[Survey of 1,410 Non-Bed Clinics] Only 9.4% of Clinics with Websites Describe All 3 Categories of MHLW Posting Rules (Notification No. 107)
Wellpipo Co., Ltd. conducted a survey of 1,410 non-bed clinics nationwide and found that only 9.4% of facilities with websites fully describe all three categories of the Ministry of Health, Labour and Welfare's mandatory posting rules (Notification No. 107), which became obligatory in the 2024 medical fee revision. This suggests an estimated 94,000 clinics nationwide remain non-compliant.
📋 Article Processing Timeline
- 📰 Published: April 30, 2026 at 19:00
- 🔍 Collected: April 30, 2026 at 10:31
- 🤖 AI Analyzed: April 30, 2026 at 19:47 (9h 16m after Collected)
Wellpipo Co., Ltd. (Headquarters: Hakata-ku, Fukuoka City; Representative Director: Masaya Ohno) conducted a random sampling survey of 1,410 non-bed clinics nationwide to assess their compliance with the "Posting Matters Determined by the Minister of Health, Labour and Welfare (Notification No. 107) to be Published on HP," which was made mandatory in principle by the 2024 medical fee revision. Approximately one year after the full mandatory implementation (June 2025), and with further expansion of posting requirements in the FY2026 revision (effective June 1, 2026), it was found that only a mere 9.4% of facilities with websites were able to describe all three categories, with the lowest being "Issuance of Detailed Statements" at only 9.3%. It is estimated that approximately 94,000 clinics nationwide remain non-compliant.
**Survey Summary**
* Out of 1,410 non-bed clinics nationwide, 66.0% (931 facilities) possessed an official website.
* Among facilities with a website, only 9.4% (78 facilities / out of 828 scorable facilities) described all three categories: facility standards, issuance of detailed statements, and out-of-insurance burden.
* The lowest description rate among the three categories was "Issuance of Detailed Statements" at 9.3% (121 facilities out of 1,307 scorable facilities).
* Followed by "Out-of-insurance Burden" at 15.4% and "Facility Standards" at 23.3%.
* 48.8% (404 facilities) of facilities with websites had no description found for any of the three categories.
* Nationwide, an estimated 94,000 non-bed clinics lack at least one of the three categories.
**Background: What is the "HP Posting Obligation" of Notification No. 107?**
With the 2024 (Reiwa 6) medical fee revision, insurance medical institutions providing outpatient care were mandated to "also publish the posting matters determined by the Minister of Health, Labour and Welfare (Notification No. 107) on their websites" (Article 2-6, Paragraph 2 of the Regulations on Responsibilities of Medical Care Providers). A transitional measure was set until May 31, 2025, with full mandatory implementation from June 1, 2025.
These posting rules are categorized into 5 items in "Article 1" of the Notification (① Basic Inpatient Fees ② DPC-related ③ Matters notified to Regional Bureaus of Health and Welfare ④ Status of Detailed Statement Issuance ⑤ Out-of-insurance Burden). Among these, "Matters Notified" is linked to over 20 individual posting requirements, including facility standards, medical information acquisition additions, medical DX promotion system development additions, lifestyle disease management fees, after-hours response additions, and detailed statement issuance system additions.
The Ministry of Health, Labour and and Welfare's cautionary notice (Hoihatsu Notice) explicitly states that this measure was taken "from the perspective of promoting the provision of information to patients," and the revision explanation material from the Central Social Insurance Medical Council also indicates that, based on the digital principle, making written posting matters available online is the intent of the system.
**Posting Requirements Further Expanded in the FY2026 Revision**
In the FY2026 medical fee revision (MHLW Notification No. 68 of Reiwa 8, main implementation on June 1, 2026) announced on March 5, 2026, the items requiring web publication have been further expanded. Key changes are as follows:
* Abolition/integration of medical information acquisition additions/medical DX promotion system development additions, and establishment of "Electronic Medical Information Linkage System Development Addition" (e.g., Addition 1: 15 points for initial outpatient visit). To claim this addition, the website publication of utilization status of My Number health insurance cards and electronic prescriptions will be a facility standard.
* Mandatory publication of the Online Medical Care Guidelines Compliance Checklist on the website.
* Mandatory posting (in principle, web publication) of whether long-term prescriptions and refill prescriptions are available.
* Continued posting due to reduction in points for generic name prescription additions (Addition 1: 10→8 points, Addition 2: 8→6 points).
The nature of posting has evolved from "whether it was introduced" to an actual performance evaluation type of "whether actual usage is disclosed," and a type of posting where "if not posted, additions cannot be obtained" (a claim requirement type) is spreading.
**Survey Results**
This survey analyzed the actual situation from four perspectives: HP ownership rate / 3-category description rank distribution / description rate by category / prefectural rank 3 rate.
**HP Ownership Status (N=1,410)**
* 66.0% (931 facilities) possessed an official website. 34.0% (479 facilities) had no website or their URL could not be identified. Facilities where acquisition was not possible due to SSL certificate errors etc. (103 facilities, 7.3%) were excluded as undecided.
**3-Category Description Status Rank Distribution**
Among the 828 scorable HP-owning facilities:
* Rank 3 (all 3 categories described): 78 facilities (9.4%)
* Rank 2 (1-2 categories described): 346 facilities (41.8%)
* Rank 1 (none described): 404 facilities (48.8%)
**Description Rate by Category (among 1,307 scorable facilities)**
* Issuance of Detailed Statements: 121 facilities / 9.3%
* Out-of-insurance Burden (diagnostic fees, self-pay medical care, beauty, diapers, etc.): 201 facilities / 15.4%
* Facility Standards (notification additions, management fees): 305 facilities / 23.3%
The judgment criteria were lenient: "Regardless of the presence of a dedicated page or list format, if the relevant keywords were found anywhere, such as in announcement articles, footers, self-pay fee pages, or site maps, it was counted." Even with these lenient criteria, the rates remained at this level.
**Survey Summary**
* Out of 1,410 non-bed clinics nationwide, 66.0% (931 facilities) possessed an official website.
* Among facilities with a website, only 9.4% (78 facilities / out of 828 scorable facilities) described all three categories: facility standards, issuance of detailed statements, and out-of-insurance burden.
* The lowest description rate among the three categories was "Issuance of Detailed Statements" at 9.3% (121 facilities out of 1,307 scorable facilities).
* Followed by "Out-of-insurance Burden" at 15.4% and "Facility Standards" at 23.3%.
* 48.8% (404 facilities) of facilities with websites had no description found for any of the three categories.
* Nationwide, an estimated 94,000 non-bed clinics lack at least one of the three categories.
**Background: What is the "HP Posting Obligation" of Notification No. 107?**
With the 2024 (Reiwa 6) medical fee revision, insurance medical institutions providing outpatient care were mandated to "also publish the posting matters determined by the Minister of Health, Labour and Welfare (Notification No. 107) on their websites" (Article 2-6, Paragraph 2 of the Regulations on Responsibilities of Medical Care Providers). A transitional measure was set until May 31, 2025, with full mandatory implementation from June 1, 2025.
These posting rules are categorized into 5 items in "Article 1" of the Notification (① Basic Inpatient Fees ② DPC-related ③ Matters notified to Regional Bureaus of Health and Welfare ④ Status of Detailed Statement Issuance ⑤ Out-of-insurance Burden). Among these, "Matters Notified" is linked to over 20 individual posting requirements, including facility standards, medical information acquisition additions, medical DX promotion system development additions, lifestyle disease management fees, after-hours response additions, and detailed statement issuance system additions.
The Ministry of Health, Labour and and Welfare's cautionary notice (Hoihatsu Notice) explicitly states that this measure was taken "from the perspective of promoting the provision of information to patients," and the revision explanation material from the Central Social Insurance Medical Council also indicates that, based on the digital principle, making written posting matters available online is the intent of the system.
**Posting Requirements Further Expanded in the FY2026 Revision**
In the FY2026 medical fee revision (MHLW Notification No. 68 of Reiwa 8, main implementation on June 1, 2026) announced on March 5, 2026, the items requiring web publication have been further expanded. Key changes are as follows:
* Abolition/integration of medical information acquisition additions/medical DX promotion system development additions, and establishment of "Electronic Medical Information Linkage System Development Addition" (e.g., Addition 1: 15 points for initial outpatient visit). To claim this addition, the website publication of utilization status of My Number health insurance cards and electronic prescriptions will be a facility standard.
* Mandatory publication of the Online Medical Care Guidelines Compliance Checklist on the website.
* Mandatory posting (in principle, web publication) of whether long-term prescriptions and refill prescriptions are available.
* Continued posting due to reduction in points for generic name prescription additions (Addition 1: 10→8 points, Addition 2: 8→6 points).
The nature of posting has evolved from "whether it was introduced" to an actual performance evaluation type of "whether actual usage is disclosed," and a type of posting where "if not posted, additions cannot be obtained" (a claim requirement type) is spreading.
**Survey Results**
This survey analyzed the actual situation from four perspectives: HP ownership rate / 3-category description rank distribution / description rate by category / prefectural rank 3 rate.
**HP Ownership Status (N=1,410)**
* 66.0% (931 facilities) possessed an official website. 34.0% (479 facilities) had no website or their URL could not be identified. Facilities where acquisition was not possible due to SSL certificate errors etc. (103 facilities, 7.3%) were excluded as undecided.
**3-Category Description Status Rank Distribution**
Among the 828 scorable HP-owning facilities:
* Rank 3 (all 3 categories described): 78 facilities (9.4%)
* Rank 2 (1-2 categories described): 346 facilities (41.8%)
* Rank 1 (none described): 404 facilities (48.8%)
**Description Rate by Category (among 1,307 scorable facilities)**
* Issuance of Detailed Statements: 121 facilities / 9.3%
* Out-of-insurance Burden (diagnostic fees, self-pay medical care, beauty, diapers, etc.): 201 facilities / 15.4%
* Facility Standards (notification additions, management fees): 305 facilities / 23.3%
The judgment criteria were lenient: "Regardless of the presence of a dedicated page or list format, if the relevant keywords were found anywhere, such as in announcement articles, footers, self-pay fee pages, or site maps, it was counted." Even with these lenient criteria, the rates remained at this level.