Head of Medical Law Practice
Specializes in medical, corporate, and migration law. Has extensive experience working with medical and pharmaceutical businesses, particularly in licensing, circulation of medicines, and comprehensive legal support of healthcare institutions, including corporate, tax, and employment matters, as well as market entry projects of foreign companies into Ukraine.
Medical license for a rehabilitation center
In Ukraine, a new state control system has been finally formed and implemented — the licensing of modern rehabilitation in the healthcare sector. The legal framework, based on the Law of Ukraine “On Rehabilitation in the Healthcare Sector”, has completely changed the rules of the game for practicing specialists. Modern requirements of the licensing authority do not just regulate the mechanics of patient recovery, but are strictly synchronized with the mandatory electronic documentation of rehabilitation care in the eHealth system (ESOZ).
Recent changes to the Licensing Conditions for Conducting Economic Activity in Medical Practice set additional strict requirements for the formation of multidisciplinary rehabilitation teams (MRTs). The state has clearly regulated the work of specialists providing psychological assistance. From now on, only specialists with higher education in the fields of “Psychology” and/or “Medical Psychology” who have at least 1 year of confirmed work experience in medical institutions or rehabilitation centers and meet the qualification standards of the Ministry of Health of Ukraine can be involved in the MRT staff.
An important breakthrough for the industry: the new legislation allows licensing of rehabilitation specialists who are not medical workers but directly provide assistance to patients. These include:
- physical therapists;
- occupational therapists;
- speech and language therapists (logopedists);
- prosthetists-orthotists.
This allows legalizing the activities of a new type of rehabilitation institutions that are not classic hospitals and work in a so-called mono-professional environment (where there are no doctors, and assistance is provided exclusively by physical therapists and occupational therapists). Regardless of the legal form, each service provider is obliged to maintain and report in the form of an individual rehabilitation plan (IRP).
If you plan to order an expansion of the Ministry of Health license or open a business from scratch, the medical law attorneys of the Prikhodko & Partners company have prepared a step-by-step practical roadmap for you.
Legal forms of work: how to open a rehabilitation center — LLC or Sole Proprietorship (FOP)?
The first strategic question that a founder asks before opening a private rehabilitation center is the choice of the organizational and legal form of activity. The tax burden and the volume of future services of your institution directly depend on this.
Legal entity: LLC (Limited Liability Company), Public Organization, Charitable Foundation
For whom: Investors and partners who plan to create a large multidisciplinary rehabilitation center with an inpatient department, a pool, and the involvement of many specialists.
Advantages: The ability to simultaneously license an unlimited number of medical specialties. A legal entity has the maximum chances of participating in public procurement and large-scale cooperation with insurance funds.
Feature: Mandatory presence on staff of a medical director with appropriate managerial experience and category.
Sole Proprietorship (FOP) — private practice
For whom: Practicing Physical and Rehabilitation Medicine (PRM) doctors, physical therapists, or occupational therapists seeking to open their own rehabilitation office or outpatient clinic.
Flexibility: A simplified taxation system, easy accounting, and a minimum of bureaucracy at the start of the business. Today, a Sole Proprietor has the full right to hire personnel and officially form their own multidisciplinary team.
Advice from a medical lawyer: Registration of an LLC or Sole Proprietorship in itself does not give you the official status of a “rehabilitation institution”. You acquire this status exclusively at the moment when you declare a specific list of medical specialties and non-medical specialists of the rehabilitation cycle in the information submitted to the Ministry of Health.
Which NACE codes (KVEDs) to choose for opening a rehabilitation center?
In order for your medical practice license (rehabilitation) to be issued flawlessly, it is necessary to correctly select the codes of types of economic activity:
| 86.22 | Specialized medical practice | Basic for the work of doctors of physical and rehabilitation medicine (rheumatologist, cardiologist, neurologist, traumatologist-orthopedist, etc.). |
| 86.90 | Other human health activities | Mandatory for rehabilitation, because it is what legalizes the work of physical therapists, occupational therapists, speech therapists, and psychologists. |
| 86.21 | General medical practice | For primary examinations and consultations. |
| 86.10 | Hospital activities | If your center will have beds (inpatient department). |
| 96.04 | Physical well-being activities | For providing additional services (hygienic massage, saunas, salt rooms). |
Requirements for a rehabilitation center: how to successfully pass the Ministry of Health inspection
To obtain a medical license for rehabilitation, a business entity must fulfill three main groups of licensing conditions:
- prepare the premises according to DBN standards;
- select personnel;
- equip the material and technical base.
1. Requirements for the premises of a rehabilitation institution and DBN standards
A modern premises for rehabilitation must strictly comply with state building norms (DBN V.2.2-10:2022 “Healthcare Institutions”).
- Real inclusivity (barrier-free): the institution must have an official expert conclusion on accessibility for low-mobility population groups. The entrance must be equipped with a ramp with a standard slope (up to 8%) and two-level handrails (70 and 90 cm) or a certified lift. Doorways of offices and bathrooms must be at least 90 cm wide, and thresholds no higher than 2 cm with a rounding.
- Functional zoning: The area of a standard office for a doctor’s or specialist’s reception must be at least 18 sq.m. If several specialists work in one office, the area increases proportionally to maintain patient privacy.
- Physical therapy (kinesitherapy) hall: with an area of 18 sq.m or more (depending on the number of patients present at the same time) to accommodate large exercise machines and suspension systems.
- Inclusive bathroom: Mandatory presence of a specialized restroom with a turning radius for a wheelchair (from 1.5 m), support handrails, and an emergency call button for personnel.
- Disposal of medical waste: Availability of a valid contract with a specialized company for the removal and destruction of hazardous medical waste and an equipped separate isolated place for their temporary storage inside the center.
2. Requirements for the personnel of a rehabilitation center: from solo practice to multidisciplinary rehabilitation teams
There is a myth that a huge staff is needed to start a rehabilitation business. In fact, the licensing conditions are very flexible:
- License for one specialist: If you are a PRM doctor or a certified physical therapist, you can open a private office as a Sole Proprietor individually.
- Multidisciplinary Rehabilitation Team (MRT): Becomes mandatory if you plan to provide a full range of services and legally claim funding from the National Health Service of Ukraine (NHSU) under rehabilitation packages.
The Prikhodko & Partners company will help you conduct an audit of the personnel’s qualification documents, check diplomas and specialists’ certificates, officially employ the staff, and carry out the turnkey registration of medical workers in the eHealth system.
3. Equipment list for a rehabilitation department: minimum medical set
The licensing authority verifies the presence of each piece of equipment according to the approved equipment list. The absence of even a basic goniometer becomes a ground for license refusal.
Useful lifehack: You can start with one specialty, and later, as the business grows, arrange an expansion of the medical practice license — add new specialties, additional equipment, or inpatient beds.
For example, when forming the material and technical base for an inpatient rehabilitation department, the licensee is obliged to strictly comply with the provisions of the Order of the Ministry of Health of Ukraine No. 995 dated May 31, 2023. This regulatory document is the main checklist for the licensing authority. It defines the exact list of devices, diagnostic tools, and exercise machines necessary to provide specialized care to adults in the post-acute rehabilitation period.
If you plan to order a turnkey medical practice license or expand existing areas, the medical lawyers of the Prikhodko & Partners law firm will conduct a detailed audit of the available equipment for compliance with the Exemplary Equipment Lists approved by the Ministry of Health to ensure successful medical practice licensing.
Procedure for obtaining a license for a rehabilitation institution: Step by step
The registration procedure consists of three key steps, where every detail matters.
Step 1. Preparation of information. Drawing up a detailed description of the material and technical base (indicating the year of manufacture and serial numbers of the equipment) and the personnel potential of the institution. An application for a medical license and an inventory are necessarily prepared.
Step 2. Submission of the document package. Documents are submitted electronically through the Portal of Electronic Services of the Ministry of Health, or personal submission to the “Single Window” of the Ministry of Health in Kyiv is available, or sent by registered mail with an inventory of the enclosure via post.
Step 3. Decision making and payment. The law provides for 10 working days for reviewing the documents (on average, with the issuance of the Order — up to 14 calendar days). The decision is published in the form of an Order of the Ministry of Health on the official web resource. After that, the licensee is strictly obliged within 10 working days to pay a state fee in the amount of one subsistence minimum (in 2026 — 3,328 UAH).
Why do independent attempts to obtain a medical license often fail?
According to statistics, more than 40% of applicants who try to go through the procedure on their own receive official refusals or the return of documents for revision. The most frequent reasons:
- Improperly executed documents regarding the accessibility of the premises for low-mobility groups (inclusivity).
- Concluding a contract for the processing of medical waste with a company that does not have an appropriate license from the Ministry of Economy for this type of activity.
- Errors in filling out the personnel block (expired doctors’ certificates, lack of CPD points, discrepancy between job titles and the classifier).
- Outdated forms of blanks and names of medical specialties.
What is the real cost of a mistake? Each round of refusal is an automatic loss of at least two to three weeks of time. The downtime of rented premises, payment of wages to hired doctors and rehabilitators “into the air” cost the owner both direct losses and reputational ones. In addition, delaying the start can lead to the loss of valuable specialists who will go to competitors.
Legal support and assistance in turnkey licensing of rehabilitation practice
To protect your medical business from financial losses and bureaucratic hell, a rational decision is professional assistance in licensing a rehabilitation center from experts. The Prikhodko & Partners law company takes on the entire complex of works:
- full legal and tax consulting, selection of safe NACE codes, registration of an LLC or Sole Proprietorship;
- preliminary technical audit of the premises for compliance with DBN and control of obtaining a conclusion on inclusivity prior to signing the lease agreement;
- thorough verification of the educational and qualification documents of the personnel;
- formation of a correct package of Information and an application to the Ministry of Health without any risk of return;
- registration of the organization and employees in the eHealth system;
- full support of the consideration of documents in the licensing authority until the issuance of a positive Order of the Ministry of Health;
- preparation of the institution for concluding contracts with the NHSU.
Do you need a guaranteed result on the first try? Contact a leading medical lawyer at the Prikhodko & Partners company right now. Our team will ensure the fast and legal receipt of a license online throughout Ukraine or in our office!
Calculate the cost of services
1 question
Are you planning to open a rehabilitation center or office?
2 question
Do you already have a premises and need it checked for compliance with State Building Norms (DBN)?
3 question
Do you need a consultation on choosing NACE codes (KVEDs) and the form of ownership (Sole Proprietorship/LLC)?
What to do if I am not in Kyiv?
Medical law covers a very wide range of services, and most of them can be provided remotely – with modern technologies, this is not only possible but also more convenient and efficient. Even court sessions are not an obstacle – we participate in them online.
At the same time, it is possible for a lawyer to travel outside Kyiv and the region to provide certain services.
Contact and clarify information by phone!
How can I get a disability group?
In order to understand whether you can receive a disability group, a lawyer studies your medical documents in detail, consults with specialist doctors, and then concludes whether you have grounds for registering a disability and which group.
If there are grounds, the lawyer gives comprehensive advice on what and how to do to maximize the chances of receiving a positive opinion of the medical board.
If necessary, the lawyer provides full support.
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