Telemedicine Platform Licensing

Does a telemedicine app need a license?

If it purely connects patients to independent doctors, usually no. If it employs doctors and provides care directly, it likely needs a medical facility permit.

Can I operate a virtual clinic without a physical location?

Under current Georgian regulations, obtaining a medical permit usually requires a physical address that meets sanitary standards.

How to avoid being classified as a medical provider?

Structure your platform as a technology service provider, ensuring doctors remain independent contractors with full medical autonomy.

What is the penalty for operating without a license?

Operating a medical facility without a required permit leads to significant fines and immediate suspension of activities.

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Telemedicine platform licensing differs from individual doctor licensing and concerns the legal entity — the company providing the service. In Georgia, the main question is: Is your platform merely a technological intermediary (like Uber for doctors) or a provider of medical services (a virtual clinic)? Defining this status is crucial because medical activities are subject to mandatory licensing or a permit regime, while IT services are not. Without proper structuring, the platform may be held liable for illegal medical practice. This service is designed for startups, clinics, and tech companies wishing to legally operate a telemedicine business.

Specialists on Legal.ge offer strategic legal services for platform authorization:

  • Status determination: Analyzing the business model to determine if you need a medical activity license/permit.
  • Permit documentation: Obtaining a medical activity license or a permit for an inpatient/outpatient institution (if necessary).
  • Notification obligation: Registering in the Registry of Economic Activities with the appropriate code and notifying the regulator (if the activity does not require a permit but is regulated).
  • User Agreements (ToS): Developing platform rules that clearly distinguish the platform's liability from the doctor's medical liability.
  • Partnership agreements: Contracts with clinics and doctors who provide services through the platform.

A practical example is an app that directly hires doctors and offers "treatment" to patients. In this case, the app acts as a clinic and needs the appropriate permit. If the app only connects an independent doctor with a patient and takes a commission, it may remain a technology provider. However, the line is very thin: setting prices, quality control, and branding can be considered organizing medical activities. Also to be considered is the presence of high-risk medical activity elements (e.g., emergency care), which definitely requires a license.

In Georgia, licensing of medical institutions is regulated by the Law "On Licenses and Permits" and Government Resolution No. 385 "On the Rule of Issuing Medical Practice Licenses and Inpatient Institution Permits." Although the concept of a "virtual clinic" is not explicitly in the law, the regulatory body (Regulation Agency for Medical and Pharmaceutical Activities) requires a medical service provider to have a physical address and meet sanitary-hygienic norms, which is a challenge for telemedicine startups.

Working with a specialist helps you choose the right legal structure. It might be better to partner with an existing licensed clinic (a "white label" model) rather than obtaining your own license. A lawyer will help you formalize this model to avoid fines and suspension of operations.

Legal.ge is your guide through healthcare bureaucracy. Platform licensing is a complex process, but with the right legal strategy, it is surmountable. Contact our experts to build your telemedicine business on a solid legal foundation.

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