What is the difference between the roles of the Principal Officer (PO) and Key Appointment Holders (KAHs)?
The role of the PO under HCSA is akin to that of the “clinic manager” under the PHMCA. The PO provides oversight to the day-to-day management of the licensable healthcare service. It is the PO’s duty to ensure operational compliance with the regulations and assist the licensee to review any risks to patient safety and welfare.
While the role of the “KAH” is now formalised under the HCSA, it is not a new concept. The KAHs are the governing body and generally the controlling mind and will of the licensee, and to be determined based on the business structure as registered with the Accounting and Corporate Regulatory Authority (ACRA). KAHs generally comprise the Board of Directors (BOD) for companies, the partners for partnerships, or the owner for sole proprietorships. They are responsible for the strategic leadership and corporate management oversight of the organisation, but they have limited direct influence over the day-to-day operations on the ground as compared to the PO.
Examples of typical KAHs in different settings include:
Board of Directors for acute hospitals and community hospitals, large medical / dental clinic chains, clinical laboratories and large nursing homes, as these are typically complex set-ups owned by companies;
Partners in partnerships, which typically own less complex set-ups, such as a small multi-doctor clinic;
The business owner of sole proprietorships, which typically own simple set-ups, such as a solo GP clinic. Where a clinic is owned by an individual and the business is not registered with ACRA as a sole proprietorship, that individual is the KAH.