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In brief

On 26 February 2021, the Singapore Ministry of Health (MOH) announced that it is introducing a new voluntary listing of direct telemedicine service providers, to assist patients with making informed choices when selecting telemedicine service providers. According to the MOH, this scheme will be an interim measure to promote patient safety and welfare in the provision of telemedicine services, pending the upcoming regulation of telemedicine services under the new soon-to-be-implemented Healthcare Services Act.


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As it stands, listing with the MOH is voluntary. However, the MOH “strongly encourages” providers to apply to be listed, as this could ease the transition to the licensing regime under the Healthcare Services Act by 2022. Given that telemedicine services are currently unregulated, participation in the listing can serve as a useful litmus test for MOH’s future standards and expectations of telemedicine service providers under the new Healthcare Services Act. This will also give providers time to relook and revise their existing practices gradually ahead of the new laws, thereby promoting business continuity by minimising any last-minute disruptions to their businesses once the Healthcare Services Act comes into effect.

More information on the new voluntary listing initiative may be found here. Our most recent newsletter covering the Healthcare Services Act can also be found here.

In more detail

On 26 February 2021, the Singapore Ministry of Health (MOH) announced that it is introducing a new voluntary listing of direct telemedicine service providers, to assist patients with making informed choices when selecting telemedicine service providers. According to the MOH, this scheme will be an interim measure to promote patient safety and welfare in the provision of telemedicine services, pending the upcoming regulation of telemedicine services under the new soon-to-be-implemented Healthcare Services Act.

Qualification under the new voluntary listing scheme is not automatic; the MOH will only list providers that have committed to comply with certain process and governance measures on the MOH website.

To qualify, the providers must:

  • Ensure their doctors and/or dentists have completed MOH’s telemedicine e-training;
  • Implemented professional and process measures ensuring the safety of telemedicine care. This includes the implementation of follow-up protocols, patient identity verification processes, etc.). The provider must also ensure that such measures and protocols are adhered to; and
  • Submit an application form to MOH to be listed. This form will include a declaration that the provider is compliant with MOH’s measures.

A key benefit of being listed by the MOH is that from 1 April 2021, only listed providers can:

  1. offer Community Health Assist Scheme (CHAS) subsidies; and/or
  2. submit MediSave claims for the follow-up of chronic conditions via video consultations under the Chronic Disease Management Programme (CDMP).

It should be noted that this development follows the corresponding closure of the MOH’s previous regulatory sandbox (the Licensing Experimentation and Adaptation Programme or LEAP). LEAP had begun in 2018 as an initiative by the MOH to gather insights on the provision of telemedicine services from 11 participating telemedicine and mobile medicine providers, and work closely with these providers to promote the safe growth of telemedicine. The information gathered during LEAP had since been collated to form the basis for the abovementioned free telemedicine e-training programme launched by the MOH in March 2020. To date, more than 6,000 learners have completed the e-training, which seeks to educate health professionals and staff on the limitations, safe use and incorporation of telemedicine into their existing practices.

The full listing of direct telemedicine service providers, as well as the steps and form to submit an application, may be found on the MOH’s website here.

Author

Andy Leck is the managing principal of Baker McKenzie.Wong & Leow. Mr. Leck is recognised by the world’s leading industry and legal publications as a leader in his field. Asian Legal Business notes that he “always gives good, quick advice, [is] client-focused and has strong technical knowledge for his areas of practice”. Alongside his current role as managing principal, Mr. Leck has held several leadership positions in the Firm and externally as a leading IP practitioner. He currently serves on the International Trademark Association's Board of Directors and is a member of the Singapore Copyright Tribunal.

Author

Ren Jun is an associate principal of Baker & McKenzie.Wong & Leow. Ren Jun extensively represents local and international intellectual property-intensive clients in both contentious and non-contentious IP matters, such as anti-counterfeiting; civil and criminal litigation; commercial issues; regulatory clearance; and advertising laws. Ren Jun also advises on a wide range of issues relating to the healthcare industries. These include regulatory compliance in respect of drugs, medical devices, clinical trials, health supplements and cosmetics; product liability and recall; and anti-corruption. Ren Jun is currently a member of the Firm's Asia Pacific Healthcare ASEAN Economic Community; Product Liability and Regulatory Sub-Committees.