Гайдлайн от юриста по открытию частной медицинской практики: пакет документов, необходимый клиникам

If you have decided to open a private medical practice, you can only be congratulated! Although owning a job is never easy, working for yourself and your brand is always an honor and respect, and it also guarantees many additional opportunities (and higher earnings, of course) compared to hired work.

Of course, when opening your office or clinic, consultation with a lawyer is inevitable. However, to begin with, you should independently study the package of documents that you will need to officially open your medical business.

Attorney, partner of the Interregional Bar Association Elena Radzievskaya, at the Business Shot 5.0 conference, told a complete guide on how to open your own clinic.

Algorithm for opening a private medical practice

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Of course, the topic is more legal, but the future owner of the medical business and private medical practice is simply obliged to know the main aspects. The main algorithm can be built into a system of 4 stages.


The order of the main steps when opening a private medical practice:
1. Search for premises and registration of the right to use it / ownership of it.

2. State registration (simultaneous registration of a VAT payer and a single tax payer is possible).

3. Obtaining a license to practice medicine.

4. Accreditation of a medical institution (no later than 2 years from the start of the activity).


Finding suitable premises
The government has set rather strict requirements for the premises where medical facilities should be located. And not all premises will meet these requirements. When looking for a space, first consider whether you are satisfied with the terms of its lease or purchase, and whether it meets the criteria established by law, and only then "dive" in the next steps.


The room must match:
- to the requirements of GSN V.2.2-10-2001 “Buildings and structures. Health care”;

- sanitary and hygienic and fire safety standards.



The most convenient option is to rent a room in already functioning medical institutions (for example, an office or a whole wing in a city or regional clinic).

This takes the headache out of legal compliance, as it's all been decided before you. However, the law also has requirements for the lease of such premises of state or communal property.

You should be aware that the premises that will be examined for compliance with license conditions, first of all, must comply with the State Building Code (GSN). For each specific type of medical services, construction state standards establish their own requirements. That is, it all depends on your list of services.

In addition, it must be borne in mind that, in accordance with paragraph 36 of the Licensing Conditions, medical devices and medical devices must be used by the licensee only in adapted premises, the requirements for which are defined in the instructions for use (passport) or technical documentation. And you will most likely still use special equipment.

State registration

State registration means the registration of a legal entity. As mentioned above, there may be simultaneous registration of both a VAT payer and a VAT payer.

State registration is the stage when you determine in what form you will carry out activities when

creating a clinic. Now the existing licensing conditions allow obtaining a license for medical practice not only for legal entities, but also for individual entrepreneurs. But there are cases when a legal entity is needed. According to statistics, more than 70% of legal entities that are now registered and registered in the State Register are limited liability companies (LLC). Close to this form and PE (private entrepreneurship). For an LLC, the Civil Code introduced a restriction - this form of enterprise can have only one legal entity-founder, but this legal entity cannot have only one founder. In other cases, it is better to register an emergency. True, it is still too difficult to sort out this issue without lawyers.

Obtaining a license

A medical license must be obtained from the Ministry of Health.

A business entity acquires the status of a medical institution from the day it receives a license.

The procedure for issuing licenses is regulated by the Decree of the Cabinet of Ministers dated March 2, 2016 No. 285 "On Approval of Licensing Conditions for Carrying out Business Activities in Medical Practice".


Licensing conditions provide for obtaining a license to carry out business activities in medical practice:
- legal entities, regardless of their organizational and legal form;

- individual entrepreneurs.


It is necessary to distinguish between the following types of services:
- medical cosmetology (licensing is required);- aesthetic cosmetology (licensing is not required). use of special technical equipment and tools.

These are hardware cosmetology, chemical peels, mesotherapy, ozone therapy, therapeutic massage, epilation, permanent makeup, wart removal, etc.




Aesthetic cosmetology

- these are procedures aimed at caring for the skin of the face and body that do not violate the integrity of the skin.

These are haircuts and styling, coloring and hair extensions, manicures and pedicures eyebrow tinting and modeling, eyelash extensions, masks and body wraps, make-up, relaxing (not therapeutic!) massage of the face, hands, neck, etc. .Licensing conditions, which are determined by the Cabinet of Ministers, establish requirements for business entities engaged in medical practice. First of all, these are the requirements for the premises - sanitary and hygienic and fire safety standards, as we wrote above. The act of the sanitary and epidemiological inspection of the facility is currently issued by the State Service for Food Safety and Consumer Protection.
relaxing (not therapeutic!) massage of the face, hands, neck, etc.

The differences between cosmetology and medical services, we think, do not need to be explained.

Licensing conditions, which are determined by the Cabinet of Ministers, establish requirements for business entities engaged in medical practice.

First of all, these are the requirements for the premises - sanitary and hygienic and fire safety standards, as we wrote above. The act of the sanitary and epidemiological inspection of the facility is currently issued by the State Service for Food Safety and Consumer Protection.
relaxing (not therapeutic!) massage of the face, hands, neck, etc.

The differences between cosmetology and medical services, we think, do not need to be explained.

My default imageLicensing conditions, which are determined by the Cabinet of Ministers, establish requirements for business entities engaged in medical practice.

First of all, these are the requirements for the premises - sanitary and hygienic and fire safety standards, as we wrote above. The act of the sanitary and epidemiological inspection of the facility is currently issued by the State Service for Food Safety and Consumer Protection.
which are determined by the resolution of the Cabinet of Ministers, establish requirements for business entities engaged in medical practice.

First of all, these are the requirements for the premises - sanitary and hygienic and fire safety standards, as we wrote above. The act of the sanitary and epidemiological inspection of the facility is currently issued by the State Service for Food Safety and Consumer Protection.
which are determined by the resolution of the Cabinet of Ministers, establish requirements for business entities engaged in medical practice.

First of all, these are the requirements for the premises - sanitary and hygienic and fire safety standards, as we wrote above. The act of the sanitary and epidemiological inspection of the facility is currently issued by the State Service for Food Safety and Consumer Protection.

Second, the requirements for personnel in medical practice. Medical practice by the licensee is carried out in accordance with medical specialties and specialties of junior specialists with medical education, the list of which is approved by the Ministry of Health. .


It is not allowed to introduce positions that are not provided for in the List of Medical Positions, positions of junior specialists with medical education and the Nomenclature of Specialties for Professionals with Higher Non-Medical Education Working in the Health System.

The third group of requirements under the Licensing Conditions is the requirements regarding the equipment with which medical practice is carried out. They are regulated by the order of the Ministry of Health of October 31, 2011 No. 739 "On approval of the tables for equipping medical equipment and medical devices of the structural units of the consultative and diagnostic center". which must be submitted to the one-stop shop of the Ministry of Health:



1. Application for obtaining a license of the established form (Appendix No. 1 to Resolution No. 285).
2. Information about the state of the material and technical base, the availability of personnel, indicating their educational and qualification level. Requests to submit additional documents are illegal!

The list of grounds for revocation of a license is clearly defined in Article 16 of the Law "On Licensing Types of Economic Activities". The decision to annul a license can be appealed to the Expert and Appeal Council for Licensing (MOZ), as well as by going to court (administrative lawsuit, the defendant is the Ministry of Health). The grounds and terms for filing a claim are limited.

For carrying out activities without a license or in violation of the License Conditions, administrative liability (heavy fines with confiscation) is provided for officials of business entities and administrative and economic liability (


cancellation of a license for medical practice
) for licensees. Accreditation
When a medical facility is already operating, accreditation should be obtained.

Accreditation is voluntary.

Accreditation of a medical institution

indicates the official recognition of a certain level of medical services and the availability of conditions for their provision.

If an institution decides to undergo an accreditation procedure, then it is carried out by a special team that checks in practice the veracity of the data from the documents submitted during registration with the Ministry of Health. The process can take up to six months. Accreditation can be passed by anyone, regardless of the form of ownership. The received accreditation certificate has an expiration date.

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