The Regulation on the Independent Practice of Healthcare Professionals (“Regulation”), published in the Official Gazette dated March 29, 2025 and numbered 32856, has entered into force, setting forth the procedures and principles regarding the standards, establishment, operation, supervision, and closure processes of health service units to be opened by healthcare professionals (“HCPs”) for independent practice.
Under the Regulation, the procedures and principles governing the independent practice of HCPs such as clinical psychologists, nurses, midwives, physiotherapists, audiologists, dietitians, speech and language therapists, podologists, and occupational therapists are defined. Notably, the definition of HCP under this Regulation does not include physicians, dentists, or pharmacists. Moreover, it is emphasized that clinical psychologists included in the Regulation may practice their profession within the scope of their professional qualifications by obtaining a license from the Ministry of Health under the name of a health service unit. These health service units are defined as private healthcare institutions where HCPs independently perform their professional services.
1- Key Provisions
Among others, the Regulation provides the following:
- Health service units may only be established by Turkish citizens and cannot be operated by legal entities.
- A maximum of three HCPs with the same professional title may jointly open a unit, and a separate license will be issued for each individual.
- If a licensed unit does not begin operations within 6 months, the license will be revoked. The suspension period may be extended up to 2 years in cases of force majeure.
- Spatial and physical standards and signage rules are clearly outlined. Importantly, HCPs are prohibited from providing healthcare services under the names of consultancy, education, coaching, or similar without operating a health service unit licensed under their own name. Licenses or permits obtained from other institutions do not grant the right to provide healthcare services.
- Patient data, prescriptions, and treatment plans must be recorded electronically using a health information management system registered with the Ministry’s registry system. Technical and administrative measures must be taken to ensure data security. Medical records signed with an electronic signature will be considered official.
- HCPs are required to perform their duties in compliance with ethical principles and relevant legislation. Additionally, informational and promotional activities must comply with the Regulation on Promotion and Informational Activities in Health Services, published in the Official Gazette numbered 32263. Misleading advertisements, demand-generating content, or unfair competition against other healthcare institutions are expressly prohibited.
- Branch offices are not permitted, and the presence of pharmaceuticals, cosmetics, or unauthorized equipment is forbidden within the unit.
- Unauthorized service provision, operation under another institution's license, and providing services outside one's professional scope are strictly prohibited.
2- Considerations Regarding Clinical Psychologists and Dietitians
The Regulation stipulates that clinical psychologists and dietitians must operate with a license, rather than a workplace opening permit. Accordingly, they must establish a health service unit in compliance with the conditions set out in the Regulation. This clearly indicates that these professionals are not permitted to provide services from their homes or in association with health institutions to which they are not affiliated. Furthermore, they may not share office space with professionals from other fields, for instance, an architect and a dietitian may not operate within the same unit.
It is also important to note that only clinical psychologists fall within the scope of HCPs as defined in the Regulation and are permitted to establish an independent practice. Psychologists without the “clinical” title are not eligible to open a practice under this Regulation.
Overall, there are differing interpretations of this matter, and changes may occur in both legislation and its implementation over time.
3- Scope of Supervision as Regulated
Article 22 of the Regulation mandates at least one regular inspection per year, and, when necessary, supervision related to medical indications. According to the Health Service Unit Supervision Inquiry and Administrative Sanction Form (“Form”) provided in Annex-5, at least one regular inspection per year will be conducted. In addition, audits regarding compliance with medical indications and procedures may be carried out when deemed necessary by the Ministry.
These inspections will include evaluations based on patient records, treatment documentation, and electronic systems. Thus, it is anticipated that health service units will be subject to at least annual inspections and partial inspections concerning personal data security. Furthermore, the Regulation provides for the establishment of audit commissions comprised of at least three experts from Ministry-affiliated institutions or universities to assess compliance with medical indications and practices. These commissions will regularly review operations for compliance with legislation.
Moreover, whether an HCP holds a valid license, adheres to the ethical principles set by the Ministry, and ensures that all medical devices within their scope are registered in the Product Tracking System (ÜTS) will also be inspected.
4- Evaluation and Potential Impacts
The Regulation, effective as of March 29, 2025, requires existing health service units to become compliant within three months and obtain licenses if necessary. This marks a significant transitional period, particularly for HCPs currently operating without a license.
The Regulation establishes a supervision system that prioritizes ethical standards, patient safety, and data protection. Through the mandatory annual inspections and expert audit commissions, the goal is to ensure transparent, safe, and high-quality services across the sector.
As the implementation process continues, further clarifications and updates in practice are expected.
Click here for the Turkish version of the Regulation.