The Ministry of Health ("MOH") recently proposed a Healthcare Services Bill ("HCS Bill") to keep apace with rapid advances in healthcare, including telemedicine. Sweeping changes have been proposed.

The HCS Bill will replace the current Private Hospitals and Medical Clinics Act ("PHMCA") (last updated in 1999) which only regulates healthcare providers with physical premises.

Key proposed changes compared with the PHMCA

  1. Private hospitals;
  2. Medical clinics;
  3. Clinical laboratories; and
Healthcare establishments

Regulatory scope is much broader to encompass the following:

  1. Healthcare services;
  2. Allied health and nursing services;
  3. Traditional medicine; and
  4. Complementary and alternative medicine.

Beauty and wellness do not fall under the ambit of the Bill.

Licensing approach Healthcare providers are licensed based on physical premises.

Healthcare providers are licensed based on the services they provide and not physical premises.

For example, telemedicine services that may not use a physical premise would nonetheless have to be licensed, provided such services are characterised as "healthcare service" under the Bill.

National Electronic Health Record ("NEHR")

No requirements

All licensed healthcare providers must contribute to the NEHR. The NEHR is intended to capture a person's medical history across different healthcare providers.

Strict safeguards will be in place to ensure patients' NEHR records are kept confidential and only accessed for purposes of patient care. Patients who do not wish to be part of the NEHR may choose to opt out.

Prohibition of unsafe practices, services and employment restrictions No requirements

Unsafe medical practices have been explicitly prohibited, which include bio-identical hormone replacement therapy with therapeutic claims, skin whitening injections, and stem cell activator protein for skin rejuvenation.

Employment restrictions will apply for those that work in healthcare services catered to frail or vulnerable patient groups.

"Step-in" safeguards for residential care services No requirements

To ensure patients in residential care services receive continuous care, MOH will be empowered to "step-in" and help failing healthcare services. The powers will only be exercised as a last resort.


The maximum fine is SG$20,000

The maximum jail term is 24 months.

The maximum fine will be increased from SG$20,000 to SG$100,000.

No change in the maximum jail term.


MOH is inviting feedback from the public on the HCS Bill from 5 January 2018 to 15 February 2018. They plan to enact the Bill later this year.

The Bill will be implemented in the following phases:

Phase Services that will need to comply with the new legislation
1 (from Dec 2019) Existing PHMCA medical and dental clinics, as well as clinical laboratories.
2 (from June 2020) All PHMCA-licensed hospitals and nursing homes.
3 (from Dec 2020) New services such as telemedicine that have not been regulated under the PHMCA.


The HSC Bill addresses significant healthcare trends, specifically telemedicine and Singapore’s ageing population. Although the Bill presents downstream challenges such as data security and patient privacy regarding the NEHR, it is a welcome development that provides better safeguards for patients.