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In brief

Following the implementation of the Healthcare Services Act in phases since January 2020, the Ministry of Health (MOH) announced the first and second reading of the Healthcare Services (Amendment) Bill (Bill) on 6 February 2023 and 6 March 2023 respectively. If passed, most of the amendments as set out in the Bill will be implemented together with the second phase of implementation of the Healthcare Services Act (HCSA) in mid-2023. 

In more detail


The first phase of the HCSA came into effect in January 2022, with the second and third phases slated to come into effect in June 2023 and the end of 2023 respectively. 

The MOH has continued to refine the HCSA, proposing amendments to the HCSA in October 2022. Our previous alert discussing these proposed amendments may be found here

After taking into consideration feedback from stakeholders, the MOH has released further details on the proposed amendments. The main objectives of these amendments are to enable the MOH to be nimbler in responding to the evolving healthcare landscape, to enable premises-neutral care to be delivered across its healthcare settings and to strengthen governance to safeguard patient safety and welfare. 

The MOH’s proposed changes to the HCSA can be categorized into two main themes: (i) future-proofing HCSA for regulatory agility; and (ii) stronger governance to protect patient safety and welfare. Some key proposed changes are set out below. 

Future-proofing HCSA for regulatory agility

First, the amendments will introduce regulation of four primary modes of service delivery: (i) permanent premises; (ii) temporary premises; (iii) conveyances; and (iv) remote provision, where licensees must obtain approval to provide licensable healthcare services by any of these four modes.

The clearer regulatory framework seeks to give service providers confidence to continue to provide and expand home care services. Bringing medical services closer to the community and into homes will enhance convenience for both patients and their caregivers, reducing caregiver burden.

Second, the MOH will also remove the 14-day notice period for any modification of license conditions where there is immediate or imminent harm to patient safety or public health. This would allow the MOH to swiftly implement new healthcare protocols to protect public health under exceptional circumstances. 

Stronger governance to protect patient safety and welfare

There have also been several amendments geared at protecting patient safety and welfare. 

First, licensees will be required to obtain approval before providing a specified service, which would generally apply to services that involve more complex or higher risk procedures, such as liposuction, endoscopy, radiation oncology services, etc. 
Second, licensees will be required to seek approval from the MOH before appointing a clinical governance officer (CGO). This replaces the existing obligation for licensees to merely notify the MOH when it appoints a CGO. This would allow the MOH to ensure upfront that a competent individual is appointed to better safeguard patient safety. 

Third, the robustness of employee background screening has also been enhanced by the MOH, where the MOH will have flexibility to vary the scope of restrictions of employees/engaged individuals in different healthcare settings based on the anticipated risk of patient harm. For example, certain licensees may be prohibited from employing any individual who has committed egregious crimes without approval from the MOH. 

Fourth, advertising restrictions will be implemented to ensure that consumers are not misinformed of a healthcare provider’s services. In particular, licensees will be prohibited from using a specialty name in their business names or logos if there is no practitioner practising in such specialty. For example, a clinic may not be called “The Brain Clinic” if there is no neurologist practising in that clinic. Additionally, to avoid public misperception, licensees may not use the terms “Singapore” or “National” in English or other languages (unless such terms are used in existing business names, in which case the existing business names may be retained). 

Finally, the regulatory framework for healthcare service advertising will be streamlined. Some advertising requirements for non-licensable healthcare services will be regulated under the HCSA. For example, non-HCSA licensees will be prohibited from claiming to treat medical conditions or diseases. 


Andy Leck is the head of the Intellectual Property and Technology (IPTech) Practice Group and a member of the Dispute Resolution Practice Group in Singapore. He is a core member of Baker McKenzie's regional IP practice and also leads the Myanmar IP Practice Group. Andy is recognised by reputable global industry and legal publications as a leader in his field. He was named on "The A-List: Singapore's Top 100 lawyers" by Asia Business Law Journal 2018. In addition, Chambers Asia Pacific notes that Andy is "a well-known IP practitioner who is highlighted for his record of handling major trade mark litigation, as well as commercial exploitation of IP rights in the media and technology sectors. He's been in the industry for a long time and has always been held in high regard. He is known to be very fair and is someone you would like to be in the trenches with you during negotiations." Furthermore, Asian Legal Business acknowledges Andy as a leading practitioner in his field and notes that he “always gives good, quick advice, [is] client-focused and has strong technical knowledge for his areas of practice.” Andy was appointed by the Intellectual Property Office of Singapore (IPOS) as an IP Adjudicator to hear disputes at IPOS for a two-year term from April 2021. He has been an appointed member of the Singapore Copyright Tribunal since May 2010 and a mediator with the WIPO Arbitration and Mediation Center. He is also appointed as a Notary Public & Commissioner for Oaths in Singapore. He previously served on the International Trademark Association’s Board of Directors and was a member of the executive committee.


Ren Jun Lim is a principal with Baker McKenzie Wong & Leow. He represents local and international clients in both contentious and non-contentious intellectual property matters. He also advises on a full range of healthcare, as well as consumer goods-related legal and regulatory issues. Ren Jun co-leads Baker McKenzie Wong & Leow's Healthcare as well as Consumer Goods & Retail industry groups. He sits on the Law Society of Singapore IP Committee and on the Executive Committee of the Association of Information Security Professionals. He is also a member of the Vaccines Working Group, Singapore Association of Pharmaceutical Industries, a member of the International Trademark Association, as well as a member of the Regulatory Affairs Professionals Association. Ren Jun is ranked in the Silver tier for Individuals: Enforcement and Litigation and Individuals: Prosecution and Strategy, and a recommended lawyer for Individuals: Transactions by WTR 1000, 2020. He is also listed in Asia IP's Best 50 IP Expert, 2020, recognised as a Rising Star by Managing IP: IP Stars, 2019 and one of Singapore's 70 most influential lawyers aged 40 and under by Singapore Business Review, 2016. Ren Jun was acknowledged by WTR 1000 as a "trademark connoisseur who boasts supplementary knowledge of regulatory issues in the consumer products industry." He was also commended by clients for being "very responsive to enquiries and with a keen eye for detail, he is extremely hands-on. His meticulous and in-depth approach to strategising is key to the excellent outcomes we enjoy."

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