The Healthcare Services Act (HCSA) will replace the current Private Hospitals and Medical Clinics Act (PHMCA) in phases. Phases 1 and 2 were implemented on 3 January 2022 and 26 June 2023 respectively. Phase 3 will be implemented by December 2023.
Licensees must comply with ALL of the following requirements*
*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.
The HCSA 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 26 June 2023, licensees will be required to seek MOH's approval for the modes of service delivery (MOSDs) and specified services (SSes) provided. More information about the MOSDs and SSes can be found here.
Please click here to access the Act, the various Regulations under HCSA, the Licence Conditions for each Licensable Healthcare Service and the Code of Practice.
Tables 1 and 2 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 |
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^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 |
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*Nuclear Medicine Assay, Imaging and Therapy have been combined into a single LHS named Nuclear Medicine Service. Under this LHS, Nuclear Medicine Imaging has been classified as a Specified Service.
For the consolidated list of LHSes and their allowable specified services and modes of service delivery, please click here.
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A. How HCSA fees are charged
Under HCSA’s framework of Licensable Healthcare Services (LHS), and approvals for the allowable Modes of Service Delivery (MOSD) and Specified Services (SS), there are corresponding fees applicable.
Under HCSA, all fees are based on a standard 2-Year licence tenure, and the applicable regulatory fees have been adjusted to ensure that they remain commensurate with the regulatory costs of a 2-year licence. The purpose of this standardisation is to help licensees reduce the administrative complexity of managing multiple licences with different licence expiry dates.
B. Licence tenure and fees on transition from PHMCA to HCSA
Under PHMCA, 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:
C. Licence fees and MOSD fees
Your HCSA licence fees will include the approval of one MOSD under the said licence. For the MOSDs beyond the first, MOSD fees will be charged based on per-premises or conveyance basis, i.e. separate fees will apply for services provided at each premises and conveyance. MOSD fees also apply to temporary premises and remote delivery where these are allowed. However, there are exceptions which are further explained below.
D. Capacity-based Fees
However, there are licence categories that are not charged based on per premises / conveyance basis but are tiered by capacity, such as:
- 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)
- Blood Banking Service, which is tiered based on the total number of permanent premises and conveyances (i.e., sites) held by the licensee (i.e. 10 or fewer sites; more than 10 sites)
For these licence categories, licensees will only need to hold a single licence regardless of the number of vehicles in a fleet or sites.
- Example:
Table 3 lists the licence fees for each LHS under HCSA Phases 1 and 2. Fees shown are with respect to offering the service via any one allowable mode of service delivery (MOSD).
Table 3: List of Licence Fees Applicable for each Licensable Healthcare Service
Licensable Healthcare Service | Licence Fee |
1. Acute Hospital Service | - $9,900 (1,000 beds or more)
- $7,700 (less than 1,000 beds)
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2. Ambulatory Surgical Centre Service | $850 |
3. Assisted Reproduction Service | $1,900 |
4. Blood Banking Service | - $7,300 (more than 10 sites^)
- $5,500 (10 or fewer sites^)
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5. Clinical Laboratory Service | $1,016 |
6. Community Hospital Service | - $2,300 (100 beds or more)
- $1,500 (fewer than 100 beds)
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7. Cord Blood Banking Service | $1,950 |
8. Emergency Ambulance Service | - $1,300 (more than 10 vehicles)
- $1,000 (10 or fewer vehicles)
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9. Human Tissue Banking Service | $1,050 |
10. Medical Transport Service | - $900 (more than 10 vehicles)
- $800 (10 or fewer vehicles)
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11. Nuclear Medicine Service | $1,950 |
12. Outpatient Dental Service | $360 |
13. Outpatient Medical Service | $360 |
14. Outpatient Renal Dialysis Service | $850 |
15. Radiological Service | $1,016 |
^ Sites may include either permanent premises or conveyances.
E. Fee Bundles
Fee Bundles were also introduced to help licensees lower costs when licensees need to hold several HCSA licences and MOSD approvals. The available fee bundles are as below:
a. Acute Hospital Service Bundle
Acute hospital service providers will not incur any additional licence fee for the licences for Outpatient Medical Service, Clinical Laboratory Service, Radiological Service, and Ambulatory Surgical Centre Service (Table 4) when these services are provided on the same premises.
Table 4: Acute Hospital Service Bundle
LHS | Licence Fee |
Acute Hospital with the following LHSes (in any combination): - Outpatient Medical Service;
- Clinical Laboratory Service;
- Radiological Service; or/and
- Ambulatory Surgical Centre Service
| - $9,900 (1,000 beds or more)
- $7,700 (less than 1,000 beds)
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b. Ambulance Bundle
Providers offering both Emergency Ambulance Service (EAS) and Medical Transport Service (MTS) will enjoy a bundled licence fee, instead of having to pay for the respective licence fees of the EAS and MTS licences (Table 5).
Table 5: Emergency Ambulance and Medical Transport Services Bundle
LHS | Licence Fee |
- Emergency Ambulance Service; and
- Medical Transport Service
| - $1,300 (more than 10 EAS & MTS vehicles)
- $1,000 (10 or fewer EAS & MTS vehicles)
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c. Mode of Service Delivery (MOSD) Bundle
Providers offering Assisted Reproduction Service, Outpatient Medical Service, Outpatient Dental Service, and Outpatient Renal Dialysis Service will not be charged for any additional MOSD approval fee for the provision of temporary premises and/or remote provision (where applicable), if provided in conjunction with a permanent premises or conveyance (where applicable) (Table 6):
Table 6: List of MOSD combinations eligible for the MOSD Bundle for Assisted Reproduction Service, Outpatient Medical Service, Outpatient Dental Service, Outpatient Renal Dialysis Service Providers
| Combination of MOSDs | Examples | Eligibility for MOSD Bundle | Licence Fee |
(A) Outpatient Medical and Dental Services |
1 | Only 1 MOSD | - Brick-and-mortar clinic only
- Teleconsultations only (applicable only for Outpatient Medical Service providers)
- House calls only
| - | $360 |
2 | - Permanent Premises;
- Remote; &/or
- Temporary Premises
| - Brick-and-mortar clinic,
- Teleconsultations, &/or
- House calls
| Yes | $360 |
3 | - Conveyance;
- Remote; &/or
- Temporary Premises
| - Outpatient medical/dental services via a bus,
- Teleconsultations, &/or
- House calls
| Yes | $360 |
4 | - Temporary Premises; &
- Remote
| - Teleconsultations; and
- House calls
| Yes | $360 |
5 | - Permanent Premises; &
- Conveyance
| - Brick-and-mortar clinic; and
- Outpatient medical/dental services via a bus
| No | $360 + $360 = $720 |
6 | - Permanent Premises;
- Conveyance;
- Temporary Premises; &
- Remote
| - Brick-and-mortar clinic,
- Teleconsultations,
- House calls and
- A bus offering the services
| - (1), (3) & (4) will be bundled
| $360 + $360 = $720 |
(B) Assisted Reproduction Service |
1 | Permanent Premises only | | - | $1,900 |
2 | - Permanent Premises; &
- Remote
| - Brick-and-mortar clinic; and
- Peri-procedural follow-ups done remotely
| Yes | $1,900 |
(C) Outpatient Renal Dialysis Service |
1 | Only 1 MOSD | | - | $850 |
2 | - Permanent Premises;
- Remote; &
- Temporary Premises
| - Brick-and-mortar clinic,
- Peritoneal dialysis with home visit; and
- Teleconsultation incidental to renal dialysis service
| Yes | $850 |
3 | - Permanent Premises; &
- Remote
| - Brick-and-mortar clinic; and
- Teleconsultations incidental to renal dialysis service
| Yes | $850 |
4 | - Permanent Premises; &
- Temporary Premises
| - Brick-and-mortar clinic; and
- Peritoneal dialysis with home visit
| Yes | $850 |
5 | - Remote; &
- Temporary Premises
| - Teleconsultation incidental to renal dialysis service; and
- Peritoneal dialysis with home visit
| Yes | $850 |
d. Specified Services (SS) Bundle
In most cases, licensees who offer SSes will incur an SS fee that is in addition to the LHS fee indicated in Table 3 above. The SS fee is dependent on whether the SS is categorized as “simple” or “complex”. SS fees are charged as set out in the Healthcare Services (Fees) Regulations 2021. Licensable Healthcare Services where SS fees are not applicable include Clinical Laboratory Service or Radiological Service.
Providers who offer more than one simple SS will be able to enjoy a bundled fee if the simple SSes are offered under the same LHS category (Table 7). Similarly, providers who offer two complex SSes under the same LHS category will also qualify for a bundled fee (Table 8). SSes under different LHS categories will not be bundled together (Table 9).
Table 7: Application of the SS bundle for offering simple SSes within the same LHS category
Service | LHS Fee | Simple SS Fee | Total Fee |
(A) | (B) | (A) + (B) |
1 Simple SS under LHS Z | $Z | $900 | $Z + $900 |
Application of SS Fee Bundle for Simple Sses |
2 Simple Sses under LHS Z | $Z | $1,700 | $Z + $1,700 |
3 or more Simple Sses under LHS Z | $Z | $2,500 | $Z + $2,500 |
Table 8: Application of the SS Bundle for offering complex SSes within the same LHS category
Service | LHS Fee | Complex SS Fee | Total Fee |
(A) | (B) | (A) + (B) |
1 Complex SS under LHS Z | $Z | $1,900 | $Z + $1,900 |
Application of SS Fee Bundle for Complex SSes |
2 complex SSes under LHS Z | $Z | $3,700 | $Z + $3,700 |
Table 9: SS bundle does not apply to SSes that are offered across multiple LHSes
Service | LHS Fee | SS Fee | Total Licence Fee |
(A) | (B) | (A) + (B) |
SS Fee Bundle is not applied in such a scenario |
LHS Z with 1 simple SS | $Z | $900 | $Z + $900 |
LHS C with 1 simple SS | $C | $900 | $C + $900 |
Total | $(Z + 900) + $(C + 900) |
These bundles are applicable only when the services and MOSDs approved are provided (i) by the same licensee, (ii) out of the same premises, (iii) have the same end-dates for all licences, and (iv) can be inspected together. Please click here for a summary of all the LHS and SS fees applicable.
F. Standard Administrative Fees
Application 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 the above principles, 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).
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Late Fee and Amendment Fee Charges
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.
G. Impact on Licensees
While you may need to hold multiple HCSA licences and approvals, most licensees will see no change, or a reduction in their licence fees, unless you provide newly introduced licensable healthcare services (e.g. Cord Blood Banking, Human Tissue Banking, Assisted Reproduction).
To help you manage these changes, we have introduced:
- Regulatory Fee Bundles: to help you lower costs when you need to hold multiple HCSA licences and MOSD approvals.
- 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.
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.