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Public Consultation On Proposed Amendments to the Healthcare Services Act

         The Ministry of Health (MOH) is inviting views and feedback on the proposed amendments to the Healthcare Services Act (HCSA) to strengthen safeguards for patient safety and welfare. The HCSA amendments are targeted for implementation in June 2023.

2.       HCSA was enacted in 2020 to replace the Private Hospitals and Medical Clinics Act (PHMCA) to better safeguard patient safety and wellbeing in the changing healthcare environment, while enabling the development of new and innovative healthcare services. The Act is being implemented progressively in three phases, which started in January 2022 and will be completed in end-2023 when the PHMCA will be repealed [1].

3.              Over the past two years, we have engaged extensively with various stakeholders and noted several areas of enhancements for the regulatory framework. Under the proposed amendments, patients will benefit from the delivery of healthcare services by licensees under a robust regulatory regime, and from greater clarity and transparency in healthcare services advertising and modes of service delivery.

4.             MOH proposes the following enhancements to HCSA, which will enable patients to benefit from a robust regulatory regime governing healthcare services delivered through different modes, and to have greater clarity and transparency in healthcare services advertising.

1)    Advertising of healthcare services not licensed under HCSA

·       Non-HCSA licensees cannot claim to treat medical conditions or diseases when advertising healthcare services.

·       Non-registered healthcare professionals who use the title of “Dr” in their advertisement of healthcare services must make clear to the public what their qualifications and credentials are, so that the public are not misled that the “Dr” is one associated with a general medical practice (e.g. with a MBBS Degree).

2)    Use of specialty names in business names

·       HCSA licensees are not allowed to use terms associated with specialties in their business names if there is no such specialist employed by them. e.g. a clinic cannot be called a “Neurology Clinic” if there is no neurologist working in the clinic.

3)    Regulation of different modes of healthcare service delivery

·       Different modes of service delivery will be introduced for each healthcare service (as appropriate to the service) so that the public is aware of the modes of service delivery they can access. e.g. a medical clinic can choose “Permanent Premises” for its clinic service delivered at its brick and mortar physical premises, “Temporary Premises” for providing home visits or community site screenings, and “Remote” for teleconsultations, if it wishes to provide those modes of services.

4)    Safeguarding the provision of healthcare services by introducing an approval regime for the delivery of specified services (e.g. imaging modalities under the Radiological Service) and the appointment of clinical governance officers.

5)    Refining the scope of employee background screening according to the degree of risk to patients’ safety and welfare.

6)    Allowing MOH to take immediate action to address urgent patient safety issues by removing the 14-day notice prior to modification of licence conditions for groups of licensees in such special circumstances, e.g. requiring licensees to implement screening requirements for patients and caregivers to mitigate the spread of COVID-19.

5.             In particular, MOH is seeking views from a) the general public, b) licensees who have already come onboard HCSA in Phase 1, and c) healthcare providers who may take up HCSA licences in the future. The feedback gathered from the public consultation will better inform the implementation of HCSA in subsequent phases.

6.             For licensees who are coming onboard HCSA in Phase 2, details on specific HCSA requirements will be provided separately at the respective service regulation consultations in the next few months.

7.             Everyone has a part to play to improve and safeguard patient safety and welfare. The amendments are targeted for implementation in June 2023.  From 12 October to 11 November 2022, members of the public are invited to visit to provide their feedback on the proposed changes to HCSA.


12 OCTOBER 2022

[1] HCSA has been implemented on 3 January 2022 for clinical support services such as clinical laboratory and blood banking, emergency ambulance and medical transport services, General Regulations and Advertisement Regulations. In Phase 2 of implementation, hospitals, ambulatory care services and some specialised services like assisted reproduction will transit to HCSA. Phase 3 will see the implementation of HCSA for long-term care services and other specialised and new services.

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