The Ministry of Health (MOH) has issued a notice of intended revocation of licence to MaNaDr Clinic Pte Ltd on 24 October 2024 for the provision of outpatient medical services across all its modes of service deliveries i.e. physical, temporary and remote. This is in view of MOH’s assessment that MaNaDr Clinic is unable to continue providing outpatient medical services in a clinically and ethically appropriate manner.
2. In addition, MOH will refer 41 doctors who provided teleconsultations at MaNaDr Clinic to the Singapore Medical Council (SMC) for inquiries into possible professional misconduct, as they have potentially breached one or more of the ethical guidelines in SMC’s Ethical Code and Ethical Guidelines (ECEG). These guidelines pertain to a doctor’s duty of care, clinical evaluation of patients, provision of telemedicine, medical records, issuance of Medical Certificates (MCs), and prescription of medicines.
Revocation of MaNaDr Clinic’s Licence
3. On 16 August 2024, MOH issued a direction to MaNaDr Clinic to stop the provision of outpatient medical services via teleconsultation until further notice. MOH has since conducted further investigations into MaNaDr Clinic’s operations and the professional practices of doctors engaged by MaNaDr Clinic to provide outpatient medical services.
4. MOH has completed its investigations. Our findings include:
(a) Short teleconsultations. A very large number of cases seen by MaNaDr Clinic doctors involved very short teleconsultations with video calls that lasted one minute or less in duration, but nevertheless concluded with the prescription of medications and issuance of MCs. Such short consultations raise concerns about the safety and quality of clinical care provided to patients, including whether the medications and MCs were prescribed and issued on sound medical grounds.
(b) Issuance of multiple MCs over a short period of time. Following these short teleconsultations, some patients were issued with multiple MCs over a few different teleconsultations within a short period of time e.g. 30 days.
(c) Questionable and poor documentation. In some instances, patient case notes contained detailed information that was not commensurate with the short duration of the teleconsultation. Conversely, in other instances, patient case notes were extremely sparse or brief, which potentially compromise the continuity of patient care.
5. Based on these findings, there is reason to believe that there is an entrenched culture of disregard for the applicable clinical and ethical standards within MaNaDr Clinic.
6. Given the above, the Director-General of Health is satisfied that MaNaDr Clinic Pte Ltd, the licensee for MaNaDr Clinic under the Healthcare Services Act 2020 (HCSA), is unable to continue providing outpatient medical services under its licence in a manner that is clinically and ethically appropriate, and intends to revoke its licence on this basis. The Director-General of Health has therefore issued a notice of intended revocation of licence to MaNaDr Clinic Pte Ltd on 24 October 2024. Upon the revocation, MaNaDr Clinic Pte Ltd will no longer be authorised to provide outpatient medical services via the following approved modes of service delivery under the business name MaNaDr Clinic:
a) At its permanent premises – the clinic located at 371 Beach Road City Gate #02-52;
b) At temporary premises (e.g. treating patients at their residences); and
c) Remote provision (i.e. providing teleconsultation services).
In accordance with HCSA, MaNaDr Clinic Pte Ltd has 14 days to make representations to MOH.
7. In addition, MOH is currently reviewing whether Dr Siaw Tung Yeng, the Principal Officer and Clinical Governance Officer of MaNaDr Clinic, has discharged his duties in these capacities satisfactorily, in assessing his suitability to continue acting in these capacities (for three other licensed outpatient medical services, as the case may be).
Professional Misconduct of Doctors
8. Based on the findings from MOH’s investigations, MOH will also be referring 41 doctors to the SMC for inquiries into alleged professional misconduct. These arise from the potential breaches described in paragraph 4, i.e. short teleconsultations, which concluded with prescription of medication and/or issuance of MCs, repeat issuance of MCs to the same patient over a short period of time, and questionable and poor documentation.
9. Of the 41, there were 13 doctors who worked as locum practitioners providing teleconsultations at MaNaDr Clinic while being employed by the public healthcare institutions (PHIs) or MOH Holdings. These doctors had breached their employment terms by undertaking external employment and conducting secondary clinical activities without the approval of their employers. Furthermore, most of these doctors provided teleconsultations while on active duty in the PHIs.
10. Five have since left the public healthcare sector. Of the remaining eight, seven have been dismissed. The remaining doctor, due to lesser severity of his actions, has been subjected to disciplinary action.
11. Doctors who practise telemedicine are reminded to abide by the SMC’s ECEG at all times. MOH views these inappropriate practices and their potential impact on patient safety very seriously and will not hesitate to take further action against doctors, including referral to SMC, for any found to have engaged in professional misconduct. MOH will also take such misconduct into consideration in assessing professional standing and suitability for any licensing matters under the HCSA or applications that may be submitted for accreditation under MOH’s healthcare financing schemes such as the Community Health Assist Scheme, MediSave and MediShield Life.
12. MOH will continue to monitor and audit other licensed providers of outpatient medical services who provide teleconsultation services, either through the MaNaDr platform or other telemedicine platforms, to ensure that teleconsultations are conducted in compliance with regulatory requirements. MOH will take regulatory actions against the licensees and/or key appointment holders, should non-compliances be found.
13. All licensees granted approval under HCSA to provide outpatient medical services through remote provision are reminded to comply with their licensing obligations under the HCSA, the applicable regulations, and conditions of their licences and licensing-related approvals (including the Licence Conditions for Remote Provision of Outpatient Medical Services).