LICENSING TELEMEDICINE SERVICE UNDER HCSA
What is licensable: Currently, only direct doctor and/or dentist-led teleconsultations are licensable under the Healthcare Services Act (HCSA), as MOH adopts a risk-based regulatory approach to healthcare services. This refers to consultations with a doctor or dentist without seeing them in-person, and via ways like apps, video calls, phone calls, or texts. Other forms of telemedicine (TM) services such as telecollaboration and telesupport for administrative purposes (e.g. appointment booking) will not be licensed under HCSA.
Who is licensed: Licensable providers may be independent doctors/dentists offering teleconsultations themselves, OR organisations who hire or engage doctors and/or dentists to provide teleconsultations as part of the organisation’s services. Under HCSA, such providers (whether individual doctors or dentists, or organisations) will be required to hold an Outpatient Medical Service or Outpatient Dental Service licence with approval for the remote mode of service delivery (MOSD). Please be reminded that providing telemedicine services without the relevant licence and MOSD approval constitutes a breach under Section 8 of HCSA.
Who will not be licensed: TM platforms and applications’ providers providing software as a service to doctors and dentists will not be licensed under the HCSA. That is, those who do not provide direct medical care, and only offer the technology support for TM (e.g. platforms offering software-as-a-service for teleconsultation, directory listings, payment solutions).
Please refer to HCSA.sg for more details on licensing under HCSA, including the specific regulatory requirements for offering TM services.
TRANSITION OF VOLUNTARY LISTING OF DIRECT TELEMEDICINE SERVICE PROVIDERS TO HCSA LICENSING
Note. Please refer to go.gov.sg/telemedicineproviders to seek medical attention if you are a COVID-19 patient on HRP.
In 2018, the Licensing Experimentation and Adaptation Programme (LEAP) Regulatory Sandbox for TM was set up to better understand the risks of direct TM service providers. With the increasing number of TM providers, MOH had listed direct TM service providers in 2021, as a transition approach prior to licensing.
With the licensing of TM providers under the Healthcare Services Act (HCSA) from 26 June 2023, the Voluntary Listing has been discontinued and licensees’ information providing TM services (e.g. operating hours, contact details) are now listed on HealthHub.