01 Jun 2010
- RESIDENCY/EMPLOYMENT STATUS
- Is it mandatory to check work permit/passes of all women seeking TOP?
The residency/travel documents and/or work permit/pass should be verified prior to performing the TOP and a copy of the documents should be kept in the medical records for verification.
- Can TOP be performed for a woman who is unable to produce any travel documents and/or residency status documents?
No. The authorised TOP doctor has to ensure that the woman requesting TOP complies with the residency requirements stipulated under the TOP Act by verifying the relevant documents. Under the Termination of Pregnancy Act, an authorised medical practitioner shall not carry out treatment for the termination of pregnancy on any pregnant woman other than:
- a citizen of Singapore or the wife of a citizen of Singapore;
- is the holder, or is the wife of a holder, of a work pass issued
under the Employment of Foreign Manpower Act; or
- a person who has been resident in Singapore for at least 4 months immediately preceding the date of TOP.
- Can I perform TOP for a tourist who has been in Singapore for the past one month?
No. The exception would be only if the TOP is immediately necessary to save the life of the pregnant woman, which shall be supported by documentary evidence.
- Are work permit holders required to be resident in Singapore for four months to be eligible to undergo TOP?
No. The minimum residency requirement of four months stay in Singapore prior to the TOP does not apply to holders or the wife of holders of permits/passes issued under the Employment of Foreign Manpower Act.
- Are student pass holders eligible to undergo TOP without the minimum four-month residency requirement?
No. Holders of passes issued under the Immigration Act such as the student pass and long term visit pass are required to be resident in Singapore for four months prior to the TOP.
- DURATION OF PREGNANCY
- Can TOP be performed for a patient who is already 24 weeks pregnant with an abnormal foetus?
Under the TOP Act, no treatment for terminating a pregnancy of more than 24 weeks can be carried out unless the treatment is immediately necessary to save the life or to prevent grave permanent injury to the physical or mental health of the pregnant woman. There shall be documentary evidence to support that the treatment was immediately necessary.
- CONSENT
- Can a patient’s husband request to have TOP performed on his wife and sign the consent form on behalf of his wife?
No. The termination of a pregnancy must be carried out only at the request of the pregnant woman and with her consent.
- Can a mentally handicapped pregnant woman give her consent for the TOP?
The authorised TOP doctor should abide by the assessment of the psychiatrist on whether the pregnant woman is mentally capable of making her own decisions. If the pregnant woman is not capable of making her own decisions, legal advice should be sought for compliance with the Mental Capacity Act.
- TOP FOR GIRLS AGED LESS THAN 16 YEARS
- Can TOP be performed for a girl aged less than 16 years?
Yes. However, it is mandatory under Regulation 5 of the TOP Regulations to refer an unmarried girl below 16 years of age for pre-abortion counselling at the Health Promotion Board Counselling Centre when she seeks TOP. The TOP must not be carried out if the girl is not able to produce the Certificate of Attendance (COA) issued to her by Health Promotion Board Counselling Centre.
- Can the doctor assure the girl aged less than 16 yrs that information on the TOP would be kept confidential?
Yes. Under Regulation 12(2) of the TOP Regulations, no fact or information relating to treatment to terminate a pregnancy shall be given to any person for any purpose unless the patient has expressly consented to the disclosure.
- Is it required to refer a married girl aged less than 16 years of age to HPB for pre-abortion counselling?
No. However, the married girl should be provided the pre-abortion counselling that is provided to other women.
- APPROVED TOP INSTITUTION
- How do I apply for my clinic to be an approved institution to carry out TOP
if you are applying for a new medical clinic licence to provide TOP services, you may apply through the MOH website via electronic licensing application at https://www.moh-ela.gov.sg/ela/. If you wish to add on TOP service to an existing medical clinic licence, please call Tel: 63251170 or email moh_ela_info@moh.gov.sg for a userid and password.
- Do I need to submit Form I?
Yes. It has to be submitted through the electronic licensing application at https://www.moh-ela.gov.sg/ela/.
- How long does it take for my clinic to be approved to carry out TOP?
MOH needs to inspect the facilities for compliance with the TOP Act/Regulations and Guidelines before approval could be provided. It takes about 2 weeks from the day of inspection to issue of the approval for TOP if the clinic is found to be fully compliant with the requirements under the TOP Act/Regulations and its Guidelines during the inspection.
- What is the implication of the number of TOP done in a clinic on the subsequent renewal of the approved TOP institution status?
There is no implication for renewal of the approval based on the number of TOP carried out in an approved TOP institution as long as the institution is able to comply with the requirements under the TOP Act.
- APPROVED TOP DOCTOR
- I have recently qualified as a specialist in Obstetrics and Gynaecology. Can I start performing TOP in my licensed medical clinic?
Under Regulation 3 of the TOP Regulations, you have to apply to the Ministry to be an authorized doctor to perform TOP. You have to write in to us with your relevant qualifications. Please note that if your clinic is not an approved institution to carry out TOP, you have to apply for the clinic to be an approved institution before you can proceed to perform TOP in your clinic.
- I am an authorized TOP doctor. Can I perform TOP in other
medical clinics which are approved institutions to carry out TOP?
No. Authorised doctors are allowed to perform TOP in only one approved medical clinic.
- Do I need to cancel the approval to provide TOP in one medical clinic before applying to perform TOP in another medical clinic?
Yes. You will need to write to the Ministry of your intention to cancel the approved TOP status of your clinic and put in a new application via eLA for approval to provide TOP in another clinic.
- I am an authorized TOP doctor performing TOP in my own clinic. Can I perform TOP in a private ambulatory surgery centre?
No. Ambulatory surgery centres are also licensed as medical clinics. Authorised doctors are allowed to perform TOP in only one approved medical clinic.
- I am an authorized TOP doctor performing TOP in my own clinic. Can I perform TOP in approved hospitals?
Yes. If the doctor is authorized to perform TOP under the TOP Act and is credentialed by the hospital/s to perform TOP, the doctor may perform TOP in such hospital/s.
- PERSONNEL
- What does trained nurse refer to?
Trained nurse refers to either a registered nurse or an enrolled nurse.
- My TOP counsellor has resigned recently. Can I provide TOP counselling for my patients?
Under Regulation 4, every approved institution shall have amongst its personnel at least one doctor or nurse who have undergone the abortion counselling skills training course. Abortion counselling may be provided by the approved TOP doctor if he/she has undergone the abortion counselling skills training course. If the trained counsellor leaves employment, the approved institution is required to inform the Ministry of Health within 2 weeks.
- COUNSELLING FACILITIES
- What are the facilities required to provide abortion counselling?
Every approved institution shall provide the following facilities for counselling and such facilities shall, where applicable, be in proper working condition:
- Visual Display Unit (eg television, flat panel monitor etc)
- video cassette recorder / VCD player
- video tapes / VCD on abortion produced by Health Promotion Board
- pamphlets produced by Health Promotion Board
- Where can I obtain educational materials for TOP counselling?
Approved TOP doctors/institutions may request TOP educational materials from HPB by providing the name and address of the clinic (Email: hpb-hic@hpb.gov.sg Tel: 64353954 Fax: 63361277).
- When is the annual return of Form V (Return of personnel & facilities) required to be submitted?
The date for annual return of Form V is 1st June of every year.
- PRE-ABORTION COUNSELLING
- Is it mandatory to provide pre-abortion counselling to all women seeking abortion?
Pre-abortion counselling must be provided to a pregnant woman, regardless of her marital status, who:
- is a Singapore citizen or permanent resident;
- has passed the primary school leaving examination (PSLE);
- has at least some secondary education, and
- has less than three children.
- Do I have to provide pre-abortion counselling for women diagnosed with foetal abnormality?
The pre-abortion counselling should be modified to suit the needs of the pregnant woman diagnosed with an abnormal foetus.
- Can I proceed to perform TOP on my patient if she refuses to receive counselling before the TOP procedure?
Under Regulation 5 of the TOP Regulations, it is mandatory for all women who fulfill the criteria in 9.1 to receive counselling before the TOP procedure.
- Can I proceed to perform TOP on my patient after she has been counselled and if she requests to have the procedure done the next day as she has to go overseas urgently?
Under Regulation 6 of the TOP Regulations, TOP can only be carried out at least 48 hours after the pre-abortion counselling for those who require mandatory pre-abortion counselling.
- Can I perform TOP immediately if the patient claims that she had undergone pre-abortion counselling at another clinic?
The TOP may be performed only if the woman is able to provide documentary evidence from the other clinic that she had undergone preabortion counselling and 48 hours have lapsed since the counselling.
- Do we have to wait 48 hours after pre-abortion counselling to perform the TOP?
Yes.
- POST-ABORTION COUNSELLING
- Do I have to perform post-abortion counselling to all my patients?
Yes. However, the counsellor has the flexibility to conduct the post-abortion counselling at any time during the admission for abortion, either before or after the procedure. The actual timing can be determined by the doctor, based on his assessment of the patient, her condition and type of anaesthesia or sedation that she would be given.
- Do I have to provide post-abortion counselling for women who have undergone sterilisation following abortion?
Women who have undergone sterilisation following abortion need not go through the standard post-abortion counselling but should be provided other appropriate counselling based on needs.
- Must pre- & post-abortion counselling be provided by the same counsellor?
No. The institution has the flexibility to conduct the pre- & post-counselling by different counsellors.
- TOP RETURNS
- Do we still need to submit Form VI if the patient never reported for follow up or went elsewhere for the TOP or decided to keep the pregnancy after pre-abortion counselling has been provided?
Yes. Form VI should be completed and submitted electronically within 30 days of the pre-termination of pregnancy counselling if no treatment to terminate pregnancy was subsequently carried out.
- Do we still have to fill up Form VI if TOP has been performed after 24 weeks to save the life of the pregnant woman?
Yes.
- Can I file the TOP returns of my patients performed by me in an approved TOP hospital as TOP performed in my approved TOP clinic?
No. The TOP returns should be filed under the name of the institution in which the TOP procedure was performed.
- Do I need to file my TOP returns immediately after TOP is performed on my patients?
Under Regulation 9 of the TOP Regulations, a report on the request for treatment to terminate a pregnancy shall be made to the Director of Medical Services by the authorised medical practitioner within 30 days of the posttermination of pregnancy counselling if treatment to terminate pregnancy is carried out on a pregnant woman.
- Do we still need to keep a hard copy after submitting TOP returns online?
No. However, you should document the generated account number after the successful submission of the report (Form VI) electronically.
- Do we need to fill in the women’s occupation, number of children, live birth and adoption?
Yes.
- What should be done if clinic has submitted Form VI for successful pre-abortion counselling, but patient returns 2 weeks later to have TOP?
You will need to submit a new Report on request for treatment to terminate pregnancy (Form VI).
- TOP REGISTER
- Can I maintain an electronic TOP register for the TOP performed in my clinic?
Yes. However, the electronic TOP register shall be used solely for recording particulars of all treatments to terminate pregnancy carried out in the institution and such register shall contain at least the following particulars:
- name of operating theatre
- name of authorised medical practitioner who carried out the treatment
- name of patient as indicated in her identity card or passport
- identity card or passport number of patient
- date of operation; and
- method of termination of pregnancy.
- Can we record the TOPs performed in various operating theatres in the hospital electronically in a single register?
Yes. Hospitals may maintain a single electronic register to record the TOPs performed in multiple locations within the hospital. However, the hospitals must be able to retrieve any information required on TOP from the electronic register at any time.
- TOP ACT, REGULATIONS AND GUIDELINES
- Where can I find the TOP Act, Regulations and Guidelines?
A copy of the TOP Act can be downloaded at http://agcvldb.agc.gov.sg/html/homepage.html and the TOP Guidelines can be downloaded at https://www.mohela.
gov.sg/ela/docroot/html/TOP_Guidelines_updated%20Apr%202004.pdf
A copy of the TOP Regulations may be purchased from Singapore National Printers.
- CONTACT MOH
- How can we contact MOH on queries related to TOP issues?
For enquiry on TOP issues, you may write to the Licensing, Inspection & Audit Branch, Regulatory Compliance & Enforcement Division, Ministry of Health, 16 College Road, Singapore(169854) or email at: moh_ela_info@moh.gov.sg. You may also wish to contact our administrative staff at Tel: 63251170 or Fax: 63252600.
The full document can be downloaded below:
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