If ASEAN countries were willing to commit to market opening in healthcare in future trade negotiations, should they do so at the multilateral or regional level?<sup>17</sup> No general answer can be given. The benefit of engaging in the WTO is that trade commitments are made on a nondiscriminatory or most-favored nation (MFN) basis. This is economically advantageous, as services providers from around the world will enjoy the same market access conditions, favoring entry of the most efficient suppliers.

At the same time, there are also reasons for negotiating at the regional level. One is that bargaining may be more productive among a smaller set of countries. The WTO now has 148 members at all levels of development and the multilateral trade agenda has much expanded since the early GATT days. Trade negotiations at the multilateral level therefore tend to be complex and time-consuming. Indeed, progress in the current multilateral services negotiations under the Doha Development Agenda (DDA) has been limited, so far.<sup>18</sup> For countries ready to commit to market opening in services, a bilateral or regional forum may deliver quicker results. In addition, if service providers from within the region are at an infant stage, regional market opening may, in theory, offer learning externalities that can enable these providers to become more efficient and eventually face global competition. But regional liberalization may also entail economic costs, mainly in the form of second-based service providers entering the domestic market. Notwithstanding these considerations, the conclusion of trade agreements is also driven by political imperatives, which in recent years have favored the negotiation of bilateral and regional agreements.

There is little controversy that regional agreements have an important role to play in the area of regulatory cooperation. Making regulatory regimes more compatible seems neither feasible nor desirable at the multilateral level. The WTO currently has 148 members, at every level of development and with a wide variety of legal and regulatory systems. While the ten ASEAN countries are not a homogenous group either, there does appear to be scope for increased cooperation in the health sector—as is already happening in many other fields.

The national research studies for the seven ASEAN countries identified a number of specific areas for regulatory cooperation that could be pursued at the ASEAN level:

- _Promoting health tourism exports_ .  Notwithstanding the need for appropriate policy sequencing as outlined above, there are a number of initiatives that could expand trade within the region.  First, an ASEAN-wide framework for the portability of health insurance could be developed, which would seek to address the concerns of public and private insurers in covering medical expenses occurred in other ASEAN countries.

> 17 For a more detailed discussion of the choice of regional versus multilateral agreements in services, see Mattoo and Fink (2004).

> 18 The climate for negotiating trade in health services under the GATS also does not appear to be favorable.  Some NGOs have raised concerns that GATS commitments in the health sector would encroach on national sovereignty and promote inequitable health systems.  In the current negotiating round, this has led the European Communities to refrain from making market-opening requests in this sector to developing countries.  Compared to other service sectors, such as financial and express mail delivery services, there also do not appear to be strong private sector lobbies pushing for liberalization.

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