Licensing of Telemedicine Services under HCSA
Who needs to hold an HCSA license
Service providers, whether organizations or individuals, who intend to provide Licensable Healthcare Services (LHS) must obtain the relevant HCSA license before providing the above services. Please click here for a list of descriptions of the various LHSs.
What is licensed: Currently, remote consultations led directly by a doctor are licensed under the Health Care Services Act (HCSA). This refers to consultations via apps, video calls, phone calls or text messages without visiting a doctor in person.
Licensable Healthcare Services, Mode of Service Deliveries and Specified Services
A licensed provider may be an independent physician who provides teleconsultation themselves, or an organization that employs or engages physicians to provide teleconsultation as part of the organization's services. Under the HCSA, such providers (whether individual physicians, or organizations) will be required to hold an Outpatient Medical Service license and be approved for a remote Mode of Service Delivery (MOSD).
If a doctor offers services in his/her own professional and personal capacity, such as providing teleconsultations, then the doctor will be required to obtain his/her own licence under HCSA.
1. Licensable Healthcare Services
Under the HCSA, healthcare providers need to apply for approval to hold a license for the licensable healthcare services (LHS) they provide, as well as an appropriate mode of service delivery (MOSD) for the LHS.
2. Mode of Service Delivery
[Telemedicine] / [ Remote operations via virtual platforms or apps, such as virtual GP consultations]
The licensee must seek approval from the MOH for the MOSD used to deliver the LHS.
Specified Services
Collaborate Prescribing Service
Licensee
Can be either Corporation / Individual
Responsible and accountable for overall compliance with HCSA
Appoints suitable individuals for other key roles
Detailed Responsibilities of Key Personnel
Under HCSA a Key Appointment Holder (KAH), a Principal Officer (PO) and a Clinical Governance Officer (CGO) must be appointed, in addition to the licensee. Click here for more details on the roles and responsibilities of these key personnel.
1. KEY APPOINTMENT HOLDER (KAH)
Must be Individual(s)
Responsible for strategic leadership and general management oversight
For relevant KAH requirements according to business structure, refer to the Code of Practice at HCSA.sg (go.gov.sg/hcsa-resources).
2. PRINCIPAL OFFICER (PO)
Must be an Individual
Assists the licensee in ensuring overall operational compliance with HCSA
Oversees day-to-day management of the services - similar to "Manager" role under PHMCA
3. CLINICAL GOVERNANCE OFFICER (CGO)
Must be an Individual & Clinical and Technical expert
Assist the licensee in clinical governance and technical oversight of complex services
Clinical qualification and experience requirements are detailed in the respective Service Regulations
Requirements to Become a Clinical Governance Officer
An individual must be in good standing and meet all of the following criteria to be appointed as a Clinical Governance Officer (CGO).
1. For an individual to meet the requirements to become a CGO, he or she must:
a. Reside in Singapore while serving as CGO
b. Be a formally registered doctor with the Singapore Medical Council (SMC) and hold a valid practicing certificate
c. Meet one of the following conditions:
i. Registered as a specialist in any branch of medicine under the Medical Registration Act, or
ii. Registered as a family doctor in the Register of Family Physicians in accordance with the Medical Registration Act, or
iii. Have practised as a full-time doctor continuously for at least 5 years or a total of at least 5 years in a period of 10 consecutive years in either
an equivalent medical institutions under the Private Hospitals and Medical Clinics Act
d. [Tele-MOSD / [Remote MOSD] only] Complete the telemedicine e- training course specified by the Ministry of Health.
2. To fulfil the suitability qualifications as a CGO, an individual must not:
a. Have any of the following convictions unless the conviction has spent:
i. Criminal conduct involving fraud or dishonesty;
ii. Contravention of any offense under the HCSA, PHMCA or any applicable act listed in Appendix A of the Code of Practice;
iii. Criminal acts specified in Third Schedule of the Registration of Criminals Act; or
iv. Any other criminal conduct involving abuse, ill treatment, assault or physical violence
b. Face pending charges for an offense under 2a(iv)
c. Be an undischarged bankrupt
d. Have had the of his or her healthcare professional registration with the Ministry of Health canceled, revoked or suspended
e. Have served as a director or manager of a healthcare provider whose registration or license has been suspended, canceled or revoked
f. Have had eligibility or approval to participate in a public program administered by the Ministry of Health revoked or suspended
g. Lack capacity within the meaning of the Mental Capacity Act 2008.
For further details on the suitability requirements for a Key Office Holder please see the Code of Practice.
How to Apply
Steps to Apply for a New HCSA License.
For providers who intend to provide licensable healthcare services, you will need to obtain the relevant license before you can provide services in Singapore.
To apply for an HCSA license you need to:
1. Log in to the Healthcare Application and Licensing Portal (HALP) using SingPass or CorpPass.
Select available LHSes, SSes and MOSDs types
Enter licensing details and other service-related information
Attach supporting documents
Submit the application and pay the relevant license fees as required
Complete the self-assessment checklist
2. Receive inspection date confirmation.
Ensure documents are ready for inspection (e.g. Pressure Vessel Registration from MOM, Irradiation Equipment License from NEA)
The inspector may contact you after the inspection for further clarifications
3. Once all licensing requirements are met, receive email notification of the status of your application.
4. View the e-licence on HALP upon approval.
5. Update on HALP if there are any changes to your licence.
Licence Fee
Under the HCSA, all fees will:
Be based on standard 2-year license term;
Be generally on a per service and per venue/transportation basis; and [per-service and per-premises / conveyance basis]
Include standard management fees. [Standard Administrative Fees]
Please see the table below for more details on the exact fee that applies.
List | Licence Fee |
Stand-alone Mode of Service Delivery (MOSD):
| $360 |
Please refer to HCSA.sg for more details on HCSA licensing, including specific regulatory requirements for providing TM services. telemedicine (TM)
For the most up-to-date and comprehensive information, it's always recommended to refer to the official source: the Ministry of Health, Singapore's website on Licensing of Telemedicine Services under HCSA https://www.moh.gov.sg/licensing-and-regulation/telemedicine.
How Bestar can Help
Bestar can assist with understanding the licensing process for telemedicine services under the Healthcare Services Act (HCSA) in Singapore. Here's how we are able to help:
Understanding License Requirements: We can clarify which license is needed, whether it's an Outpatient Medical Service or Outpatient Dental Service license with approval for the remote Mode of Service Delivery (MOSD) https://www.moh.gov.sg/covid-19/telemedicine-tele-art.
Knowing Who Needs a License: We can advise if you're an independent doctor or dentist or an organization employing them, as both require a license for teleconsultations https://www.moh.gov.sg/covid-19/telemedicine-tele-art.
Following HCSA Regulations: We provide guidance on the specific regulatory requirements for offering telemedicine services under the HCSA https://www.moh.gov.sg/covid-19/telemedicine-tele-art.
Contact us to inquire about our specific offerings related to telemedicine licensing.
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