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Healthcare Compliance for Specialized Hospitals to Survive Indonesia’s New Health Law – UU 17/2023

Healthcare Compliance for Specialized Hospitals to Survive Indonesia’s New Health Law – UU 17/2023

Dr. Hardyansyah, MPH-MMR Sp. KKLP
December 13, 2025

Contents

The clock is ticking for specialized hospitals across Indonesia. With the implementation deadline for the sweeping new health regulations fast approaching in July 2026 (estimated), single-focus institutions must urgently adapt their service model or face significant licensing and operational hurdles.

The new legal framework that is established by the Omnibus Law (UU No. 17/2023) and detailed in Government Regulation (PP) No. 28/2024 signals a fundamental shift away from rigid classification systems toward a model based on integrated patient care and service capability.

The Core Challenge: No More “ENT-Only or Surgery-Only”

Under the former regulations, a specialized hospital (e.g., dedicated solely to Ear, Nose, and Throat or Ophthalmology) could restrict its offerings. However, the new government regulation repealed the old hospital law and now mandates that all licensed hospitals must adhere to a broad list of 12 minimum essential services, including:

  • Intensive care (pelayanan intensif)
  • Surgical services (pelayanan bedah)
  • Laboratory and Radiology services (pelayanan laboratorium dan radiologi)
  • Nutrition and Blood Services (pelayanan gizi dan darah)
  • Mortuary services (pemulasaran jenazah)

For a traditionally narrow specialty hospital, this new mandate means that simply performing their core specialization is no longer enough to renew their operating license.

The previous assumption that a purely single-focus service model will be permitted is likely incorrect; the hospital must now demonstrate an integrated support infrastructure.

Healthcare Compliance Perspective & Why Specialty Hospitals Are Most Vulnerable

Specialized hospitals typically operate with lean service portfolios, tightly scoped staffing, and limited auxiliary functions. Under the new law:

  • Minimal ICU capability is mandatory
  • Basic surgical readiness is required
  • Lab, imaging, and blood services must be accessible—either internally or externally
  • Hospitals must demonstrate integrated patient pathways aligned with national health standards

The assumption that “specialized means exempt” is no longer valid. Hospitals must either build, partner, or integrate to survive the licensing renewal cycle starting in 2026.

The Path to Adherence: Pivot, Partner, and Prioritize

The most realistic strategy for specialized hospitals with limited operational budgets is not immediate, costly expansion, but rather strategic partnerships and administrative re-engineering:

Service Adherence StrategyAction Plan
Outsource & Partner for Essential ServicesDo not recruit or procure expensive new equipment where possible. Instead, enter into formalized, documented agreements (MoUs) with nearby general hospitals or third-party accredited facilities to provide the mandatory services you lack (e.g., contracting an Anesthesiologist for minimal intensive care coverage, outsourcing blood banks, advanced lab tests, and mortuary services).
Streamline Referral SystemsPerfect the internal processes for accepting referred patients (Rujukan) and, crucially, sending them back to primary care when appropriate (Rujuk Balik). This ensures compliance with the new integrated care model and reduces the burden of long-term post-specialty care.
Cross-Train Existing StaffDesignate and cross-train existing nurses, pharmacists, and support staff to manage and coordinate the mandatory support services (e.g., nutrition and sterilization documentation) to fulfill administrative roles without hiring new, high-cost specialists.
Solidify Emergency & Social FunctionsFormally document and train staff on protocols for immediate, non-refusal emergency care and disaster response (Gawat Darurat and Bencana/KLB/Wabah), ensuring compliance with new patient safety requirements.

Brief Administrative Compliance Highlights

Parallel to the service pivot, administrative compliance must be a priority to meet the July 2026 deadline (estimated):

  • Mandatory Digital Integration: Ensure your Electronic Medical Record (RME) system is fully functional and successfully integrated with the national SIKNAS platform. This is non-negotiable for future licensing and reporting.
  • SDM Licensing Updates: All doctors and health workers must complete the process to convert their licenses (STR) to the new “Seumur Hidup” (Lifetime) status. This simplifies future renewals.
  • New Internal Regulations (PIR): Update the Hospital Internal Regulations to reflect the new patient safety policies, define mandatory minimum services, and clarify clinical governance structures.

Do You Need Expert Guidance on the Transition?

Navigating this complex regulatory shift while managing a constrained budget requires specialized expertise. Whether you need to:

  • Identify opportunities for cheap, high-quality OEM manufacturers to procure necessary but affordable basic medical equipment.
  • Seek advisory consultation to streamline the new SDM, RME, and overall administrative licensing process.
  • Develop a strategic blueprint to create a “Center of Excellence” model that meets the new service requirements and secures future funding.

Product Registration Indonesia specializes in simplifying complex health sector regulations. Let them assist you in transforming regulatory adherence into a strategic advantage, ensuring your hospital thrives beyond the estimated 2026 deadline.

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