Progress of Physician Multi-Site Practice Across China: Policy Evolution and Regional Implementation

On January 12, 2015, the National Health and Family Planning Commission released the “Several Opinions on Promoting and Regulating Physicians’ Multi-Site Practice,”The following mandatory requirements are explicitly stipulated for physicians practicing at multiple institutions: Physicians in the categories of clinical medicine, stomatology, and traditional Chinese medicine are permitted to practice at multiple locations. Physicians engaging in multi-site practice must hold a professional technical title at the intermediate level or above, have engaged in practice within the same specialty for no less than five years, be in good health and capable of fulfilling the duties associated with multi-site practice, and have no record of unsatisfactory performance in their regular physician assessments over the two most recent consecutive cycles.. Unlike in the past,The new policy changes the previous requirement of "obtaining written consent from the primary practice location" to "obtaining consent from the medical institution at the primary practice location," meaning that physicians need only fulfill notification and filing procedures with their primary employing institution. Approval from the primary employer is no longer required to engage in multi-site practice, and the cap on the number of medical institutions where a physician can practice simultaneously has been abolished.

In fact, as early as ten years ago, the former Ministry of Health promulgated an interim regulation “to promote medical exchange and development, improve healthcare standards, ensure medical quality and safety, facilitate public access to medical services, and protect the legitimate rights and interests of patients, physicians, and medical institutions,” which stipulated that physicians could engage in “outbound consultations” upon approval by their affiliated institutions.

In September 2009, the former Ministry of Health issued the "Notice on Issues Concerning Physicians' Multi-Site Practice", with pilot programs implemented in selected regions. It is stated that the reasonable mobility of medical personnel will be steadily promoted to facilitate vertical and horizontal talent exchanges among different medical institutions. The registration of physicians for multi-site practice is being studied and explored, a scheme regarded as truly legitimizing doctors’ “moonlighting.” Notably,The notice at the time also explicitly stipulated that “physicians shall, in principle, practice within the same province, autonomous region, or municipality directly under the Central Government, with no more than three practice locations.”. Subsequently, on November 5, 2011, the former Ministry of Health issued a notice to expand the pilot program for physicians’ multi-site practice, encouraging medical personnel to practice in grassroots and rural areas.

November 5, 2014, formulated by the National Health and Family Planning Commission, the National Development and Reform Commission, the Ministry of Human Resources and Social Security, the State Administration of Traditional Chinese Medicine, and the China Insurance Regulatory Commission“Several Opinions on Promoting and Regulating Physicians’ Multi-Site Practice” (Guo Wei Yi Fa [2014] No. 86) was issued along with a notice. These opinions abolished the regulation limiting the number of practice locations for physicians.Shortly after the issuance of that notice at the end of 2014, the National Health and Family Planning Commission released an official announcement in January of this year titled “Several Opinions on Promoting and Regulating Physicians’ Multi-Site Practice.” The figure below illustrates the timeline of policy developments regarding physicians’ multi-site practice:



VCBeat has compiled and rated the policies and enforcement intensity regarding physicians’ multi-site practice across all provinces, municipalities directly under the central government, and autonomous regions in China (excluding Hong Kong, Macao, and Taiwan). The analysis reveals that although most regions have issued clear policy documents, the actual number of physicians engaging in multi-site practice remains low. According to statistics from public news reports, Gansu Province has the highest number of physicians registered for multi-site practice, with 7,003 practitioners. This achievement is attributed to its explicit policies, which mandate multi-site practice registration for three categories of personnel, thereby resulting in a higher registration volume. Yunnan, Guangdong, and Zhejiang Provinces follow, each with approximately 4,000 practitioners. Notably, the figure of 4,750 for Yunnan Province is derived solely from Kunming, where the implementation measures for managing multi-site practice have been in effect for five years. The chart below illustrates the temporal trends in the number of physicians engaged in multi-site practice across various provinces and municipalities:



Furthermore, it was found that there is no strict proportional relationship between the duration of implementation and the extent of adoption of physicians’ multi-site practice policies. Although in most cases, earlier implementation correlates with more in-depth adoption, as seen in Guangdong, Yunnan, Sichuan, and Beijing, there are exceptions. Some provinces and municipalities, such as Zhejiang, Shanxi, Gansu, and Liaoning, initiated these policies later but have achieved a high level of implementation.

An overview of policies across various provinces and municipalities reveals representative differences in regulatory provisions. For instance, Beijing, Chongqing, Guangdong, Liaoning, Shandong, and Hainan have explicitly stated that the number of hospitals where physicians can practice at multiple sites will no longer be restricted. Shanghai has announced an open, flexible practice platform for outstanding physicians, enabling them to commence medical practice with minimal administrative burden (“ready-to-practice” model). Some regions, such as Chongqing, have opened their doors to medical institutions from overseas, Hong Kong, Macao, and Taiwan, encouraging the establishment of medical facilities through joint ventures, collaborations, or sole proprietorships. Guangdong also stipulates that physicians from Hong Kong, Macao, and Taiwan who have obtained short-term medical practice qualifications may engage in multi-site practice within the province. Regarding private clinics, Hebei Province allows general practitioners to work full-time or part-time in primary healthcare institutions, as well as to independently establish individual clinics or jointly operate clinics with others. Shandong Province similarly permits qualified physicians to open private clinics. Furthermore, Hainan Province encourages the full utilization of internet technologies, such as telemedicine, to facilitate multi-site practice, implementing a distinctive “cloud registration” system and establishing online clinics.

Furthermore, in accordance with the new policy provisions, the registration process for physicians' multi-site practice has been streamlined.In areas where conditions are ripe, regional registration may be independently explored based on local circumstances to promote the full and orderly mobility of healthcare professionals within the region.It can be seen that provinces such as Guangdong, Jiangsu, Shandong, Hunan, and Hainan have proposed exploring provincial regional registration systems tailored to local conditions. Furthermore, althoughThe new policy explicitly states that, except for the aforementioned circumstances, individuals holding hospital-level leadership positions in public hospitals are generally prohibited from engaging in other forms of multi-site practice.However, Zhejiang Province has proposed that leaders serving as hospital directors and department heads may also engage in multi-site practice. It has innovatively introduced regulations for independent practice, proposing to explore the implementation of independent practice for medical professionals with the title of associate chief physician (or above) and for technical staff in four scarce specialties—emergency medicine, radiology, ultrasonography, and pathology—on the basis of physicians’ multi-site practice.

The table below presents the rating of the implementation level of multi-site practice for physicians across various provinces and cities.The assessment results in the table are primarily based on news reports regarding policy implementation issued by various provinces; they may contain biases and are for reference only.：



Furthermore, while multi-site practice and independent practice by physicians are both reasonable and legal abroad, doctors in China have yet to be liberated from the hospital system. They still rely on hospital platforms for their professional development. How much longer will it take to achieve true independence for physicians? It is difficult to say at this stage, as numerous challenges remain in the implementation of multi-site practice. These issues urgently require collaborative discussion and resolution by policymakers and society as a whole.

1. Most physicians are adopting a wait-and-see approach. While the policies are well-designed, their effective implementation remains a primary concern for frontline doctors and those at tertiary hospitals. First, hospital administrators must establish concrete, actionable agreements regarding the allocation of physicians’ responsibilities, rights, and time, thereby safeguarding the interests of three parties: the hospital (as the primary practice site), the physicians themselves, and the patients.

2. Can doctors shed their psychological burdens and take the first step, emboldened by policy support? Can hospitals prioritize the broader social interest and place patient welfare first, truly embodying the benevolent spirit of the medical profession by encouraging and supporting their physicians in engaging in multi-site or independent practice? This issue extends beyond mere regulatory compliance; it involves deeper social and ethical considerations, such as respect for human nature and the spirit of dedication. For instance, physicians may fear that multi-site practice could lead to institutional barriers to career advancement, while hospitals may be reluctant to release talent they have cultivated to competing institutions. How can these conflicting interests be effectively reconciled? Can legal mandates alone provide a solution? These questions warrant thorough reflection.

3. In situations where the law fails to fully safeguard individual interests, some capable physicians still engage in unauthorized off-site practice (“moonlighting”). Although this entails certain risks and operates within a legal gray area, the high financial rewards lead these doctors to take such chances. The current reality is that young physicians still rely on the technical platforms of public hospitals for substantial career development, while those who can practice independently through “moonlighting” are typically highly skilled or experienced retired physicians—a scarce resource indeed.

In fact, under the new policy regulations, clear provisions have been made regarding the aforementioned issues. For instance, medical institutions serving as the physician’s primary practice site are required to support physicians’ multi-site practice, scientifically and reasonably define physicians’ job responsibilities, and improve specific management measures pertaining to performance evaluation, rewards, disciplinary actions, and competitive appointment.Physicians’ professional title promotions, academic standing, and other related matters shall not be adversely affected by their engagement in multi-site practice. Physicians practicing at multiple sites shall separately enter into an employment (labor) contract with their primary practice location and a service agreement with each of the other medical institutions where they intend to practice, clearly defining the respective rights and obligations of all parties.Therefore, local hospitals across the country should adhere to national regulations, strictly implement policies and laws, explore the liberalization of multi-site practice for physicians, and encourage independent practice. It is believed that through concerted efforts across regions, we can gradually break down the entrenched barriers of the old system and psychological resistance, dismantle the long-standing institutional walls within hospitals, and achieve the free flow of medical talent resources.

Appendix: Overview of Multi-Site Practice Policies for Physicians Across Provinces and Cities