There is no need to state a “non-specified” person’s qualification and the disclaimer every time the title “Dr” is used in a healthcare advertisement.

The information (i.e., qualifications and disclaimer) can be set out once within the same advertisement.

For social media posts, it would suffice to have the information to be set out once in the profile information. Similarly, for websites, it would also suffice to have the information set out once in the profile page. In the case of a two-page advertising leaflet, it would suffice to have the information set out once on the first page. The disclaimer can also be set out in the form of a footnote.

The website of the psychology clinic provides information of its psychological services and features its clinical psychologist. This would be deemed as healthcare service advertising. As the clinical psychologist is not a “specified person” under Section 31B of the HCSA, he / she must comply with the following when using the title “Dr”:

• state his/ her educational qualifications whenever the title “Dr” is used; and

• include a disclaimer that “his/ her educational qualification is not a medical or dental qualification”

The practice of Traditional Chinese Medicine (TCM) is not considered a licensable healthcare service under HCSA. Advertisements of TCM service(s) will not be subject to advertising controls under the Healthcare Services (Advertisement) Regulations.

However, Traditional Chinese Medicine Practitioners must adhere to the Ethical Code and Ethical Guidelines for Traditional Chinese Medicine Practitioners.

Section 31B of the HCSA was promulgated to ensure that consumers are not misled by healthcare service advertisement into thinking that a person who uses the “Dr” title is a mainstream registered medical or dental practitioner.

This is in response to feedback received against non-medical practitioners practising at non-licensed healthcare premises for allegedly misleading members of public with the use of the title, “Dr”.

Requirements under Section 31B of the HCSA applies only to advertisements and is not applicable to context outside of advertisements.

The requirements under Section 31B of the HCSA do not apply to settings outside the context of advertisements, for example:

• A clinical psychologist who uses the title “Dr” in a psychology class at an Institute of Higher Learning.

• A podiatrist who publishes a paper in the Singapore Medical Journal (SMJ) or The Journal of the American Medical Association (JAMA) and uses the title “Dr”.

Some examples of persons who are not “specified persons" :

a) Non-registered allied health professionals (i.e., not currently listed in the Second Schedule of the Allied Health Professionals Act 2011):

i. Audiologists

ii. Clinical Psychologists

iii. Dietitians

iv. Podiatrists

v. Prosthetists/Orthotists

b) Non-registered complementary and alternative medicine practitioners:

i. Chiropractors

ii. Osteopaths

iii. Ayurvedic medicine practitioners

c) Others:

Medical/ dental practitioners or registered allied health professionals who do not/ no longer hold valid practising certificates under the respective legislative acts that govern their professions. For example, retired medical practitioners or persons who hold medical qualifications, but is not registered as a medical practitioner with the Singapore Medical Council to practise as a medical practitioner in Singapore.

Non-healthcare trained person who holds a PhD. For example, the CEO of a medical group who owns a chain of medical clinics and wishes to use the title “Dr” in the advertisement by virtue that he has a PhD in Mechanical Engineering, he needs to adhere to the requirements under Section 31B of the HCSA as he is not a “specified person”.

Licensees are allowed to advertise government programmes if the substantive content comprises factual information about or relating to the healthcare services provided by a licensee, where the healthcare service is provided in relation to a programme that is funded (in whole or in part), initiated or endorsed by the Government or the Health Promotion Board.

HCSA does not govern the use of names of MOH’s related agencies in advertising. However, this will be controlled by the agencies whose programs the services purport to be a part of. Licensees will need to comply with the rules stipulated for the respective programs.

In general, licensees should ensure that their advertisements are factual and not deemed to be misleading to the general public and comply with all the requirements under Healthcare Services (Advertisement) Regulations.

Under the HCSA, non-HCSA licensees must comply with certain advertising requirements.

Under section 31(1) of HCSA, a person must not advertise, or cause to be advertised, a licensable healthcare service unless the person is a licensee authorised to provide that licensable healthcare service; or is acting on the authority of the licensee (referred to as an “authorised person” in the HCS (Advertisement) Regulations). It is acceptable for non-licensees to state they are collaborating with the licensee. However, if non-licensees wish to advertise a licensable healthcare service the licensee is providing, they must obtain prior approval from the licensee. The advertisements would also need to comply with the HCSA (Advertisement) Regulations, including requirements relating to the medium the advertisement appears in# , and the content and form of the advertisement.

#newspapers, directories, medical journals, magazines, brochures, leaflets, flyers, pamphlets or the Internet (including mobile application software).

No. Dental veneer procedure is a dental service. As dental service is a licensable healthcare service, non-HCSA licensees must not advertise licensable healthcare services.

Under section 31(1) of HCSA, a person must not advertise, or cause to be advertised, a licensable healthcare service unless the person is a licensee authorised to provide that licensable healthcare service; or is acting on the authority of the licensee (referred to as an “authorised person” in the HCS (Advertisement) Regulations).

Regardless of the use of terminology that is specific to the principles of Traditional Chinese Medicine or Western Medicine, healthcare service advertising by non-HCSA licensees should not contain any claims that the healthcare service provided can treat a condition affecting the human body. In the example raised in the question, the advertisement could factually list the services provided for “消渴症” but should not claim to treat “消渴症”.

Some examples of advertisements by non-HCSA licensees that comply with Section 31A of the HCSA:

• Advertisement by a Traditional Chinese Medicine Clinic: “TCM acupuncture can help with knee pain and back ache.”

• Advertisement by a Psychology Clinic: “Our psychology service helps patients to manage mental conditions such as depression, anxiety, eating disorder and obsessive-compulsive disorder.

Some examples of advertisements by non-HCSA licensees that contravene Section 31A of the HCSA:

• Advertisement by a Traditional Chinese Medicine Clinic: “We treat chronic diseases such as hypertension, diabetes and all cardiac conditions.”

• Advertisement by a Chiropractic Clinic: “We are experienced in treating scoliosis.”

The table of allowable MOSDs for LHSes and SSes can be found here

The majority of LHSes will be delivered via the Permanent Premises MOSD, however for some LHSes we have allowed the provision of these services through other modes such as Temporary Premises and Conveyances. This is determined based on the type of services provided, the feasibility of the service being delivered via that MOSD, the level of risks to patient safety and the reasonable business or care models for such services.

In instances where licensees intend to provide their LHS via more than one MOSD, we have created MOSD bundles for certain LHSes to ensure licence fees remain affordable to businesses. For example, all Outpatient Medical Service licensees are provided a bundle of “Permanent Premise”, “Temporary Premise” and “Remote” MOSDs for the provision of their outpatient medical service.

The disclosure of the sponsorship may enhance transparency in this regard to consumers. However, it is unethical and inconsistent to allow licensees to pay for and, in so doing, influence the content of the “review”, while giving the consumer the impression that the “review” is a genuine reflection of the writer’s or presenter’s personal experience (when there is in fact underlying commercial interest).

Yes. However, where such materials constitute healthcare advertisements (e.g. encourages the use of the services), they are subject to HCS (Advertisement) Regulations.