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Getting Ready for the HCSA

The Healthcare Services Act (HCSA) will replace the current Private Hospitals and Medical Clinics Act (PHMCA) in phases. Phase 1 was implemented in January 2022, and Phase 2 and 3 will be implemented in June and Dec 2023 respectively.

Overview of Requirements Applicable to HCSA Licensees

Licensees must comply with ALL of the following requirements*

Overview of HCSA Req to Comply Diagram_caa18Mar23
*FAQs and guidance carry illustrations of good practices to help licensees interpret and meet the requirements in the Regulations and LCs; and these are not enforceable.

Over the past two years, MOH engaged extensively with various stakeholders and noted several areas of enhancements for the regulatory framework.

On 6 March 2023, Parliament approved the amendments to HCSA  to ensure patients 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.

The HCSA Amendments (2023) will introduce specified services and non-premises based modes of service delivery (e.g. virtual medical consultations, home medical care) for various licensable healthcare services. From June 2023, licensees will be required to seek approval for the modes of service delivery (MOSDs) and specified services (SSes) provided. More information about the MOSDs and SSes can be found here.

To learn more about the HCSA and its amendments, please click here.

To support the implementation of the HCSA Amendments, MOH will also be amending the General Regulations prior to Phase 2 implementation. The amended General Regulations will be shared with all licensees and uploaded on once finalised. 

Tables 1 to 3 below lists the respective specified services and the mode of service delivery allowable for each licensable healthcare service (LHS). Click on the respective links to view them.

Table 1: Allowable SSes and MOSDs for HCSA Phase 1 LHSes

Clinical Support Services

*As Nuclear Medicine Imaging and Nuclear Medicine Assay services will be combined into a single LHS named Nuclear Medicine Service in HCSA Phase 2, please click on “Nuclear Medicine” under Table 2 for the list of its allowable specified services and mode of service delivery.

^For Clinical Laboratory Service and Radiological Service, the specified services correspond to the laboratory disciplines and specified tests, and various imaging modalities.

Table 2: Allowable SSes and MOSDs for HCSA Phase 2 LHSes

Inpatient Services

Outpatient Services

Clinical Support Services

For the consolidated list of LHSes and their allowable specified services and modes of service delivery, please click here.

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Healthcare Application & Licensing Portal (HALP)

The Healthcare Application & Licensing Portal (HALP) is the licensing system that will replace the current e-Licensing (eLIS) system, for all HCSA licence applications and renewals. Access HALP at to submit HCSA licence applications and manage your HCSA licences. 

Phase 1 HCSA licensees may click here to download HALP training manual.

Licensees will be updated when the training guide for Phases 2 and 3 are available.

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Licence Fees (applicable to Phase 1 Licensees only)

A. How HCSA licence fees are charged

Under HCSA, all licence fees will:

(i) Be based on a Standard 2-Year Licence Tenure.

  • The purpose of this standardisation is to help licensees reduce the administrative complexity of managing multiple licences with different licence expiry dates.
  • Licence fees have been adjusted to ensure that they remain commensurate with the regulatory costs of a 2-year licence.

Under PHMCA today, Medical Clinic and Laboratory licensees could be eligible for 5-year licences. We have adjusted the fees for these licence categories to be based on a 2-year tenure under HCSA. However, licensees whose remaining PHMCA licence tenure exceeds 2 years at the time of transition to HCSA, will have their full remaining PHMCA licence tenure ported over to HCSA.

  • Example:

(ii) Be based on a per-service and per-premises or conveyance basis.

  • Licence fees will be charged based on per-service and per-premises or conveyance basis, i.e. separate fees will apply for each service provided at each premises and conveyance that the service is offered out of.

  • Example:

  • However, there are a few licence categories that are not charged based on per premises / conveyance basis but are tiered by capacity, such as:
    • Phase 1: Emergency Ambulance Services and Medical Transport Services, which are tiered by the number of vehicles (i.e. 10 or fewer vehicles; more than 10 vehicles)
  • For these licence categories, licensees will only need to hold a single licence regardless of the number of vehicles in a fleet.
    • Example:

(iii) Include Standard Administrative Fees

  • All fees are inclusive of a non-refundable application fee of $100 per service licence which will be retained in the event an application is withdrawn or rejected.

Combining (i), (ii) and (iii), this is how the HCSA licensing fees would work:

A licensee who provides Clinical Laboratory and Radiological Service at Site A will pay $1,016 for a Clinical Laboratory licence and $1,016 for a Radiological Service licence (i.e. total of $2,032).

  • Both the Clinical Laboratory and Radiological Service licences held for Site A will be valid for 2 years.
  • Each licence fee includes a non-refundable application fee of $100.
    • Should the licensee withdraw their application before the start of the licence, they will be refunded $916 for the Clinical Laboratory licence and $916 for the Radiological Service licence. $200 will be retained as the non-refundable application fee (i.e. $100 for each licence).

Please also note that in addition to the licensing fees described above, the fees chargeable for late renewals and amendments are similar to what is currently charged under PHMCA, and will continue to apply:

  • Renewal applications which are received less than 2 months before the licence expiry, will be charged a late fee equivalent to 20% of their full licence fees.
  • Over the 2-year tenure of a licence, if there are changes to the licence that require an amendment of the licence, a $100 administrative fee will be charged.

B. Impact on Licensees

While you may need to hold multiple HCSA licences, most licensees will see no change, or a reduction in their licence fees, unless you provide new licensable healthcare services (e.g. Cord Blood Banking, Human Tissue Banking, Assisted Reproduction)

  • To help you manage these changes, we have introduced:
    • Licence Fee Bundles: to help you lower costs when you need to hold multiple HCSA licences.
    • Gradual Fee Increase Mechanism: to spread the increase in fees by gradually increasing fees over three renewal cycles, for those who meet the eligibility conditions.

Learn more about these below.

C. Licence Fee Bundles

  • Licence Fee Bundles help you to lower costs when you need to hold several HCSA licences. These bundles are for complementary services that are provided by the same licenseeout of the same premises, have the same end-dates for all licences, and can be inspected together. Further details of any Licence Fee Bundles will be updated at a later date.

D. Gradual Fee Increase (GFI) Mechanism

  • The GFI is a mechanism put in place to help mitigate the impact of an increase in licensing fees on licensees, when transiting from PHMCA to HCSA, by gradually increasing fees over three renewal cycles, for those who meet the eligibility conditions.
  • The GFI will be applied when you make a licence renewal/application on the new IT system, within 1 year of the service being rolled out under HCSA.

Click here to see which HCSA Phase(s) your service(s) are in.