If a HCSA licensee places an advertisement targeted at foreigners who are not physically located in Singapore, will the advertisement be subject to HCS (Advertisement) Regulations?
Healthcare Services Act(Advertisement) Regulations, Application of these Regulations
Advertisement of a licensable healthcare service is subjected to the HCS (Advertisement) Regulations if it has a Singapore link, i.e. a person who is physically present in Singapore is able to have access to the said advertisement or the advertisement is addressed to a class of persons whom the licensee or authorised person knows or has reasons to know is physically present in Singapore.
Advertisements published on the licensee’s website will be subject to the requirements under the HCS (Advertisement) Regulations, even if these are targeted at foreigners not located in Singapore. This is because a person who is physically present in Singapore will be able to access the advertisement on the licensee’s website.
Related questions
Can a licensee appoint a third-party administrator (based overseas) to advertise its licensable healthcare services in other jurisdictions, i.e. promoting medical tourism?
Are the requirements under HCSA and its subsidiary legislations applicable to local licensees who provide healthcare services overseas?
What do you mean by “it is assumed that the person will not falsify or conceal the person’s identity or location.” In Regulation 3(3) of the HCS (Advertisement) Regulations?
Do Healthcare Service (Advertisement) Regulations (HCS (Advertisement) Regulations) cover advertisements of non-licensable healthcare services (e.g. Traditional Chinese Medicine, physiotherapy, chiropractic)?
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