CLARIFICATIONS ON CLAIMS MADE BY MANADR

The Ministry of Health (MOH) would like to issue clarifications in response to the comments made by MaNaDr’s management at its press conference held on 2 April 2025, as reported by the media.

Licensees must exercise governance over the provision of telemedicine

2. Dr Siaw Tung Yeng was quoted as saying that MaNaDr Clinic, being a subsidiary run separately from its parent entity Mobile-health Network Solutions, runs its clinic operations independently and manages itself.

3. The Ministry would like to emphasise that under the Healthcare Services Act 2020 (HCSA), all licensees and their key officeholders are ultimately responsible for ensuring compliance with regulatory requirements, regardless of the licensee’s corporate structure. Licensees are also fully accountable for the safety and quality of the healthcare services provided by the clinic, including telemedicine services, and must ensure that the services comply with the applicable ethical and professional standards. In this instance, as the Principal Officer and Clinical Governance Officer of MaNaDr clinic, Dr Siaw would have been responsible for the day-to-day management of the clinic and provision of clinical governance and technical oversight over the clinic’s services.

4. In addition, any doctor who practises under the auspices of a licence under HCSA, whether as a locum practitioner or an employee, does not operate independently, but must be under the supervision and oversight of the licensee and their key officeholders.

Duration of teleconsultations should be commensurate with patients’ needs

5. It was reported that MaNaDr platform recently implemented a rule that requires teleconsultation sessions to last at least one minute before a medical certificate can be issued.

6. As highlighted in MOH’s press release on 24 October 2024, short consultations raise concerns about the safety and quality of clinical assessment and care provided to patients. The duration of the teleconsultation should be commensurate with the patient profile and presenting medical conditions, as reflected in the Singapore Medical Council’s Ethical Code and Ethical Guidelines.

7. MOH would like to reiterate that it is not necessarily the case that so long as a teleconsultation exceeds a minute, it would pass muster. Ultimately, the quality and adequacy of the medical care, and not just duration of the teleconsultation, matter.

8. Licensees providing teleconsultations are required to put in place quality assurance measures such as implementing and regularly reviewing protocols and processes to ensure that doctors are conducting proper clinical assessments and prescribing and issuing medical certificates on proper medical grounds.

Implementation of Artificial Intelligence tools is regulated

9. It was also reported that the MaNaDr platform would be implementing Artificial Intelligence (AI) tools to enhance clinical standards, transcribe doctor-patient conversations, and consolidate prescribed treatment plans and other relevant medical records.

10. While the use of AI in clinical settings can enhance efficiency and has the potential to improve patient outcomes, it also brings about inherent risks and ethical concerns. This is why MOH has put in place a robust framework to regulate and govern AI in healthcare, to ensure safe and responsible design and use. Licensees are reminded that, notwithstanding their use of MaNaDr platform’s AI tools, they continue to be responsible for ensuring compliance with licensing requirements under HCSA, including patient safety and welfare for all services provided. For instance, where AI-powered tools are used for transcribing interactions between doctors and patients or consolidating prescribed treatment plans, licensees must ensure the accuracy, confidentiality, and security of the patient health records. Licensees must also check if the AI tools need to be registered with the Health Sciences Authority as a medical device, and ensure that fair and non-biased data was used to train the AI tool.

11. MOH would like to reiterate that licensees are accountable and responsible for the licensable healthcare service provided, including the conduct of their healthcare professionals and deployment of technological tools, and should comply with all necessary regulatory requirements.