IAS 37 · Healthcare

IAS 37 Provision Calculator
for Healthcare

Pre-configured for healthcare provision types: medical malpractice and clinical negligence claims, regulatory compliance penalties, drug and device recall provisions, and healthcare service restructuring.

Obligation Type

Present Obligation

Does a present obligation exist from a past event?

IAS 37 Provision Assessment Toolkit — free PDF

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IAS 37.14 — A provision shall be recognised when: (a) an entity has a present obligation from a past event; (b) it is probable that an outflow will be required; (c) a reliable estimate can be made.

IAS 37.36 — The amount recognised shall be the best estimate of the expenditure required to settle the present obligation at the end of the reporting period.

IAS 37.39 — Where there is a large population of items, the obligation is estimated by weighting all possible outcomes by their associated probabilities (expected value).

IAS 37.45 — Where the effect of the time value of money is material, the amount of a provision shall be the present value of the expenditures expected to settle the obligation.

IAS 37.72 — A constructive obligation to restructure arises only when an entity has a detailed formal plan and has raised a valid expectation in those affected.

IAS 37 Provisions in Healthcare

Healthcare entities face a provision landscape characterised by high-value clinical negligence claims, stringent regulatory compliance requirements, and the unique complexities of operating in a heavily regulated public-interest environment. Medical malpractice provisions are often the single largest IAS 37 item for healthcare organisations, with individual claims potentially reaching millions of euros and long settlement timeframes extending over many years. The probability assessment for clinical negligence claims requires careful judgement, often involving specialist legal and medical expert input. Healthcare provisions also include regulatory compliance penalties for clinical standards failures, data protection breaches involving sensitive patient information, and drug or medical device recall obligations. For publicly funded healthcare organisations, provisions for meeting governmental mandates and restructuring obligations add further complexity.

Measurement Considerations for Healthcare

Medical malpractice provisions should typically be assessed individually for significant claims using the single best estimate method (IAS 37.40), with specialist legal counsel providing probability assessments. For healthcare organisations with large volumes of lower-value clinical claims, the expected value method may be appropriate. The provision should include both the expected compensation payment and legal defence costs. Long-term claims (those expected to settle in more than one year) should be discounted to present value. Drug and medical device recall provisions should include the direct costs of recall (notification, logistics, replacement), estimated product liability claims, and any regulatory penalties. For pharmaceutical companies, the interaction between IAS 37 provisions and IAS 38 intangible asset impairment (for capitalised drug development costs) requires consideration when a product faces safety concerns.

Regulatory Context and Audit Considerations

Healthcare regulation creates both legal and constructive obligations that give rise to IAS 37 provisions. Clinical negligence claims arise from legal obligations under medical liability legislation. Regulatory compliance penalties are imposed by healthcare regulators (CQC in the UK, ANSM in France, BfArM in Germany) for failures in clinical standards, patient safety, or data protection. GDPR penalties for breaches involving patient health data can be particularly severe given the sensitive nature of medical information. Healthcare restructuring provisions must navigate complex stakeholder landscapes including patients, staff, regulators, and funding bodies, all of whom may need to be consulted before a valid expectation is created.

Common Provision Types in Healthcare

legal claim

Medical malpractice and clinical negligence claims — can involve significant uncertain amounts and long resolution timeframes

Typical: €100K-€10M per claim Timeline: 2-7 years Method: Best Estimate
regulatory penalty

Non-compliance with healthcare regulations, data protection (patient data GDPR), clinical standards failures

Typical: €50K-€50M Timeline: 1-3 years Method: Best Estimate
restructuring

Service reconfiguration, department closures, hospital ward consolidation programmes

Typical: €1M-€50M Timeline: 1-3 years Method: Best Estimate
environmental

Clinical waste management, hazardous material remediation, pharmaceutical disposal obligations

Typical: €100K-€5M Timeline: 1-10 years Method: Best Estimate
product liability

Drug or medical device recall provisions, product defect claims, adverse reaction liabilities

Typical: €1M-€1B Timeline: 3-15 years Method: Best Estimate

Worked Example: Nordic Health Partners AS

A private hospital group is defending three separate medical malpractice claims. Legal counsel provides the following probability and amount assessments:

Outcome Probability Amount
Claim A — orthopaedic complication, probable adverse outcome (75%) 75% €340.000
Claim B — diagnostic delay, possible outcome (40%) 40% €890.000
Claim C — surgical error, probable adverse outcome (80%) 80% €1.200.000

Claim A: 75% probability (>50%) — RECOGNISE provision at best estimate of €340,000. Claim B: 40% probability (<50%) — DISCLOSE as contingent liability only (€890,000 possible exposure). Claim C: 80% probability (>50%) — RECOGNISE provision at best estimate of €1,200,000. Total provision recognised: €340,000 + €1,200,000 = €1,540,000. Contingent liability disclosed: €890,000 (Claim B).

Provision Amount
€1.540.000
Regulatory Context: Healthcare entities are subject to sector-specific regulatory frameworks that create legal obligations for clinical negligence. GDPR applies with heightened significance due to the sensitive nature of patient health data. Drug and medical device regulations create product safety obligations that may trigger recall provisions.

Frequently Asked Questions — Healthcare

How should medical malpractice provisions be measured under IAS 37?
Medical malpractice provisions are typically measured using the single best estimate method for individual significant claims. Each claim should be assessed separately considering: the probability of an adverse outcome (based on legal and medical expert advice), the likely compensation if the claim succeeds (based on jurisdiction-specific damages frameworks), legal defence costs regardless of outcome, and the expected settlement timeline. Claims with probability greater than 50% are recognised as provisions; those between 10-50% are disclosed as contingent liabilities.
Can healthcare entities recognise insurance recoveries against malpractice provisions?
Insurance recoveries can only be recognised as a separate asset when receipt is virtually certain (IAS 37.53). For medical malpractice insurance, this typically requires: a valid insurance policy covering the claim, the insurer has accepted the claim or the entity has strong evidence that coverage applies, and the insurer has the financial capacity to pay. The reimbursement asset must be presented separately — gross presentation is required (IAS 37.54). The provision cannot be reduced by expected insurance recoveries that do not meet the virtually certain threshold.
How do GDPR data breach provisions work for healthcare entities?
GDPR data breaches involving patient health data can trigger IAS 37 provisions for regulatory fines (up to €20M or 4% of global turnover under GDPR), compensation payments to affected patients, notification costs, and remediation expenses. The provision is recognised when a breach is identified and notification obligations are triggered. Healthcare data is classified as 'special category' data under GDPR, potentially resulting in higher penalties. The probability and amount assessment should consider the severity of the breach, the number of affected patients, and the entity's compliance history.
Should drug or medical device recall costs be provisioned under IAS 37?
Yes. When a drug or medical device safety concern triggers a recall obligation — whether legally mandated by a regulator or arising from a constructive obligation through the entity's published safety commitments — a provision should be recognised for the estimated costs of the recall programme. This includes product retrieval costs, replacement or refund costs, communication and notification costs, regulatory compliance costs, and any expected product liability claims. The recall provision should be measured at the best estimate of total costs using available safety incident data.
How does healthcare restructuring differ from other sectors under IAS 37?
Healthcare restructuring provisions require additional consideration because of patient care continuity obligations. The restructuring plan must address how services will be maintained during and after the restructuring. Regulatory approvals may be required before clinical services can be relocated or discontinued, which affects the timing of when a valid expectation is raised. Employee termination costs must reflect healthcare-specific employment arrangements including clinical training commitments and notice periods for medical professionals.