Do I need to physically separate co-located non-licensable services from my licensed healthcare service?
Healthcare Services (General) Regulations, Licensed premises,licensed conveyances & equipment
For all co-located non-licensable services, regardless of whether they are categorically permitted to co-locate under the Fourth Schedule or require prior approval from MOH, we will impose conditions in the following instances:
(i) If the co-located non-licensable services only serve the licensee’s patients, there is no need for physical separation, as the licensee is by default responsible for the safety of his patients in the provision of the nonlicensable services that are co-located with the licensable healthcare service. If the co-located non-licensable services also serve their own walkin patients or customers (i.e., not the licensee’s patients and without going through the licensee), there is a need for:
(a) a clear physical separation (e.g., separate entrances and walls in between) of the non-licensable services from the licensable healthcare service, or
(b) a conspicuously displayed signage, or other means of communication to patients as agreed by the Director, stating that the co-located service is not licensed by MOH and a clearly documented delineation of responsibilities between the licensee and the party providing the non-licensable services (e.g., via means of a contract or written agreement).
(ii) For certain non-licensable services that are not complementary to holistic healthcare delivery e.g., chiropractic services, MOH will impose clear physical separation (same as stated in (i)(a) above) as an additional condition for co-location, to minimise the risk of patient misperception that the service is regulated by MOH. This applies regardless of whether these non-licensable services serve only the licensee’s patients or not.
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