Who has a duty to register?
All enterprises which provide healthcare outside the public health service are required to pay contributions to NPE. This scheme ensures that patients who suffer injuries due to errors made in connection with their treatment receive the compensation they are entitled to.
Who has a duty to register?
The person responsible for an enterprise that has authorised health personnel in work who provide healthcare outside the public health service must pay contributions to NPE.
Who is a person in work?
‘In work’ refers to health personnel who are permanently employed, contracted and temporarily hired health personnel. Self-employed persons working at a clinic are also considered to be persons in work, provided they are not financially responsible for the enterprise.
If you are hired by an enterprise and are financially liable for the treatment you provide, you will be responsible for registering and paying contributions.
From a purely practical point of view, it may be appropriate for a clinic with multiple self-employed persons who are hired by an enterprise and have financial responsibilities, to also register and pay contributions. This applies in particular if, externally, the clinic is considered to provide the healthcare services and patients have contact with the clinic.
Consequences of not complying with the obligation to register and pay contributions
If you do not register and pay contributions, we can claim recourse from your enterprise. Such recourse will cover the costs associated with the administrative procedure and any compensation paid out for a claim. We will also retrospectively collect contributions for any years in which the enterprise was obliged to pay contributions, but failed to do so. Ultimately, sanctions such as fines or imprisonment can be imposed.
Both private and public work
The public sector pays contributions for all activity in the public health service. If you operate privately as well as in the public health service, you must register and pay contributions for the private component of your work.
If your enterprise receives a subsidy, the difference between the FTE percentage and the subsidy must be registered. For example, if you work full-time (100 percent) and receive a subsidy of 20 percent, this must be reported and you will have to pay 80 percent of the price for the professional group concerned.
Reimbursement from Helfo/NAV
That an enterprise receives a full or partial reimbursement from Helfo or NAV does not mean that this part of the enterprise is considered to be public.
Any enterprise that has health personnel in supervised practice will be responsible for registration and the payment of contributions. This will also apply in cases where an enterprise has health personnel working to a rota.
Time spent on supervision does not need to be registered. For example, if a physiotherapist is working full-time (100 percent) and spends 20 percent of their time supervising another physiotherapist (who also works 100 percent), 1.8 FTEs must be registered, not 2 FTEs.
Enterprises that have health personnel in supervised practice who are members of an association which has a collective agreement need not register and pay contributions to NPE for these personnel. These personnel are covered by the association’s collective agreement.
The obligations regarding registration and contributions apply regardless of any individual insurance
If you have insurance through a professional association (with the exception of associations which have a collective agreement with NPE) or if you have separate Norwegian or foreign liability insurance, this will not affect the obligation to register and pay contributions under the Patient Injury Act.
Examples of enterprises not required to register
It is the party that employs (hires) a temporary member of staff that is responsible for registering and paying contributions. Temporary staff often work in place of someone who is already registered, for which contributions have been paid. If the duties of a temporary member of staff are the same as the person being replaced by the temporary employee, it is not necessary to register again. The temporary member of staff will then already be covered.
Health personnel in administrative roles only
Enterprises that employ health personnel but do not provide healthcare are not required to pay contributions. Examples include health personnel employed by directorates, supervisory authorities, insurance companies, NAV, chief medical officers, etc. Health personnel in a purely administrative role within an enterprise which provides healthcare need not be registered or pay contributions.
If you work part-time on administrative duties and part-time providing healthcare, you will be required to register and pay full contributions.
Temporary staff agencies
Agencies that provide health personnel are not required to register with NPE. The duty to register lies with the enterprise that has health personnel in work.
Consultants on an hourly basis
It is the enterprise for which you are undertaking work that will be responsible for registering all health personnel working for the enterprise, whether employed or working on a contract basis.
Organisations and associations that only occasionally provide healthcare with low FTE percentages
Organisations and associations that only occasionally provide healthcare with low FTE percentages are not required to pay contributions. Contributions will be payable if healthcare is provided to any significant extent, e.g. in connection with major events, etc.
Healthcare during spare time
There is no obligation to register or pay contributions for healthcare provided during spare time, outside of the enterprise. We may still be liable for injuries caused during spare time even if the party responsible is not required to pay contributions.
Working as a GP only
If you only work as a GP, as a municipal employee or under an agreement with the municipality, you will come under the definition of a public health service and will not have to register your enterprise. Such enterprises are financed by joint contributions from the municipality. If you run a private enterprise in addition to the enterprise that is covered by the GP agreement, you must register the enterprise with us.