Permit for the Provision of Assistance Medical Services

The activity consisting in the provision of an assistance health service is excluded from the scope of Act No. 455/1991 Coll. on Trade Licensing (Trade Licensing Act), as amended (hereinafter referred to as the “Trade Licensing Act”) – i.e. this activity does not constitute a trade. The above follows from Section 3(1)(d)(1) of the Trade Licensing Act, pursuant to which “a trade shall not include the activity performed in the exercise of the professions of psychologists and healthcare professionals under a special regulation, except for public health officers performing health surveillance over working conditions, opticians, and dental technicians under this Act.” Outpatient clinics of assistance health services are primarily regulated by Act No. 578/2004 Coll. on Healthcare Providers, Healthcare Professionals, Professional Organizations in Healthcare and on Amendments and Supplements to Certain Acts, as amended. (source: minv.sk)

According to the statement of the Ministry of Health of the Slovak Republic:

“Act No. 578/2004 Coll. regulates the operation of an auxiliary health care service facility. Minimum requirements for the staffing and material and technical equipment of an auxiliary health care service facility, as well as details concerning its designation and the designation of the protective clothing of its employees, are laid down by Decree of the Ministry of Health of the Slovak Republic No. 113/2026 Coll. (Source: Ministry of Health of the Slovak Republic)”

According to the position of the Ministry of Health of the Slovak Republic, an assistant healthcare service clinic and a transport healthcare service clinic constitute two distinct types of healthcare facilities. The legal order does not prohibit a single entity from operating both types of facilities; however, this is contingent upon meeting the statutory requirements separately and obtaining two distinct permits for each type of facility. Furthermore, an authorization to conduct first aid training courses does not confer the right to operate an assistant healthcare service pursuant to Act No. 578/2004 Coll. (Source: Ministry of Health of the Slovak Republic)

“Due to the absence of regulation under the legislation currently in force, it remains unclear whether a physician or a paramedic is required to serve as the designated professional representative for an assistance health service outpatient clinic. For this reason, the Department of Litigation and Administrative Proceedings of the Ministry of Health of the Slovak Republic is currently unable to issue permits for the operation of these clinics. Permit issuance proceedings will resume only upon the entry into force of the planned legislative amendment, where compliance with all statutory conditions pursuant to Act No. 578/2004 Coll., including new requirements applicable to the designated professional representative, will be required. (Source: Ministry of Health of the Slovak Republic)”