The Hong Kong Medical Association receives a letter from Department
of Health dated 21 December 2016, in which we were consulted on
the draft standards for medical clinics.
The Government proposes to regulate all medical clinics in Hong
Kong, save for those exempted. The Government intends to exempt
small medical practices.
To qualify as a small medical practice, a clinic must fulfill the
1. The clinic will have 3 doctors or less,
2. Each doctor must be a director of the clinic,
3. All doctors regularly see patients in the clinic, and
4. No high-risk procedure will be performed in the clinic
A small medical practice can be exempted if no doctor in the clinic
regularly sees patient in more than 2 small medical practices.
The Government has proposed "Standards for Medical clinics".
A copy of the "Standards" can be downloaded from this
There are 5 areas in the proposed regulation:
1. Management / Governance
2. Physical Conditions
3. Service Delivery and Care Process
4. Infection Control
5. Risk Management and Contingencies
The core person of Management / Governance is the "Person-in-charge"
(the Government proposes to rename him as Chief Medical Executive).
The Chief Medical Executive must either be a registered medical
practitioner or a registered dental practitioner. He will be responsible
for all policies related to medical services. He will be responsible
for overseeing the training of staff, and ensure that all doctors
working in the clinic are up to professional standard.
Physical Conditions refer to the physical structure of the
clinic, including layout, fixture, furniture and equipment. It also
includes functional aspects like ventilation, lighting, signage
and sanitation. It is in this area that usage, storage, maintenance
of equipment is spelt out. Basically, the above items must comply
with existing standards.
Service Delivery and Care Process encompasses a number of
items, including patient's rights, medical record, drug management,
handling of specimens, charge transparency etc. Each regulated clinic
is required to have in place a complaint handling policy for patients.
Infection Control requires policies in place for the prevention
and prompt reporting of infection incidence. Adequate PPEs have
to be stocked and available to staff and patients. Medical equipment
designed for reuse must be disinfected or sterilized in accordance
with accepted standards. Medical equipment designed for single use
must not be reused. Clinical / chemical wastes are to be disposed
of in accordance with the guideline laid out by the Environmental
Protection Department. Radioactive waste are handled in accordance
with the law.
Risk Management and Contingency refer to events including
resuscitation. As such, adequate equipment must be stocked and made
readily available to staff, and staff must be familiar with the
usage of such equipment. Staff training and drilling are required
to maximize patient safety in case of emergencies. Interestingly,
fire drill is part of the requirement.