capability to reduce impact.

The government’s role in shaping trust in technology
is high if public trust in the government’s transparency
is relatively high:“I will definitely feel secured because it is agovernment application. By government application,that means it has gone through a whole lot of dataprotection, [and] government security check audit”.
– Digital health startup accelerator from Singapore

This trust is concurrently tied with the strength ofgovernance on data-related policies and regulations,which creates an atmosphere of security. Public trustin the government tends to be derailed by persisting
threats such as cybersecurity issues, which remainsa challenge for most ASEAN countries:“During the pandemic, when we were doing our main
app for the pandemic management…because it was23led by the government, so the trust was very high.
We had almost 30 million users on it... Cybersecurity
issues not only in Malaysia but also in neighbouring
countries… that shakes out the trust”. – State
medical director in Malaysia
Among ASEAN countries, Cambodia and Myanmar
have not implemented laws or policies that protect
medical and health data, while other AMSs havesome regulations that protect data in general.
Lack of trust also relates to the social norms andhealth-seeking behaviours concerning technology.
The COVID-19 pandemic created an incentive for theuse of telehealth and other forms of remote medical
platforms amid community quarantines that madetraveling to medical facilities a challenge. However,some key experts noted that in the wake of postCOVID rehabilitation, patients have defaulted backto the traditional in-person consultation even if theoption of telehealth is made available to them.
“It is about trust and the habits; people still are very
accustomed to going to a hospital. Despite all thepain points of a patient journey, some people willtake two hours, go to a rural provincial [hospital] tothe city, wait for two hours again to see a doctor for
only two minutes, and then go back home”.
– Manager in a multinational digital health company
in Viet Nam
As telehealth requires digital connectivity, access tosuch services may be limited to urban communities
that have a more stable network connection, andmobile phone ownership and utilization may be
demographic-specific and pose a challenge for older
patient populations.
“In terms of public acceptance, people are generally
ready to embrace technology; [however] the degreeof usage may vary. However, connectivity remains
an issue in rural areas… cashless transactions
are prevalent, driving smartphone usage, and the
majority of people own smartphones with improved
connectivity. These supportive factors are essential
for the advancement of digital health”. – State
medical director of Malaysia

24

Ensuring digital connectivity and network readinessremains an essential component of digital healthintegration and adoption, as noted previously.

4.2 FRAGMENTED DIGITAL HEALTH SYSTEMS
Among the key challenges facing ASEAN countries
is the establishment of a secure medical data
identification system.
“We face challenges in maintaining a consistent
health identification system. Different hospitals use
different health IDs, making it difficult to exchange
health information”. – Former head of healthinformatic division in Lao PDR
Related to medical data identification is data
ownership, which ideally should be owned by thepatient. However, without a clear regulation on data
ownership, protection, and privacy, security remains
an issue.
“While we promote data interoperability, data
ownership is not well-defined in Malaysia. Currently,
patient data belongs to hospitals. We are working
on enabling patients to own their data. We are also
pushing for more collaboration with cloud service
provider to ensure compliance and security, thoughchallenges exist in government regulations”.
– Government startup accelerator in Malaysia
The government plays an important role in ensuringthat these regulatory policies are in place to protect
patient data and ensure that whoever owns medical
data has the adequate means to keep it secure.
“Seamless transition of patient data through acircled platform that allows registered and certified
healthcare entities. It can be startups, small
businesses, publics hospitals to assess information
upon request by the specific user”. – Digital healthstartup accelerator from Singapore
Patients must be sure that their data are responsibly
managed when they utilize digital health services.
Equally, hospitals and medical institutions mustcomply with established legal standards andguidelines to guarantee the safety and security ofpatient data records.

5. ADVANCING DIGITAL HEALTH ADOPTION IN
ASEAN
Given the relative differences in the digital healthcapacities and uptake of ASEAN countries, thisreport offers four strategies for governments toadvance the adoption of digital health in the region.
These are (1) build trust through data protection
and governance, (2) develop standards for aninteroperable digital health infrastructure, (3) enabledigital startups to foster innovation, and (4) promotehealthcare professionals’ digital training support.

5.1.
BUILD
TRUST
THROUGH
PROTECTION AND GOVERNANCE

DATA

In addition to enhancing the interoperability of thehealthcare data ecosystem, fostering user trust is also
vital for the adoption of digital health in the region.
Experts in digital health underscore the importanceof robust regulatory structures and mechanisms thatbalance innovation and data security. Achieving thisbalance is essential as it would foster confidence
in the ecosystem. Figure 9 shows that out of the 10
AMSs, five have existing laws and regulations specificto digital health and data protection and three havelegal frameworks for data protection, while twoare still developing both. The Appendix presents acomprehensive list of existing laws and regulations
on telemedicine and telehealth and data protection
for medical data.

FIGURE 9. DATA PROTECTION AND DIGITALHEALTH LAWS AND REGULATION AMONGASEAN COUNTRIESAMS with legal
framework fordata protection
Brunei Darussalam
Lao PDR
ThailandIndonesia
Malaysia
Philippines
Singapore
Viet Nam

AMS with laws
or regulations
for ehealth,telemedicine, anddigital healthCambodia
Myanmar

Source: Authors

Trust is a key element in the adoption of digital
health technologies, especially for users who areencountering and using digital health services forthe first time. A recommended approach to fostering
trust and ensuring the implementation of appropriate
guidelines is the adoption of sandbox practices.
Digital health sandboxes provide a controlledenvironment for the preliminary testing of newtechnological solutions prior to their public release.
This also presents a timely opportunity for regulators
to ascertain that clear data governance, stringent
cybersecurity guidelines, and data protection policies
are in effect. At present, countries like Singapore,
Malaysia, and Indonesia have implemented sandbox
programs specifically for digital health technologies.

5.2.
DEVELOPSTANDARDS
INTEROPERABLE
DIGITALINFRASTRUCTURE

FORAN
HEALTHWithin ASEAN countries, the absence of acomprehensive and unified digital health data system
is a significant hurdle. Notably, the Philippines andMalaysia have created comprehensive national
digital health frameworks and blueprints andindustry standards for health information exchange.
Singapore, Malaysia, and Brunei Darussalam haveestablished nationwide electronic medical records
systems. Despite these efforts, the integration
and use of medical data across diverse platforms
continues to be inconsistent. This issue prevents theseamless connectivity of health data and complicatesthe user experience in digital health.
In terms of data encoding, the absence of uniform
data standards and taxonomy are major obstacles inallowing interoperability of electronic health records.
For instance, when documenting a patient’s medical
history, public and private hospitals employ various
platforms to encode medical data, which could bein different formats. Without well-defined data
standards, the task of synchronizing digital systems
and enhancing interoperability remains challenging.
To enhance interoperability, unifying data encoding
is key to harmonizing data and creating a datasystem for the healthcare sector. A certain degreeof digital proficiency is also required for healthcare
workers to shift from paper records to digital data
and to understand and use the same taxonomy of
medical data.
25

CASE STUDY 1: ESTABLISHING SINGAPORE’S
NATIONAL ELECTRONIC HEALTH RECORD

5.3. ENABLE DIGITAL STARTUPS TO FOSTERINNOVATION

In 2011, Singapore’s Ministry of Health initiated its
first national electronic health record (NEHR), whichbecame the foundation for the integration of all
patients’ medical records and can be accessed byvarious public and private healthcare providers who
are onboarded into the system. This development
was motivated by the continuity of care envisioned
in the “One Patient One Record” goal of the Ministryof Health. Health data stored in the NEHR includes
patient demographics; hospital visit, admission, anddischarge history; radiology and laboratory test
results; medication history and allergies and drug
reactions; and surgical procedure history (Synapxen.d.).

In addition to the adoption of digital technologies
by conventional healthcare entities like hospitals
and clinics, digital health specialists emphasize thecrucial role of startups in propelling the digital healthecosystem forward. These startups are instrumental
in creating technology-driven solutions that not only
encourage users to embrace digital health but also
introduce pioneering business models.

Singapore’s healthcare system combines public
and private health servicing, where primary care is
80% private (general practitioner clinics) and 20%
public, secondary and tertiary care is 80% public
and 20% private (hospitals), and intermediate andlong-term care is 70% public and 30% private. Initial
implementation challenges included the unevennessof data encoding from various sources, including
codification, structure, availability, and taxonomy.
To overcome these initial challenges, theimplementation was staged in two phases. The firstphase beginning in 2012 involved one-way sharing ofhealth data, limiting viewing of health information
to the NEHR portal. The second phase, which was
accomplished in 2015, included increased integrationand two-way health data flows, more informationand data sources, and increased portal access andreconciliation services (Stephanie 2018, 1129).
An important aspect and challenge of setting up the
NEHR is the onboarding of both public and private
healthcare providers, especially the latter, which may
regard being part of the network as unnecessary
and costly. At present, some private clinics andhealth providers (including general practitioners andoutpatient specialists) are accessing the NEHR. See(2020) revealed that among private healthcare service
providers that do not access it, low levels of technicalaptitude and perceived inadequate level of support
contribute to less likelihood to use the system.

26

To stimulate innovation in the healthcare sector,
nations like Singapore and Malaysia have set up
specialized agencies to aid digital health startups.
For instance, Startup SG offers financial assistance,
education, and infrastructure support for startups,
accelerators, and investors. Similarly, the Malaysian
Research Accelerator for Technology & Innovation
serves as an accelerator, providing research
incubation assistance from the conceptual stage tomarket entry and expansion.
“The sandbox process involves technology
assessment teams evaluating start-ups’ readinessfor clinical validation. We advise start-ups on whether
they need sandbox validation or can proceed tomarket access”. – Government startup accelerator in
Malaysia“The main challenge for local innovations is the costof certification. Medical devices, especially high-risk
ones, require costly tests. The application processitself can be time-consuming sometimes taking six
months to a year. This is a major financial burden forstart-ups, potentially leading to bankruptcy”.
– Government startup accelerator in Malaysia
While pinpointing a viable business model and a
proof of concept with real market value and demand
is a key step in fostering innovation, it is just the
beginning. Equally important is for governments tofacilitate the entry of digital startups into the market
by ensuring fair competition. Enabling these startups
to expand and flourish is vital for them to make asignificant contribution to the healthcare industry.

CASE STUDY 2. INDONESIA’STELEHEALTH SANDBOXIn 2023, Indonesia’s Ministry of Health launcheda regulatory sandbox with the aim of testing
new innovations in digital health, specifically intelemedicine. This initiative was formalized throughDecree No. HK.01.07/Menkes/1280/2023. Initially,
the sandbox program was started to find innovative
solutions to malaria treatment. Eventually, it expanded
to include telemedicine applications (Antara 2023a).
The telemedicine sandbox aimed to foster innovative
digital solutions, while ensuring regulatory compliance.
One of the criteria specified by the decree is for thedigital solution to have the potential to benefit the
public through inclusivity and equal accessibility.
The initiative gathered interest from 15 developers,
including Riliv, Medic+, Klinik Simas Sehat, Good
Doctor, Naluri, MyCLNQ Sehat, Lifepack, Alodokter,
Halodoc, Sehati TeleCTG, Getwell, FitHappy, Cexup,
SIRKA, and SehatQ (Antara 2023b). The sandbox
closed in December 2023 with the government
currently assessing the next steps in terms ofpotential policies for the telehealth sector.
Regulatory sandboxes in Indonesia’s digital healthindustry are expected to include other sectors of thedigital health ecosystem, including the protectionof personal data, the pharmaceutical industry, anddata-based health technologies (Antara 2023a).

5.4. PROMOTE HEALTHCAREPROFESSIONALS’ DIGITAL TRAININGSUPPORT
One of the main challenges of several AMSs’ digital
health capacities involve limited availability of digitalready healthcare professionals and tech supporters.
Interviews with several health officials echoed thisassessment, who noted that because the priority haslargely been on infrastructure development, limited
public resources have hampered streamlined trainingof health professionals.
Many opportunities exist to include digital healthsubjects in health education curricula, in continuing
professional education courses, and in post-graduate
studies.

The ASEAN Mutual Recognition Arrangements aim toharmonize education and professional qualificationsof selected professionals, including of doctors,
nurses, and dentists, and could be a good platform
for onboarding digital health capacity building among
ASEAN professionals, or as part of certification
requirements.
The private sector and non-governmentalorganizations also play an important role in building
the capacities of health professionals, especially inaligning with industry standards.

TOWARDS DIGITAL-IN-HEALTH
The role of digital health in expanding medical
services to a wider consumer base in Southeast Asia
will continue given current developments in medical
and health technology. The implications of this will
be varied and wide-ranging and adjust rapidly to theneeds of changing societies. ASEAN countries aregradually evolving towards an older population, and
the WHO projects that by 2030, 13.7% of Southeast
Asians will be over 60 years old, a figure anticipatedto rise to 20.3% by 2050. Moreover, new illnesses anddiseases needing new therapeutic interventions are
emerging. The use of digital health technologies
will aid in enhancing accessibility and elevating thequality of care as Southeast Asia confronts newhealth issues resulting from an ageing population.
This report underscores the importance of establishingstandards to allow for data interoperability among
health service providers, building trust throughstrong governance in data protection, supporting
innovation through digital startups, and promoting
the digital training of healthcare professionals.
While the pandemic has significantly accelerated theadoption of digital health, it is vital to underscore theresponsibility of ASEAN governments in maintaining
this progress. Incorporating digital transformation
strategies into broader national health plans could
direct the attention of digital health ecosystem
participants towards infrastructure, trust, andinnovation, all of which are essential for advancing
the digital health agenda.

27

REFERENCESACCESS Health International Southeast Asia (2019). Reaching 650 million: Digitaltechnology is key to achieving universal health coverage in ASEAN. Singapore.
https://accessh.org/reports/reaching-650-million-how-digital-technology-is-keyto-achieving-universal-health-coverage-in-asean/
Antara (2023a). Health Ministry launches regulatory sandbox to secure telemedicine.
Accessed 4 June 2024.
https://en.antaranews.com/news/278697/health-ministry-launches-regulatorysandbox-to-secure-telemedicine
Antara (2023b). Minister announces 15 health innovators chosen for regulatory
sandbox. Accessed 4 June 2024. https://en.antaranews.com/news/283449/
minister-announces-15-health-innovators-chosen-for-regulatory-sandbox
GDHM (Global Digital Health Monitor) (2023a). Database. Accessed 21 March 2024.
https://monitor.digitalhealthmonitor.org/map
GDHM (Global Digital Health Monitor) (2023b). The state of digital health 2023.
https://digitalhealthmonitor.org/stateofdigitalhealth23
Network Readiness Index (2023).
networkreadinessindex.org/countries/

Accessed

21

March

2024.

https://

See, Q. Y. (2020). Attitudes and perceptions of general practitioners towards the
National Electronic Health Record (NEHR) in Singapore. European Medical Journal
5(1): 86–93. https://doi.org/10.33590/emj/19-00184
Stephanie, F. L. (2018). Singapore’s NEHR: Challenges on the path to connected
health. 2017 IEEE International Conference on Industrial Engineering andEngineering Management, December 2017, 1128–1132. https://dx.doi.org/10.1109/
IEEM.2017.8290068

28

Synapxe (n.d.). National health electronic record. Accessed 4 June 2024. https://www.synapxe.sg/healthtech/national-programmes/national-electronic-healthrecord-nehr/
TFGI (Tech for Good Institute) (2023). Towards a resilient cyberspace in Southeast
Asia.
https://techforgoodinstitute.org/wp-content/uploads/2023/07/TFGI_
Towards_a_Resilient_Cyberspace_in_Southeast_Asia_Executive_Summary.pdf
World Bank (2023). Digital-in-health: Unlocking the value for everyone.
Washington DC: The World Bank. https://openknowledge.worldbank.org/entities/
publication/06ffb4d1-a7c0-4563-9feb-f14fa8395e32
WHO (World Health Organization) (2010). Monitoring the building blocks of healthsystems: A handbook of indicators and their measurement strategies. Geneva:WHO.
WHO (World Health Organization) (2012). National ehealth strategy toolkit. Geneva:
WHO.
https://www.who.int/publications-detail-redirect/national-ehealthstrategy-toolkit
WHO (World Health Organization) (2021). Global strategy on digital health 2020–2025. Geneva: WHO.
https://www.who.int/publications/i/item/9789240020924
WHO (World Health Organization) (2023). Health statistics 2023: Annex 2. Geneva:
WHO. https://www.who.int/data/gho/publications/world-health-statistics

29

APPENDIXTABLE 3. LAWS AND POLICIES ON TELEHEALTH AND DATA PROTECTION OF MEDICAL DATA
IN 10 ASEAN MEMBER STATESLAWS OR REGULATIONS ON
TELEMEDICINE OR TELEHEALTHLAWS OR REGULATIONS ON DATA PRIVACY
AND DATA PROTECTION

None

Personal Data Protection Order (under development by the
Authority for Info-communications Technology Industry ofBrunei Darussalam)

None

E-Commerce Law (2019)

Minister of Health Regulation No. 9 of 2020
on Guidelines for the Implementation ofTelemedicine Services

Electronic Information and Transactions Law, supplemented
by two regulations: Government Regulation No. 71 of 2019
regarding Provisions of Electronic Systems and Transactions
and Minister of Communications & Informatics Regulation No.
20 regarding Protection of Personal Data in Electronic System(“ PDP Regulation ”).

BRUNEIDARUSSALAM
CAMBODIAINDONESIA

Konsil Kedoktoran Indonesia (KKI) Regulation
No. 74 of 2020 on Clinical Authorities andMedical Treatment Through Telemedicine
During the COVID-19 Pandemic

Law of the Republic of Indonesia No. 11 of 2008 Concerning
Electronic Information and Transactions

Regulation of Minister of Health of
the Republic Indonesia No. 20 of 2019:
Organisation of Telemedicine Services
through Health Service Facilities
Law No. 36 of 2009 on Health
None

LAO PDR

Law on Resistance and Prevention of Cybercrime No. 61/NA(2015)
Telemedicine Act 1997 (Ministry of Health)

MALAYSIA

Law on Electronic Data Protection No. 25/NA (2017)

Personal Data Protection Act 2010 and subsidiary regulations

Malaysian Medical Council Advisory on Virtual
Consultation 2020 (during the COVID-19
pandemic)
Medical Device Authority Act (2012) (Act 737)
None

MYANMAR30

None

Telehealth Act of 2012

Republic Act 10173: Data Privacy Act of 2012

Telehealth Act of 2014
Senate Bill No. 1618 (The Philippine eHealth
Systems and Services Act) *(Not yet
enacted)Guidelines of the Use of Telemedicine in
COVID-19 Response

PHILIPPINES

Privacy Guidelines on the Processing andDisclosure of COVID-19 Related Data for
Disease Surveillance and Response
Guidelines on the Monitoring and Evaluation(M&E) of the Use of Telemedicine in
COVID-19 Response
Department of Health-University of thePhilippines Manila (DOH-UPM) Joint
Memorandum Circular No. 2020-0001“Telemedicine Practice Guidelines”
Health Services Act 2021–2022 (Singapore
Ministry of Health)

SINGAPORE

Personal Data Protection Act 2012 (No. 26 of 2012) and othersubsidiary legislations and regulations

2015 National Telemedicine Guidelines(Ministry of Health)
Ethical Code and Ethical Guidelines 2016 - A6.
Telemedicine (Singapore Medical Council)
Regulatory Guidelines for Telehealth Products
and Devices (2018)
Notification No. 54/2563 (2020) Guideline on
Telemedicine and Online Clinics (The Medical
Council of Thailand)

THAILANDVIET NAM

Personal Data Protection Act 2019 - section 26

eHealth Strategy, Ministry of Public Health(2017–2026)

Regulating the Management of Distance
Medicine Circular 49/2017 (Viet Nam Ministryof Health)Decree No. 13/2023/ND-CP on Personal Data Protection

Decision No. 4888 of 2019: Application of
Smart Health Information Technology in the
Period of 2019-2025 (Ministry of Health)

Directive No. 16 of 2017

Law on Network Information Security 2016

Law No. 15/2023/QH15 – article 80: Law on
Medical Examination and Treatment 2023.

Source: Collected by authors from various sources (links to the original source are included where available)31