The current scope of HCSA is limited to regulating direct healthcare service provision. Concierge services, that involve third party providers who are essentially an administrative coordinating service and not engaged in direct patient care, will not be regulated.

Professional guidelines, such as Singapore Medical Council’s Ethical Code and Ethical Guidelines (SMC ECEG) provide guidance for medical practitioners contracting with such managed care organisations (MCOs) or third party administrators (TPAs) to ensure objectivity of their clinical judgement and the provision of the required clinical standard of care.

MOH will continue to monitor the patient safety risks and study the landscape of these concierge services further, before deciding on the appropriate regulatory framework, should important patient risks emerge.

Additionally, if TPAs should advertise licensable healthcare services, they are subject to the requirement under section 31 of HCSA, and can only advertise on a licensee’s authorisation and must still comply with all relevant advertising rules. If they also directly provide a licensable healthcare service in the course of their operations, they will need to hold the relevant HCSA licence