News & Announcements

A year after the enactment of Law No. 17 of 2023 on Health (“Indonesian Health Act”), the government has issued  implementing Government Regulation No. 28 of 2024 (“GR 28/2024”).

The notable points of GR 28/2024 are as follows:

1. Vast Recognition of Telemedicine
   GR 28/2024 elaborates details of telemedicine services which were previously only briefly addressed in the Indonesian Health Act. The details are as follows:
   • Scope of Telemedicine Services: Telemedicine now encompasses teleconsultation, telepharmacy, and other related services, in line with advances in science and technology.
   • Parties allowed to provide Telemedicine Services by using their own telemedicine application or utilize a third-party application are:
     1. hospitals;
     2. healthcare centers;
     3. clinics;
     4. independent practices;
     5. health laboratories; and
     6. pharmacies.
   • Further requirements on telemedicine services are anticipated to be dealt with in the upcoming implementing regulations from the Ministry of Health (“MOH”).
2. Requirements for Foreign Overseas Graduate Doctors
   1. The Indonesian Health Act explicitly exempts Foreign Overseas Graduate Doctors from the MOH’s competency evaluation requirements (if they meet the following criteria):
      – Graduated from a recognized overseas medical school and have at least 5 years of practice experience abroad as a specialist or sub-specialist doctor; or
      – Have expertise in a specific advanced medical field and at least 5 years of practice experience abroad.
      After the enactment of GR 28/2024, the competency evaluation appears to be “partially reinstated” for foreign overseas graduate doctors because it now requires a portfolio assessment against doctor’s practical ability assessment, instead of competency test. Details of the portfolio assessment have not yet been regulated but are also expected to be outlined in MOH’s upcoming implementing regulations.
   2. However, the requirement to obtain a recommendation from the Indonesian Doctors Association (Ikatan Dokter Indonesia) before applying for a doctor’s practice license (Surat Izin Praktik – “SIP”) has now been omitted. This reform is expected to streamline the SIP application process, potentially shortening it to less than approximately 2 months, depending on the regions.
   3. Any foreign doctor must apply for the registration certificate (Surat Tanda Registrasi – “STR”) as one of the permits required for foreign doctors to be eligible to practice in Indonesia. Foreign doctors, regardless of whether they graduated from local or overseas universities, can obtain an STR with a limited validity of 2 years (extendable for an additional 2 years). This clarifies a potential misunderstanding from the Indonesian Health Act, which only specified a 2-year restriction for the STR of foreign overseas graduate doctors and implied that foreign doctors graduated from local universities may obtain a lifetime STR.

Our team will closely monitor developments and provide updates on significant changes to the MOH regulations, particularly concerning telemedicine and the evaluation procedures for foreign doctors.

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