Preventing Death After Medical Error: A Comparative Health Policy Analysis of Patient Safety, Accountability, and Institutional Learning in Indonesia and England

Abstract

Medical error became a health-policy problem when institutional systems failed to detect risk, establish a credible account of harm, or change unsafe conditions. This article compared how Indonesia and England organised reporting, investigation, disclosure, accountability, and learning when patient-safety incidents could result in death. A qualitative comparative health policy analysis was conducted using legislation, regulatory instruments, national patient-safety frameworks, investigation guidance, reporting arrangements, and peer-reviewed research. Indonesia had a substantial regulatory and hospital-governance basis for patient safety, but learning remained dependent on uneven local reporting capacity and hospital-level review. England had a more differentiated architecture through PSIRF, LFPSE, statutory candour, regulation, and independent national investigation, although investigation quality, family involvement, and implementation of recommendations remained variable. The comparison developed accountability-learning coupling as an institutional mechanism in which learning processes remained sufficiently separate to support candid evidence, while verified findings could still move into proportionate professional, managerial, or regulatory accountability. For Indonesia, the principal reform need was stronger linkage between local incidents, national learning, family-facing explanation, and verified implementation of corrective action.