In more detail
In 2024, the MOH revoked a telemedicine service provider's license for clinically and ethically inappropriate practices. Further details may be found in our September 2024 and October 2024 client alerts.
In April 2025 the management of this telemedicine service provider announced that it would be implementing new safeguards. Among others, the new safeguards reportedly include a requirement for all teleconsultations it provides to be at least one minute long before issuing a medical certificate (MC).
Following this announcement, the MOH has provided clarifications on the provision of telemedicine services in Singapore, as follows:
- Licenses must exercise governance over the provision of medical services
The MOH emphasized that the ultimate responsibility for compliance with regulatory requirements lies with the licensee and its key officeholders. This includes day-to-day management of operations and the provision of clinical governance and technical oversight of clinical services. All healthcare professionals operating under the same license are under the supervision and oversight of the license holder, regardless of the corporate structure that governs their relationship.
- The duration of teleconsultations must be commensurate with patients' needs
The MOH reiterated that a teleconsultation that exceeds a minute does not necessarily mean that the telemedicine service meets the requisite standards. The quality and adequacy of medical care provided will vary based on patients' needs, and it is ultimately decided by whether the care provided is commensurate to the patients' needs.
- The implementation of AI tools is regulated
In response to the telemedicine company's plans to use AI tools on its teleconsultations platform to enhance clinical standards, transcribe doctor-patient conversations, and consolidate prescribed treatment plans and other relevant medical records, the MOH noted that while the use of AI could be beneficial, caution must be exercised to ensure that the use of AI is compliant with all necessary regulatory requirements. Inherent risks within the use of AI tools such as data bias, cybersecurity and confidentiality must also be robustly managed by licensees.
Key takeaways
The MOH was particularly active in its enforcement in the telemedicine industry in 2024. The breach of applicable license conditions when providing telemedicine services in Singapore involves a fine of up to SGD 20,000 and/or imprisonment for up to 12 months.
With the MOH's continued focus on regulatory requirements, data and digital health issues in the telemedicine and healthcare sectors, companies should pay close attention to their provision of licensed healthcare services and the implementation of AI tools.
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