Non-medical business scope of traditional Chinese medicine health care

According to my country's current "Standards for Traditional Chinese Medicine Health Care Services (Trial)" and the unified regulatory standards of market supervision and health care departments, the core of the non-medical business scope of traditional Chinese medicine health care institutions is service projects that are carried out around the daily health care needs of the general population, do not involve disease diagnosis and treatment, are not invasive/traumatic operations, and do not use medical-grade drugs and equipment. Any behavior that touches the boundary of "disease diagnosis and treatment" is an out-of-scope operation and is suspected of violating regulations.

A while ago, I helped a friend open a community moxibustion parlor to register. People from the district health department and the city supervisor jointly came to check. Pointing to the poster on the wall that read "Regulating uterine cold and improving irregular menstruation," they made a red cross: "If you advertise that it can improve diseases, that is medical behavior. You must first apply for a medical institution practice license, otherwise all words related to diseases and curative effects will be deleted." ”

In fact, this is also the most common pitfall for many practitioners who are new to the industry - they always feel that if they use TCM-related techniques such as moxibustion and massage, they can rely on "regulating diseases". In fact, from a regulatory perspective, the boundary between TCM health care and TCM medical treatment is very clear: any diagnosis and treatment involving pulse detection Prescriptions/prescription drugs, traumatic or invasive operations such as acupuncture/scar moxibustion/bloodletting/bone reduction, and even disease-related expressions such as "treatment, cure, diagnosis and treatment, efficacy" in publicity and communication are all medical behaviors and are not within the scope of business of ordinary health care institutions.

To be honest, when this boundary is actually implemented, the regulatory standards in different regions do differ, and there have always been different voices in the industry. For example, mild suspension moxibustion. In some cities, as long as you do not promote the treatment of diseases, health care projects can be carried out normally. In some cities, all moxibustion is directly classified as traditional Chinese medicine medical technology, and it is required to have clinic qualifications before it can be carried out. ； Another example is herbal medicated baths. Some places allow the use of herbal packages produced by regular manufacturers with the Jian brand and Xiao brand. Some places require medical qualifications as long as the use of Chinese medicinal materials is involved.

Most practitioners with traditional Chinese medicine backgrounds feel that there is no need to be so stuck: many health-preserving techniques originally come from folk daily care. Ordinary people do moxibustion to warm the stomach, or push the shoulders and neck to loosen the muscles. This is not medical treatment at all. If the restrictions are too strict, it will block the way of regular practitioners.； However, the regulatory considerations are also very realistic: more than 90% of the employees in health care institutions are not qualified as medical practitioners. If the borders are relaxed, it is easy to make arbitrary promises of curative effects and accidents due to random operations. In the past few years, there were cases of health stores performing bloodletting therapy on customers, resulting in infections. Strict borders are essentially a protection for consumers and regular operators.

Don’t believe it. I know an owner who has been running a health and wellness center for five years. He has been through this pitfall in the past two years: when he was giving shoulder and neck massage to a customer, he casually said, “If you don’t unblock this knot, it will turn into cancer.” The customer then complained to the city supervisor. Not only was he fined 8,000 yuan, but he was also required to make corrections for half a month. Later, he changed all promotional materials and communication skills with store clerks. He never mentioned any disease-related content, and only said "relieve fatigue, relax muscles, and improve stiffness." The products he used were all publicly available health care brands and makeup brands. Even the massage equipment he only bought ordinary models from the first-class medical device catalog. In the past few years, he has never had any compliance issues.

Oh, by the way, there is another misunderstanding that many people are confused about: even if you have a medical practitioner certificate, as long as the business license of the institution you open is "health care services (non-medical)", you cannot carry out any medical projects in the store. To do so, you must first go to the health department to apply for a medical institution practice license and change the nature of the institution to a medical institution. Otherwise, it will still be an out-of-scope operation.

In fact, to put it bluntly, the boundary between traditional Chinese medicine health care and traditional Chinese medicine medical treatment is complex and simple. If you position yourself as a "health maintenance" for ordinary people, just like an auto repair shop that performs routine maintenance on cars, not an auto repair shop that overhauls cars and replaces parts, don't do "treating diseases", don't make random promises about results, and follow the scope of "TCM health care services (non-medical)" on the business license, and basically you will not step into any big surprises. After all, whether it is regulatory requirements or industry development, the ultimate core is to allow ordinary people to enjoy formal health care services safely and safely. In this regard, both practitioners and consumers have the same goal.