<![CDATA[The National Health Insurance Program (JKN) in Indonesia faces serious challenges related to fraudulent practices committed by participants, healthcare facilities, medical personnel, and even the social insurance administrators themselves. The absence of a clear legal framework and a reliable mechanism for proof has led to legal uncertainty and financial losses in managing health insurance funds. In contrast, the United Kingdom, through its National Health Service (NHS), has established a comprehensive legal and institutional framework to professionally and systematically detect, investigate, and prosecute fraud. This article aims to compare the legal systems of Indonesia and the UK in handling health insurance fraud and to propose an ideal model for Indonesia. The research employs a normative juridical method with a comparative law approach. This study finds that the UK has a more robust fraud prevention and enforcement structure through bodies such as the NHS Counter Fraud Authority and Local Counter Fraud Specialists, while Indonesia still relies on internal regulations that lack legal strength. Indonesia needs to establish a professional and certified anti-fraud agency, implement a solid legal evidentiary system, impose criminal, civil, disciplinary, and administrative sanctions, ensure fair adjudication, and reform existing regulations to ensure justice and the sustainability of JKN.]]>
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